The Coronavirus Aid, Relief, and Economic Security (CARES) Act includes a Higher Education Emergency Relief Fund (HEERF) that provides more than $14 billion in emergency funding to higher education. Of those funds, more than $6 billion must go directly to students in the form of emergency financial aid grants (HEERF-student share) for expenses related to the disruption of campus operations due to the COVID-19 crisis. On April 9, 2020, the ED published a list of individual institutional allocations, a certification form that must be signed and returned in order to access the funds, and a letter from Secretary Betsy DeVos outlining ED's implementation of the CARES Act program. On April 21, 2020, ED released additional clarification on student eligibility and allowable uses of HEERF-student share funds.

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Fast Facts

• Not Title IV Aid, but Title IV Eligibility Required: While HEERF-student share dollars are not Title IV aid, ED's final rule published June 17 states that students must meet Title IV eligibility requirements in order to receive HEERF emergency grants.

• Expense v. Need: HEERF-student share dollars are to aid students for expenses related to the disruption of campus operations due to the coronavirus; this is different than a change in a student's financial need due to COVID-19, which could be a result of a loss of income rather than new expenses.

• Direct to Students: Institutions must pay HEERF-student share emergency grants directly to students and may not apply the grants toward outstanding institutional charges.

 

Washington University of Science and Technology completed to provide all the HEERF fund as of 4/30/2021

Higher Education Emergency Relief Fund Report - Student portion - 04/30/2021 

 

Frequently Asked Questions and Answers

Q: Which students are eligible to receive HEERF-student emergency funds?

A: The April 21 guidance, as well as the June 17 final rule, states that students must meet Title IV eligibility requirements in order to receive HEERF emergency funds. After confirming the Title IV eligibility requirements, the institution retains discretion over which students will receive HEERF-student share funds. According to the certification agreement, institutions are required to comply with "all applicable laws including non-discrimination laws" when determining who will receive the emergency grants. Beyond that stipulation, there are no further prohibitions of specific students in the certification agreement. Therefore, any Title IV-eligible student may receive HEERF-student share funds, unless prohibited by another law, which would include DACA students, undocumented students and international students. 

There have been many questions about awarding HEERF-student share funds to international students, online students, and undocumented students. 

International and Undocumented Students: ED's April 21 guidance states that students must meet Title IV eligibility requirements in order to receive HEERF-student share funds. Therefore, international and undocumented students are not eligible to receive emergency grants. 

Online Students: Students who were enrolled exclusively in online programs on March 13 (the date of President Trump's national emergency proclamation) are not eligible for HEERF-student share funds, per ED's April 21 guidance.

 

Q: Do we have to have a student's Free Application for Federal Student Aid (FAFSA) on file in order to disburse HEERF-student funds to students?

A: While ED's guidance does not require a FAFSA, having one on file would be the only practicable way for an institution to determine that a student is eligible to participate in the Title IV programs and meet all of applicable student eligibility requirements. Without having a FAFSA on file, schools would need to verify that a student meets the Title IV eligibility criteria. In its HEERF FAQ document, ED states the following: "The criteria to participate in programs under Section 484 of the [Higher Education Act (HEA)] include but are not limited to the following: U.S. citizenship or eligible noncitizen; a valid Social Security number; registration with Selective Service (if the student is male); and a high school diploma, GED, or completion of high school in an approved homeschool setting." Beyond this guidance, a school will need to make its own decisions on how to document if a student is or could be Title IV-eligible when awarding HEERF grants to students. 

Institutions that choose to take advantage of ED's non-enforcement policy applicable for disbursements prior to June 17 and not limit eligibility only to students who meet the Section 484 student eligibility requirements must still consider, with the assistance of legal counsel, the applicability of the Personal Responsibility and Work Opportunity Reconciliation Act, and whether and how they will document student citizenship status.

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Q: What eligibility criteria are in section 484 of the Higher Education Act (HEA)?

A: Section 484 of the HEA states that Title IV eligible students must:

•  

  • Be enrolled or accepted for enrollment in a degree or certificate program. 

