HEERF III is Finally Here – Why Your Institution Needs to Understand Practices to Monitor and Suppress COVID-19

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 FAQs in conjunction with the institutional aid portion of the funds that are now available under the American Rescue Plan Act (ARP).

This article specifically discusses the requirements under ARP to “implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines.”

What are the desired evidence-based outcomes that are desired as a part of the Act?

There are two main outcomes that are desired:

(a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and

(b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act (HEA).

What are the expectations by the Department on how institutions should be using these funds to mitigate COVID-19?

The Department has outlined four buckets that would be permissible and demonstrate compliance of ARP requirements. The below are examples of allowable expenditures and activities include, but are not limited to, costs associated with the following:

Testing:

• Establishing a diagnostic or screening testing strategy, such as setting up a testing site, purchasing tests, or hiring additional personnel to administer tests.
• Hiring personnel to support contact tracing efforts in collaboration with local public health authorities.

Prevention:

• Costs related to setting up vaccination sites on or off campus to bring the vaccine to students, faculty, and staff, including bringing sites to rural and satellite locations, and costs associated with building awareness and confidence of the vaccine among students.
• Providing masks and other personal protective equipment to students, faculty, and staff.
• Supporting clean and sanitary campus environments, including purchasing hand sanitizer and handwashing stations that can be placed throughout the campus.
• Cleaning and disinfection.
• Enhancing ventilation in classrooms or common areas.
• Using mask campaigns to increase mask compliance on campus.
• Implementing physical distancing guidelines, such as modified layouts.
• Costs associated with vaccination efforts.
• Redesigning food service facilities.
• Developing training and communication systems to communicate with students.
• Cost associated with campus and local outreach on the benefits of vaccination as a virus-mitigation strategy.

Reducing Barriers to Vaccination:

• Paying for time off for staff to get the vaccine.
• Providing sick leave to employees to get vaccinated.
• Spreading awareness and building confidence in getting vaccinated, including setting up clinics for students to receive vaccinations, or other confidence and awareness building efforts.

Supporting Students:

• Procuring additional space both on or off campus to house students, and supporting other costs associated with meeting the basic needs of students in isolation and quarantine.
• Providing academic support services and mental health services for students in isolation or quarantine.
• Supporting coping and resilience for students.

Additionally, the CDC has developed several COVID-19-focused resources tailored to institutions of higher education available at www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/index.html, including “Considerations for Institutions of Higher Education” at www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/considerations.html.

Also relevant are those activities found on the Department’s Best Practices Clearinghouse.

What are the direct outreach activities that are mandated under the Act?

This requires institutions to provide notice to financial aid applicants and current financial aid recipients that they may be able to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.

The Office of Postsecondary Education published guidance in January 2021 reminding financial aid administrators that they may use professional judgment to reduce or adjust to zero the income earned from work for a student and/or parent if the student or parent has received unemployment benefits. As such, institutions should work to disseminate this opportunity widely for their financial aid applicants and make use of the professional judgment authority as needed.

“Direct outreach” requires an institution to actively engage financial aid applicants and recipients regarding the opportunity to receive a financial aid adjustment. Such outreach should be more than a passive notification of the opportunity to receive a financial aid adjustment, such as posting this opportunity on the institution’s website. Direct outreach is not considered advertising or recruiting. Direct outreach could include, but is not limited to, any of the following:

• Email to students who receive financial aid,
• Mail to students who receive financial aid,
• Phone or voice communication,
• Webinar invitations, and
• In-person interviews or meetings.

Please note that direct outreach does not require in-person interaction to financial aid applicants. Additionally, grantees are reminded that marketing is an impermissible use of HEERF III funds.

Is there a minimum threshold that institutions are required to meet in order to demonstrate permissible use of these funds?

Congress did not set a specific threshold or amount that institutions must use to implement these two required activities. As such, recognizing that each institution’s needs and circumstances are different, institutions should be guided by the Cost Principles in 200 CFR part 200 subpart E, which require that an institution spend a reasonable and necessary portion of its HEERF grant funds in order to successfully implement these two required grant activities.

Any institution that receives an ARP (a)(1) Institutional Portion award (both supplemental awards and new awards) or ARP (a)(2) or (a)(3) award must implement these two required activities as part of the implementation of its HEERF III grant, provided it has not allocated its entire institutional portion to emergency financial aid grants for students.

How will my institution be required to document these activities?

Institutions should document how they implemented these two required activities consistent with 2 CFR § 200.334. Specifically, institutions should document (1) the strategies used to monitor and suppress COVID-19, (2) the evidence to support those strategies, (3) how those strategies were in accordance with public health guidelines, (4) the manner and extent of the direct outreach the institution conducted to financial aid applicants, and (5) how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. The Department is exploring following up by collecting more information on an institution’s implementation of these two required activities in the 2021 HEERF Annual Report to be submitted in early 2022.

Related Articles

• HEERF III is Finally Here – Some Administrative Reminders
• HEERF III is Finally Here – A Quick Guide to the Changes for Student Portion
• HEERF III is Finally Here – A Quick Guide to the Changes for Institutional Portion

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