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Updated 3/29/2021 

The Department of Education has released a slew of new guidance containing notable changes for all Higher Education Emergency Relief Fund (HEERF) allocations passed by Congress to date, including those contained in the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Coronavirus Response and Relief Supplemental Appropriations (CRRSAA) Act, and the recently passed American Rescue Plan (ARPA) Act.

General Guidance

Much of the additional guidance pertaining to HEERF aid generally echoes and formalizes guidance items ED unofficially shared with higher education associations several weeks ago.


ED reiterated that all HEERF funds can be used to make grants to students beyond just those who are Title-IV eligible, including non-degree-seeking, non-credit, dual enrollment, and continuing education students, as well as students who have left school for any reason during the period of the national COVID-19 emergency that began on March 13, 2020. The new guidance also expands eligibility to students who are qualified aliens, including refugees and persons granted asylum.


Similarly, ED confirmed that schools may 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. Otherwise, affirmative student consent is required to have emergency financial aid grants applied directly to existing account balances. The guidance also makes clear that institutions can directly use their institutional share to pay unpaid student account balances or other student account debts.


Similarly, ED formalized its earlier guidance that institutional shares of HEERF aid can be used to cover employee benefit expenses, as a component of payroll, as long as the costs are newly associated with the coronavirus pandemic.


Notably, ED’s new guidance makes clear that all HEERF allocations, both those already allocated and ARPA funds that will soon be allocated, are eligible to be used within the prescribed guidelines, for all permitted uses, dating back to March 13, 2020. ED has formalized this determination in a new Notice of Interpretation.


Also notable: This latest guidance makes clear that the one-year spending period that has been applied to each individual HEERF allocation is essentially reset with the granting of each additional HEERF allocation. Functionally, this means that schools will have one year from the date on their forthcoming ARPA grant award notifications to spend all HEERF monies they have  received thus far. No-cost extensions of up to one year for these awards also are available under certain circumstances.

Lost Revenue Guidance

ED’s guidance also included a new Frequently Asked Questions document that addresses lost revenue specifically as one of the allowable uses of all HEERF institutional funds. Lost revenue evaluations must be associated with the coronavirus pandemic and can be made back to the March 13, 2020 national emergency declaration. Allowable sources of lost revenue include tuition, room, board, fees, summer camps, bookstore, parking, and various other auxiliary services, to name a few. Lost revenue does not have to be associated with, or netted against, expenses and is considered an allowable use (type of expenditure) for quarterly and annual reporting to ED and on the Schedule of Expenditures of Federal Awards (SEFA).


NACUBO’s policy team discussed ED’s guidance at a Town Hall on March 24. The on-demand recording and accompanying slide presentation are now available.


Sue Menditto

Senior Director, Accounting Policy



Liz Clark

Vice President, Policy and Research


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