  • Not be enrolled in elementary or secondary school.

  • For currently enrolled students, be making satisfactory academic progress.

  • Not owe an overpayment on Title IV grants or loans.

  • Not be in default on a Title IV loan.

  • File "as part of the original financial aid application process" a certification that includes

    • A statement of educational purpose.

    • Student's SSN.

  • Be a U.S. citizen or national, permanent resident, or other eligible noncitizen.

  • Have returned fraudulently obtained Title IV funds if convicted of or pled guilty or no contest to charges. 

  • Not have fraudulently received Title IV loans in excess of annual or aggregate limits.

  • Have repaid Title IV loan amounts in excess of annual or aggregate limits if obtained inadvertently.

  • Have Selective Service registration verified.

  • Have Social Security Number verified.

  • Not have a federal or state conviction for drug possession or sale, with certain time limitations.

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Q: Is verification a student eligibility requirement under section 484 of the HEA?

A: The verification requirements are not included in HEA Section 484, however, the V4 and V5 selection groups include re-submission of the statement of educational purpose, which is in Section 484. 

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Q: Given all the uncertainty over the student eligibility requirements, how should we proceed?

A: Lacking further guidance, the most conservative approach for institutions seeking to distribute HEERF dollars within the near future would be to limit eligibility to students who have already met all Title IV eligibility requirements by completing a FAFSA and resolving all C codes and completing verification, if selected by ED.

Institutions that choose to take advantage of ED's non-enforcement policy applicable for disbursements prior to June 17 and not limit eligibility only to students who meet the Section 484 student eligibility requirements must still consider, with the assistance of legal counsel, the applicability of the Personal Responsibility and Work Opportunity Reconciliation Act. 

 

Q: Can a school reimburse itself for any funds it has spent on students related to COVID-19, including refunds for room and board?

A: Institutions may not use the student portion of the HEERF funds to reimburse themselves for tuition or room and board refunds. Schools may use the institutional portion of the HEERF funds to reimburse themselves for refunds made to students on or after March 13, 2020, issued for room and board, tuition, and other fees as a result of significant changes to the delivery of instruction, due to the novel coronavirus. 

 

Q: Can schools apply student emergency grants to a student's account in order to pay off outstanding balances?

A: ED has made clear that the emergency cash grants to students cannot be applied toward outstanding balances, and must be disbursed directly to students, using means such as check, electronic funds transfer, payment app, or pre-loaded debit card. Additionally, HEERF-student funds may pass through an institution's student information system/student accounts system as long as the funds are set up as to not pay the student's account balance.

 

Q: Can institutions use HEERF-student funds to reimburse themselves for emergency cash grants that a school has already disbursed to students?

A: Institutions may use HEERF-student funds to reimburse themselves if they provided an emergency grant to a student that meets the same eligibility criteria of HEERF grant funds on or after March 27 — the day the CARES Act became law. In such instances, ED would consider the institution to have made an advance payment of HEERF dollars to students in anticipation of receipt of the federal deposit.

 

Q: Can schools use HEERF-student funds to cover the cost of resources the school provided directly to students, such as giving a student a computer or internet hotspot or filling an on-campus food pantry?

A: No, the HEERF funds must be distributed to students in the form of cash grants. The funds must go from the school to the student, and the student can then use their grant to cover coronavirus-related expenses.

 

Q: By what date must HEERF-student funds be distributed? Can an institution save funds for award year 2020-21?

A: All institutions were given 1 calendar year (365 days) from the date of award in their HEERF Grant Award Notification (GAN) to complete the performance of their HEERF grant. For example, if a grantee received a GAN on April 7, 2020, the one calendar year period of performance for their HEERF grant would be through April 6, 2021.

 

Q: How should an institution determine which students receive emergency grants and the amount of each grant? 

A: Institutions must identify students who have incurred expenses related to the disruption of campus operations due to the novel coronavirus. This can be achieved either through an application form, or by identifying groups of students who have incurred the same expense due to the campus disruption, such as students enrolled in an art class who must now purchase their own supplies. ED encourages institutions to prioritize awarding of emergency grants to students with the greatest need, and suggests using the maximum annual Pell Grant amount as the maximum emergency grant, but these are not requirements; institutions have discretion in this area. 

