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In response to requests from NACUBO and others for more guidance on COVID-19 relief allocations for colleges and universities, the Department of Education shared some additional information in an email to higher education associations.

On February 10, NACUBO joined over 30 other higher education associations in a letter to ED requesting additional guidance on a number of questions related to college and university COVID-19 relief allocations provided by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, known as HEERF or HEERF I, and provided by the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act, known as HEERF II.

While several significant questions remain unanswered, ED’s recent email response provides some guidance on a few questions. ED’s response did not address several of the top concerns from the higher education community, including the eligibility of DACA and international students to receive grants from these funds, using HEERF II funds to cover expenses incurred prior to December 27, 2020, and any further direction pertaining to revenue recognition or revenue loss calculations for HEERF II. When ED’s email did mention the December 27, 2020, date, they noted that the reference is based on current guidance and is not meant to signal anything with regards to the larger question about HEERF II fund usage for expenses incurred before the date, which they are still considering.

Guidance Related to HEERF Student Funds

With regard to the portions of HEERF I and HEERF II allocations earmarked to be used to make emergency grants to students, ED emailed that:

  • Colleges can use HEERF II and unspent HEERF I funds to support certain students who are not Title IV eligible. That includes non-degree-seeking, non-credit, dual enrollment, and continuing education students. That also includes students who have left school for any reason during the period of the national COVID-19 emergency that began on March 13, 2020.
  • In cases where students have provided affirmative consent to have their emergency grants directly applied to student account charges, the grants may apply to charges that were posted to a student’s account before December 27, 2020, as long as the grant itself was made available to the student after December 27, 2020.
  • It is permissible to provide all emergency grants directly to students using the institution’s normal process for providing a credit balance refund to students without obtaining a student’s consent, as long as these funds remain unencumbered by the institution. As mentioned above, if students elect to have their emergency financial aid grants applied directly to existing account balances, their affirmative consent is required and cannot be obtained via any coercion from the institution, as is made clear in ED’s HEERF II FAQ document.

Guidance Related to HEERF Institutional Funds

With regard to the portions of HEERF I and HEERF II allocations earmarked for institutional use, ED expressed that:

  • Per the direction in ED’s HEERF II FAQ document that certain payroll expenses are eligible uses for the institutional portion of funds, colleges also can use HEERF II funds and unspent HEERF I funds to pay costs for employee benefits incurred on or after December 27, 2020. However, ED’s current guidance is that colleges cannot currently use HEERF II funds to cover costs prior to December 27 and cannot use remaining HEERF I funds, under the expanded allowable use of those funds provided in CRRSAA, for expenses incurred prior to that date.

Institutions receiving additional allocations made from HEERF I and HEERF II grant programs, including those earmarked for Minority Serving Institutions, Tribally Controlled Colleges and Universities (TCCU), and others should also heed the additional ED guidance provided for those funds. 


Megan Schneider

Senior Director, Government Affairs


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