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CARES Act Higher Education Emergency Relief Fund (HEERF)

At least half of the aid provided through this fund must be allocated for emergency grant aid to students. The Department of Education issued an interim final rule (6/17/20) codifying its position that only Title IV eligible students can receive emergency grants from the HEERF. Deeper NACUBO analysis on that rule is available here. NACUBO has also prepared a frequently asked questions for CARES Act HEERF.

Taxability and Reporting Requirements (5/8/20). This NACUBO analysis reviews the taxability of the grants to students, recommendations for 1098-T filing, and addresses disclosures institutions are to share with the Department of Education. 

On June 16, 2020, the Department of Education released supplemental FAQ guidance that provides clarification on how and when institutions can use funds from the CARES Act HEERF.

General Department of Education Resources

ED Coronavirus Resource Page. The Department of Education's general coronavirus resource page, which is updated as ED releases new guidance and resources.

Information for Financial Aid Professionals (IFAP). This site consolidates guidance, resources, and information related to the administration and processing of Title IV federal student aid. 

Title IV and Student Accounts

The Department of Education has issued guidance to help institutions recognize flexibilities intended to help them cope with disruptions caused by the coronavirus pandemic. This section includes guidance that affects bursar functions including Return to Title IV (R2T4), cash management, and credit balance refunds. 

COVID-19 Title IV Frequently Asked Questions (updated 10/5/20

This Title IV-specfic FAQ draws from previous Department of Education guidance to provide succinct responses to a variety of Title IV related questions.

Guidance for interruptions of study related to Coronavirus (issued 5/15/20 updated 6/16/20)

This wide ranging guidance, discussed in more depth here, covers a variety of issues pertinent to the business office. Chief among these changes are new flexibilities to financial statements, compliance audits, distance education requirements, campus-based aid, and R2T4.

A 6/16/20 update to the guidance extends the timeframe for relief from R2T4 requirements provided under the CARES Act "to periods that "include March 13, 2020, or begin between March 13 and the later of December 31 or the last date that the national emergency is in effect." 

Title IV compliance guidance for institutions impacted by coronavirus (issued 3/5/20 – updated 3/20/20)

This ED guidance addresses Title IV compliance concerns for institutions affected by the coronavirus pandemic. The guidance addresses five scenarios that may affect students and institutions and provides flexibilities, especially regarding distance education, for schools that are working to help students complete the term in which they are currently enrolled.

Adjustments to room and board do not require a re-evaluation of a student’s cost of attendance; schools are not required to make changes to the student’s Title IV award on the basis of such adjustment. However, making adjustments for room and board may result in a Title IV credit balance refund; ED’s rules for those must be followed.

Updated Title IV and interrupted study compliance guidance for institutions impacted by coronavirus (issued 4/3/20)

Following the declaration of a national emergency and passage of the CARES Act, this guidance expands on ED’s march publications and discusses expanded flexibilities around distance education and addresses temporary changes to some bursar functions:

  • R2T4. ED will issue guidance once a review of the CARES Act has been completed.
  • Cash Management. “Institutions must comply with cash management regulations unless unable to do so due to COVID-19 disruptions.” If an institution is unable to comply, it should retain documentation of the instance for its records. 
  • Perkins Loans. Institutions holding Perkins Loans may provide an interest rate of zero and a cessation of payments, on a voluntary basis, through September 30. Additionally, schools can grant forbearance for up to three months and may stop collection on defaulted Perkins Loans through September 30.

 FSA notice delaying new Annual Student Loan Acknowledgement requirement (issued 3/27/20)

This announcement delays implementation of the new requirement that borrowers complete an Annual Student Loan Acknowledgement. The acknowledgement, which was slated for implementation prior to disbursement for the 2020-21 Award Year will be implemented for the 2021-22 Award Year.

Federal Work Study

FSA guidance on Federal Work Study community service requirement waiver requests (updated 4/23/20)

This guidance, issued by the Office of Federal Student Aid, that explains the process for securing a waiver of the community service expenditure requirements under the FWS Program for the 2020-21 Award Year.

Student Privacy and Civil Rights

ED’s Student Privacy Policy Office (SPPO) and Office of Civil Rights (OCR) have issued guidance to help schools maintain compliance with FERPA and civil rights regulations as they respond to COVID-19. 

FERPA and COVID-19 FAQs (issued March, 2020). This FAQ and sample consent form was published by SPPO to help school officials manage public health issues related to COVID-19, while protecting student privacy. 
FERPA and virtual learning resources (issued March, 2020). SPPO published this document to highlight resources to help schools maintain student privacy standards as educators and students move to online learning.
ED Office of Civil Rights fact sheet on civil rights and serving students with disabilities during an outbreak (issued 3/16/20). This fact sheet reiterates statutes and regulations that schools must comply with as they respond to COVID-19. 

Contact

Bryan Dickson

Director, Student Financial Services and Educational Programs

202.861.2505


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