 

Q: What are the reporting requirements for the HEERF-student funds?

A: Students who receive funding from their institutions are not required to record or track how it is spent. Schools, however, will be required to report:

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  • An acknowledgement that the institution signed and returned the certification and agreement form and that the institution has used, or intends to use the funds to provide the mandated amount of at least 50% of the emergency financial aid grants to students.

  • The total amount of funds that the institution will receive, or has received under the HEERF student portion.

  • Of those funds, the total amount that has been distributed to students as of the date of reporting (i.e. the first 30-day deadline, and then every 45 days thereafter).

  • The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and therefore eligible to receive an emergency financial aid grant.

  • The total number of students who have received an emergency financial aid grant.

  • How the institution determined which students did, or will receive emergency financial aid grants and how much funding they did, or will receive.

  • Any instructions, directions, or guidance provided by the institution to students concerning the emergency financial aid grants.

The first report was generally due 30 days after the Department originally obligated funds to the institution for the Section 18004(a)(1) Student Portion.

Subsequent reports are due quarterly and must be posted no later than 10 days after the calendar quarter (October 10, January 10, April 10, July 10).

Institutions should make this information easily accessible to the public via the institution's website.

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Q: Will HEERF emergency grants be counted as income for the calculation of Expected Family Contribution (EFC) or estimated financial assistance (EFA)?

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A: No. ED's April 3 Electronic Announcement clarifies that any aid received by victims of an emergency by either a federal or state entity for purposes of providing financial relief will not be counted as income for the calculation of EFC, or as EFA.

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Q: The certification agreement says that schools, as part of the reporting requirement, have to document and report that they've continued to pay all employees/contractors to "the greatest extent practicable, explaining in detail all specific actions and decisions related thereto." Does this mean an institution will be at risk of losing funds if employees are furloughed or laid off? Does "all employees" include Federal Work-Study (FWS) and non-FWS student employees?

A: NASFAA's interpretation is that the language "to the greatest extent practicable" is an acknowledgement by ED that it is unreasonable to expect an institution to continue to pay all employees/contractors during a national crisis. If an institution is making a good faith effort to pay employees to the extent possible, and can document accordingly, the institution should not be concerned about this provision.

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Q: Are institutions required to determine all student eligibility requirements in HEA Section 484, or just the citizenship requirement?

A: HEERF funds are not Title IV federal student aid funds, but only students who are or could be eligible to participate the Title IV programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (HEA) [20 USC 1091(a)] may receive these funds.

•  

  • Be enrolled or accepted for enrollment in a degree or certificate program. 

  • Not be enrolled in elementary or secondary school.

  • For currently enrolled students, be making satisfactory academic progress.

  • Not owe an overpayment on Title IV grants or loans.

  • Not be in default on a Title IV loan.

  • File "as part of the original financial aid application process" a certification that includes

    • A statement of educational purpose.

    • Student's SSN.

  • Be a U.S. citizen or national, permanent resident, or other eligible noncitizen.

  • Have returned fraudulently obtained Title IV funds if convicted of or pled guilty or no contest to charges. 

  • Not have fraudulently received Title IV loans in excess of annual or aggregate limits.

  • Have repaid Title IV loan amounts in excess of annual or aggregate limits if obtained inadvertently.

  • Have Selective Service registration verified.

  • Have Social Security Number verified.

  • Not have a federal or state conviction for drug possession or sale, with certain time limitations.

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Q: How can institutions confirm that their students meet the eligibility requirements in HEA section 484 without collecting the FAFSA?

A: While the Interim Final Rule and ED's guidance do not require a FAFSA to demonstrate Title IV eligibility, having a FAFSA on file would be the most practicable way for an institution to determine that a student is eligible to participate in the Title IV federal student aid programs and meets all general student eligibility criteria in Section 484 of the HEA. The Interim Final Rule is unclear on whether a prior-year FAFSA is acceptable; therefore, accepting one is at the school's discretion. Just remember that a prior year's FAFSA will not have updated default and overpayment information, Statement of Educational Purpose, etc.

