HEERF III is Finally Here – A Quick Guide to the Changes for Student Portion

The following is a brief summary of some of the more significant questions that were answered by the U.S. Department of Education (Department) when they published new frequently asked questions (FAQs) in conjunction with the student aid portion of the funds that are now available under the American Rescue Plan Act (Act).

A reminder that all previous FAQs still apply, unless directly superseded by a subsequent FAQ. You should carefully review all of the FAQs as these documents have not been carried forward into the current document. 

What types of students can obtain Higher Education Emergency Relief (HEERF) relief funds?

Students are no longer required to be eligible for Title IV student financial aid in order to receive HEERF grants. That includes citizens, permanent residents, refugees, asylum seekers, Deferred Action for Childhood Arrival (DACA) recipients, other DREAMers, and similar undocumented students. Students studying abroad may receive HEERF emergency financial aid grants from the recipient institution where they are enrolled. These students must meet the criteria based on prioritizing exceptional needs that the institution has established for distributing its HEERF emergency financial aid grants.

What about concerns regarding discrimination when awarding the funds?

HEERF grantees must not distribute student emergency financial aid grants in a manner that discriminates against individuals on the basis of race, color, national origin, disability, or sex. See, e.g., 42 U.S.C. § 2000d et seq., (Title VI), 29 U.S.C. § 701 et seq. (Rehabilitation Act), 20 U.S.C. § 1681 (Title IX).

The Department finally provides better clarification of what they mean by exceptional need. This concept was addressed in the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) grants:

Other types of exceptional need could include students who may be eligible for other federal or state need-based aid or have faced significant unexpected expenses either for themselves or that would affect their financial circumstances, such as the loss of employment, reduced income, or food or housing insecurity. In addition, the CRRSAA explicitly states that emergency financial aid grants to students may be provided to those exclusively enrolled in distance education provided they have exceptional needs. The Department encourages institutions to prioritize domestic students, especially undergraduates, in allocating this funding.

What are preconditions you can’t impose when determining exceptional need?

An institution may not do any of the following (e.g., (1) establish a minimum GPA requirement, (2) imposing other academic or athletic performance or good standing requirements, (3) requiring continued enrollment in the institution or (4) required the student to first pay any outstanding debt or balance that results in failure to prioritize students with exceptional need.

How will these grants impact future federal awards to students?

They will not impact awarding. Aid (in the form of grants or low-interest loans) received by victims of an emergency from a federal or state entity for the purpose of providing financial relief is not counted as income for calculating a family’s Expected Family Contribution (EFC) under the Federal Methodology or as estimated financial assistance for packaging purposes.

What happens if the student doesn’t cash their check?

If a student does not cash their emergency financial aid grant check by a reasonable date, the institution may choose to void the check and redistribute the funds to other students by the end of their HEERF grant performance period. Institutions should engage in reasonable attempts to contact a student prior to voiding a check for an emergency financial aid grant and should document the procedures, policies, and general student contact efforts made and followed as part of their administration of their HEERF grants.

I have questions about the institutional portion, where I learn more?

We have an article covering institutional questions at www.schneiderdowns.com/our-thoughts-on/heerf-iii-changes-institutional-portion.

You can read the full set of FAQs from the Department at www.schneiderdowns.com/our-thoughts-on/heerf-iii-changes-institutional-portion.

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