Department of Education Issues HEERF Clarifications to Common Questions

On March 19, 2021, the Department of Education (DOE) issued several additional amendments to the frequently asked questions (FAQs) for the various programs that have been authorized under the Higher Education Emergency Relief Funds program (HEERF) from the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (HEERF I), the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (HEERF II) and the American Rescue Plan (ARP) (HEERF III). 

  • The period of permitted usage for all of the funds has been extended to cover the period from March 13, 2020 (the date of the declaration of the national emergency) to the expiration of the funds as noted in each piece of legislation.
  • HEERF permits the usage of funds for students who are enrolled primarily in online programs, which was not permitted under HEERF I.
  • For funds awarded under HEERF II, institutions are required to grant these funds to students with exceptional needs.  The updated FAQs note that these grants can be awarded to “students who receive Pell Grants, in awarding financial aid grants to students.  However, students do not need to be only Pell recipients or students who are eligible for Pell grants.”  While an explicit formula is not given, institutions must develop a methodology and retain documentation on how they believe they have fulfilled this requirement.
  • Institutions are permitted to have these funds appropriated to reduce outstanding balances on student accounts, assuming that students have affirmed this and it was not a precondition for receiving the funding.
  • Institutions can use HEERF grant funds to make financial aid grants to non-degree seeking, non-credit, dual enrollment, and continuing education students.  Students who are qualified aliens, as defined within 8 U.S.C. § 1641 (including refugees and persons granted asylum), may also receive HEERF financial aid grants.
  • Institutions are permitted to charge indirect costs to these grants, except for the student portion.  These costs must be reasonable and necessary.
  • Institutions may use CRRSAA funds and unspent CARES Act funds to pay for employee benefits costs as payroll costs if (1) such costs are newly associated with coronavirus, and (2) the costs were incurred on or after March 13, 2020, the date of the declaration of the national emergency due to the COVID-19 pandemic.
  • Institutions may choose to make financial aid grants to students who have left school for any reason during the period of the national emergency, beginning March 13, 2020, the date of the declaration of the national emergency.

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