Without having a FAFSA on file, the school would need to confirm by some other method that a student meets all of the Title IV eligibility criteria. Under the Interim Final Rule, a student who chooses not to fill out a FAFSA but who otherwise meets the Title IV eligibility criteria, may self-certify his, her, or their eligibility by completing an application designed by the institution in which the student attests under the penalty of perjury to meeting the requirements of Section 484 of the HEA. It is entirely up to the school to decide whether it implements such a self-certification and whether it wants to assume any potential liability for conflicting information that might arise if a FAFSA is later submitted.

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Q: Must verification be completed before awarding HEERF-student funds to students who complete the FAFSA?

A: We cannot answer whether verification would be required, but it is our understanding that verification would not be required because:

1) HEERF grants are not need-based funds under the CARES Act; and 2) verification is not a general student eligibility requirement under Section 484 of the HEA.

However, the V4 and V5 Verification Tracking Groups include re-submission of the Statement of Educational Purpose, which is in Section 484.

 

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HEERF II

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The Consolidated Appropriations Act, 2021 included additional COVID-19 relief through the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act. This new COVID stimulus bill included $23 billion for higher education institutions and students, using the same Higher Education Emergency Relief Fund (HEERF) model established in the Coronavirus Aid, Relief and Economic Security (CARES) Act.

 

Washington University of Science and Technology received $134,360 of HEERF II fund. The fund will be distributed evenly during Summer 2021, Fall 2021, Winter 2022, and Spring 2022 quarters.

 

Eligibility

Institutions may award student grants for:

• any component of their cost of attendance

• emergency costs that arise due to coronavirus, such as:
   

  • tuition

  • food

  • housing

  • health care (including mental)

  • child care

• International students are not eligible to receive the fund as in FAQ.

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Frequently Asked Questions and Answers

Q: Which students are eligible to receive HEERF II emergency funds?

A: Notably, similar to CARES, the CRRSAA includes no student eligibility requirements, however, institutions are required to prioritize grants to students with exceptional financial need, such as those who receive Pell Grants. The HEERF II funds can be awarded to online students as well. As a reminder, after a confusing and inconsistent implementation, Education Secretary Betsy DeVos issued an Interim Final Rule (IFR) on June 17, 2020, limiting eligibility for CARES Act emergency financial aid grants to students who met the eligibility criteria for Title IV student aid under Section 484 of the Higher Education Act (HEA). ED has confirmed that the IFR does not apply to HEERF II funds, however they believe the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996, which prohibits certain noncitizens from receiving federal benefits, applies to HEERF II funds, making DACA, undocumented, and international students ineligible.) It's important to note that ED has not issued written guidance to clarify whether or not undocumented, DACA, or international students may receive these funds, however a Trump administration official stated verbally that these students were not eligible.

 

Q: I'm a proprietary school. What can I use my funds for?

A: While $681 million is allocated for use by for-profit, or proprietary institutions, any funds received by proprietary institutions would only be allowed to be used for emergency grants for students. See the chart above for allowable uses for students. 

 

Q: Do I need to draw down my HEERF II funds by a certain deadline?

A: Schools that previously received Higher Education Emergency Relief Fund (HEERF) grant funds under the CARES Act (HEERF I funds) are required to start drawing down funds from both the student and institutional portions of HEERF II funds within 90 days of receiving their respective supplemental HEERF II award notifications.

Additionally, schools should not simply draw down it's entire HEERF II student and institutional allocations at once. All HEERF funds must be drawn down only as necessary to meet immediate cash need for spending the funds. That is, schools must spend funds for student grants within 15 calendar days of drawing down those funds from G5, whereas funds used for purposes other than the awarding of student grants must be spent within three calendar days of draw down.

 

Q: If I received funds through the CARES Act do I need to do anything to receive my new allocation?

