While the pandemic has had monumental impacts on higher education institutions and their students, the passage of two legislative acts have attempted to alleviate some of its financial consequences. Our education professionals have compiled all the guidance available from the Department of Education regarding HEERF and HEERF II funds for our clients and friends in higher education to help you understand the opportunities available to support your students and operations:
HEERF
Passed in the early days of the pandemic, the Coronavirus Aid, Relief, and Economic Security (CARES) Act established the Higher Education Emergency Relief Fund (HEERF), with more than $14 billion allocated to higher education. Of that, more than $6 billion was required to go directly to students in the form of emergency financial aid grants.
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Periods of Funds Availability
Institutions of higher education (IHEs) have one calendar year from the date of their award to expend funds unless the institution receives a no-cost extension. Funds may be used for pre-award costs, dating back to March 13, 2020, when the National Emergency was declared.
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Eligibility
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.
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Uses of the Student Aid Portion Funds
Institutions must make emergency financial aid grants to in-person students, provided that such emergency financial aid grants are for expenses related to the disruption of campus operations due to coronavirus. Institutions with unexpended (as of December 27, 2020) HEERF funds may use those funds to provide financial aid grants in the same way they are allowed to use the Student Aid Portion of their HEERF II funds, including by providing such grants to students exclusively enrolled in distance education.
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Uses of the Institutional Portion Funds
Institutional Portion funds may be used for those costs that have a clear nexus to significant changes to the delivery of instruction due to the coronavirus. Institutions with unexpended (as of December 27, 2020) HEERF funds may use those funds in the same way they are allowed to use their Institutional Portion HEERF II funds.
Application Deadline: September 30, 2020
Reporting
Institutions must report to the Secretary the following: how grants were distributed to students, how the amount of each grant was calculated, and any instructions or directions that the institution gave to students about the grant. Institutions must also comply with the reporting requirements under Section 15011 of the CARES Act.
HEERF II
The Consolidated Appropriations Act, 2021, signed into law on December 27, 2020, included additional COVID-19 relief through the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA). This new COVID stimulus bill included $23 billion for higher education institutions and students, using the same HEERF model established in the CARES Act.
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Periods of Funds Availability
IHEs have one calendar year from the date of their award to expend funds unless the institution receives a no-cost extension. Funds may be used for pre-award costs, dating back to March 13, 2020, when the National Emergency was declared.
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Allowable Uses
Unlike the CARES Act, the CRRSAA does not require that 50% of an institution’s funds be spent on student grants. It does, however, require that institutions spend at least the same dollar amount on student grants as they were required to spend under the CARES Act. In addition, the allowable uses of funds are more flexible than in the CARES Act, and any unused HEERF funds that an institution did not spend prior to December 27, 2020 may be spent in accordance with the allowable uses of the HEERF II funds. However, institutions are still required to adhere to the 50/50 institutional/student share split for HEERF funds spent after December 27, 2020.
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Student Aid Portion Funds
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
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Institutional Portion Funds
Institutions may use the funds to:
- defray expenses associated with coronavirus, including:
- lost revenue, reimbursement for expenses already incurred
- technology costs associated with a transition to distance education
- faculty and staff trainings
- payroll
- carry out student support activities authorized by the HEA that address needs related to coronavirus
- make additional financial aid grants to students
- defray expenses associated with coronavirus, including:
Application Deadline: April 15, 2021 for new awards
Reporting Requirements
Reporting requirements will be specified in forthcoming announcements. Note that HEERF II awards may be delayed or subject to drawdown restrictions for IHEs that have failed to meet CARES Act reporting requirements.
Audit Requirements: HEERF and HEERF II
According to the United States Department of Education Office of Postsecondary Education:
- Any non-Federal entity, including private nonprofit and public institutions, that expends $750,000 or more during the non-Federal entity’s fiscal year in Federal awards, including student financial assistance under Title IV of the Higher Education Act of 1965, as amended (Title IV) and HEERF, must have a single audit conducted in accordance with 2 CFR part 200 Subpart F-Audit Requirements.
- A non-Federal entity that expends less than $750,000 in Federal awards during the non-Federal entity’s fiscal year is exempt from Federal single audit requirements for that year, except as noted in 2 CFR § 200.503, but records must be available for review or audit by appropriate officials of the Federal agency, pass-through entity, and Government Accountability Office (GAO).
- Regardless of the need to submit an audit, all financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the last HEERF grant’s final expenditure report as required by 2 CFR § 200.334.
Single audit report packages are generally required to be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Under OMB memorandum M-20-26, those institutions that had normal single audit due dates from March 30, 2020 through June 30, 2020 were allowed to delay the completion and submission of their single audit reporting package up to six (6) months beyond the normal due date. Those institutions that have/had normal due dates from July 1, 2020 through June 30, 2021 were given an extension for up to three (3) months beyond the normal due date by OMB memorandum M-20-26 and Appendix VII of the 2020 Compliance Supplement Addendum.