A: While awards for institutions that previously received CARES Act HEERF funds will be processed automatically, ED indicated that this could take several weeks due to staffing and technology limitations. Institutions that have already submitted their HEERF annual report via the Annual Report Data Collection System will receive priority in supplemental funds disbursement. Institutions that did not receive either or both of the institutional share and student share of CARES Act funds will need to submit applications following the CARES Act process to receive supplemental allocations. New applications are due by April 15, 2021, but institutions are encouraged to apply as quickly as possible because ED indicated that they plan to process applications in the order they are received.

 

Q: What Is the deadline for schools to apply for Higher Education Emergency Relief Funds II?

A: For institutions that received HEERF I funds, applications are not required to receive supplemental awards under HEERF II. Public and nonprofit Institutions that did not previously receive CARES Act funding (HEERF I) must submit their applications for the CRRSAA student aid portion and institutional portion (HEERF II) by April 15, 2021. Likewise, proprietary institutions must submit their applications for the CRRSAA student aid portion by April 15, 2021, regardless if they have previously received funds under the CARES Act (HEERF I). 

 

Q: How long does my institution have to spend our HEERF II funds? 

A: An institution has one year from the date the school's supplemental grant was processed to distribute the HEERF II funds. For example, if a school's supplemental HEERF II funds were processed on January 20, 2021, the funds must be spent on or before January 19, 2022. If funds are not spent within the year allotted, a no-cost extension may be requested if applicable. Additionally, grants received by institutions that were created through the CARES Act in March of last year are still subject to their original one year deadline. 

 

Q: Will HEERF emergency grants be counted as income for the calculation of Expected Family Contribution (EFC) or estimated financial assistance (EFA)?

A: It is NASFAA's understanding based on conversations with ED that HEERF II grants awarded to students under CRRSAA are also not treated as EFA when packaging students. Likewise, HEERF II grants are not treated as taxable income or untaxed income for Title IV federal student aid purposes.

 

Q: Can all enrolled students, as well as students enrolled at any point since the declaration of a national emergency (including undocumented, DACA, international, non-credit, refugee students, dual enrollment, continuing education, non-degree, and other non-Title IV eligible) receive HEERF II Funds?

A: Colleges can use HEERF II and unspent CARES funds to support certain students who are not Title IV eligible. That includes non-degree seeking, non-credit, dual enrollment, and continuing education students. The Department is exploring additional opportunities – including with other agencies - for colleges to support other vulnerable students (e.g., undocumented, DACA, and international students) during the national coronavirus pandemic emergency. As always, students have discretion about how they receive their grants and schools must receive affirmative consent from students before using an emergency financial aid grant to satisfy outstanding bills.

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Q: Can students who have left school (for any reason) at any time since the declaration of the national emergency can receive HEERF I and HEERF II funds retroactively, as was allowed for students who had graduated using HEERF I funds? 

A: Yes, schools may choose to make financial aid grants to students who have left school for any reason during the period of the national emergency beginning on March 13, 2020. 

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Q: Are employee benefits covered under “payroll” in section 314(c)(1) of CRRSAA?

A: Yes, colleges can use HEERF II funds and unspent HEERF I funds to pay for employee benefits for costs incurred on or after December 27, 2020. However, the Department’s current guidance is that colleges cannot currently use HEERF II funds to cover costs prior to December 27th, or use HEERF I funds under the expanded use of funds flexibility offered under CRRSAA for expenses incurred prior to that date. The Department will update the HEERF community of any change in interpretation through future guidance documents.

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Q: If my school has unexpended CARES HEERF funds as of 12/27/2020, can those funds be spent using the CRRSAA flexibilities for payment periods before 12/27/2020 (the date the Act was signed into law)?

A: Yes, ED has clarified that institutions now have expanded flexibility to use unliquidated (unspent) funds effective December 27, 2020 (the date of enactment of the CRRSAA), for costs incurred on or after March 13, 2020, the date on which the President declared a national emergency due to the COVID-19 pandemic (85 FR 15337).

 

 

HEERF III

The American Rescue Plan (ARP) included additional COVID-19 relief for institutions of higher education. This new COVID stimulus bill included $40 billion, available through September 30, 2023, for higher education institutions and students, using the same Higher Education Emergency Relief Fund (HEERF) model established in the Coronavirus Aid, Relief and Economic Security (CARES) Act.

Washington University of Science and Technology received $95,391 of HEERF III fund. The fund will be distributed evenly during Summer 2021, Fall 2021, Winter 2022, and Spring 2022 quarters.

 

Eligibility

It is the same as HEERF II

Frequently Asked Questions and Answers

Q: Which students are eligible to receive HEERF III emergency funds?

A: Similar to the HEERF II funds, the HEERF III funds include no student eligibility requirements either. However, institutions are required to prioritize grants to students with exceptional financial need, such as those who receive Pell Grants. The HEERF III funds can be awarded to online students as well. Eligible student groups include citizens, permanent residents, international students, refugees, asylum seekers, DACA recipients, other DREAMers, and similar undocumented students.

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Q: I'm a proprietary school. What can I use my funds for?

A: While $396 million is allocated for use by for-profit, or proprietary institutions, any funds received by proprietary institutions would only be allowed to be used for emergency grants for students. See the chart above for allowable uses for students. 

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Q: Do I need to draw down my HEERF III funds by a certain deadline?

A: Schools that previously received either HEERF I or HEERF II funds are required to start drawing down funds from both the student and institutional portions of HEERF II funds within 90 days of receiving their respective supplemental HEERF II award notifications. ED has not yet issued guidance on the amount of time institutions have to begin drawing down HEERF III funds. Additionally, schools should not simply draw down it's entire HEERF III student and institutional allocations at once. All HEERF funds must be drawn down only as necessary to meet immediate cash need for spending the funds. That is, schools must spend funds for student grants within 15 calendar days of drawing down those funds from G5, whereas funds used for purposes other than the awarding of student grants must be spent within three calendar days of draw down.

 

Q: Will HEERF emergency grants be counted as income for the calculation of Expected Family Contribution (EFC) or estimated financial assistance (EFA)?

A: No. Emergency financial aid grants made by a federal agency, State, Indian
tribe, higher education institution or scholarship-granting organization (including a tribal organization) to a student because of an event related to the COVID-19 national
emergency are not included in the student's gross income.

 

Q: How long does my institution have to spend our HEERF III funds? 

A: Institutions generally must expend their HEERF grant funds within one year
from the date when the Department processed the most recent obligation of funds for
each specific grant. Thus, institutions that received a supplemental award under ARP
have one year to spend all remaining CRRSAA, CARES, and new ARP funds for each
grant from the date their ARP supplemental award is made. The specific period of
performance will be indicated in Box 6 of your institution’s GAN.

 

Q: If I received funds through the CARES Act or the CRRSA Act do I need to do anything to receive my HEERF III allocation?

A: No, if your public or non-profit institution received funding through either the CARES or CRRSA Act you do not need to do anything to receive your institutions allocation. 

To assist with management and oversight, proprietary institutions must first submit the Required Proprietary Institution Certification form signed by the proprietary institution’s President  or CEO and any owners with at least 25% ownership in the institution. Proprietary institutions must submit the form by August 11, 2021, as specified in the Federal Register. Once that certification document has been completed, institutions must email it to HEERFARP4@ed.gov.

 

Q: What are the reporting requirements for the HEERF III funds?

A: Institutions will be required to post the Quarterly Institutional Public Reporting Form and Quarterly Student Public Reporting Form for HEERF III funds to their websites by the tenth day following the end of each calendar quarter. ED acknowledges that because it never affirmatively established HEERF II reporting requirements, it is extending the deadline by which institutions must submit retroactive reports for HEERF II to the end of the second calendar quarter, which is June 30, 2021. HEERF III funds will also be subject to the annual reporting requirement in early 2022. Watch Today's News for more information on HEERF III reporting requirements.

 

Reference

Department of Education (https://www2.ed.gov/programs/heerf/index.html)

National Association of Student Financial Aid Administrators (https://www.nasfaa.org/covid19_heerf)