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CARES Act: Coronavirus Aid, Relief and Economic Security Act
HEERF: Higher Education Emergency Relief Fund, created by the CARES Act
Institutional Share: The portion of HEERF funds designated for institutional use that does not include other CARES Act relief offered specifically to HBCUS, MSIs, Tribal Colleges and Universities, FIPSE funds, or other CARES Act higher education relief
‘Emergency Grants to Students’ Funds: The portion of HEERF funds designated for providing emergency grants to students
ED: the Department of Education

HEERF ‘Emergency Grants to Students’ Funds

If students need to take online courses due to COVID-19, are they eligible to receive funds? What if they’re in an online program?

The legislation is intended to assist students who were directly affected by COVID-19. Students who were already taking exclusively online courses for the semester or are in an online program are not eligible. Students who had to transition to online courses because of the impact of COVID-19 are eligible to receive CARES Act HEERF aid if they otherwise meet the eligibility requirements specified by the Department of Education.

Under what circumstances can our institution be reimbursed for expenses utilizing the ‘emergency grant aid to students’ HEERF funds? What if we distributed computers to all students? If we advanced emergency funds to students?

Your institution may use these funds to reimburse itself for genuine, cash emergency grants provided directly to students after passage of the CARES Act who are/were eligible to receive HEERF funds as a result of hardship due to COVID-19. Physical supplies (like computers) are not eligible for reimbursement under the “emergency grant aid to students” section of HEERF, but are permissible for reimbursement out of the institutional share of HEERF funds.

Which office should handle disbursement of HEERF funds to students? Should grants be made through the financial aid office or another office? Are students required to apply for funding? Can FAFSA recipients be prioritized?

Your institution has wide latitude when it comes to the method of aid disbursement to eligible students. You can use your own formulas to determine how funds are divided among eligible recipients. Similarly, you can disburse the grants through existing or new disbursement systems, provided that your institution ensures that the aid is not in any way reduced or diminished by existing charges a student may have on their student account. Likewise, it is up to your institution’s discretion to require an application or not.

Can funds be used to offset charges on a student account? Or to reimburse our institution for travel expenses covered for students returning home?

No, funds cannot be used to offset charges on a student account, even if the student requests that it be done. Your institution must provide the aid, in its entirety, directly to students.

Can we hold funds for a future semester?

The CARES Act, Department of Education guidance, and the required certification and agreement forms submitted to ED by schools, indicates that funds should be distributed as promptly as possible.

Can students who graduated in May/June receive funds if their last semester was interrupted? What if a student withdrew before the school moved to online courses?

The legislation is intended to assist enrolled students, so if funds were disbursed to graduating students before they cease to be students, that is permissible. Once a student has graduated, or withdrawn, they would not be eligible.

Are international students eligible to receive funds from the CARES Act?

Potentially in some limited cases, but generally, no. Students must currently be eligible to receive Title IV aid in order to receive HEERF funds. Most international students do not meet these criteria. However, ED has indicated that it is reviewing its guidance regarding student eligibility requirements.

Are the Higher Ed Emergency Relief Fund (HEERF) grants to students reportable on the 1098-T?

In an FAQ posted on its website on December 14, 2020, the IRS clarified it "will not require that these grants be reported pursuant to section 6050S of the Internal Revenue Code on Form 1098-T.

Federal Work Study (FWS)

Can CARES Act funds be used to pay work-study students if positions were suspended due to COVID-19?

Schools are still permitted to use Federal Work-Study (FWS) funds to pay work-study students whose work may have been interrupted as a result of COVID-19. There shouldn’t be a need to use HEERF funds for this – the existing FWS funds for this purpose can still be used.

How long can Federal Work-Study wages continue to be paid to students who have moved off campus?

If those students’ jobs were interrupted due to COVID-19, ED has indicated that institutions may continue to pay FWS wages to students for the remainder of the current academic year (as long as those students began employment before the national emergency began).

Can remaining Federal Supplemental Educational Opportunity Grant (FSEOG) funds for Fiscal Year 2020 be transferred to federal work-study?

No, the reverse is true. Institutions can transfer up to 100% of FWS funds into FSEOG during a period of a qualifying emergency. Your institution can use any portion of your FSEOG allocation to award emergency financial aid grants to assist undergraduate or graduate students for unexpected expenses and unmet financial need as the result of a qualifying emergency. 


HEERF Institutional Share Funds

If you use the institutional portion of the funding to give additional money to students, do they have to be students who qualified to receive the ‘emergency grants to students’ portion of HEERF funds?

Yes, currently students receiving additional aid from an institutional share of HEERF funds must meet the same eligibility requirements that students receiving aid from the “emergency grants to students” portion of HEERF funds must meet. However, ED has indicated that it is reviewing its guidance regarding student eligibility requirements.

Can you provide guidance on reporting requirements for HEERF funds?

ED has provided initial guidance on some reporting requirements here. We are still awaiting guidance on all reporting requirements.

How soon can we apply for HEERF grant funds?

All HEERF funds under the CARES Act are currently available for disbursement following an eligible institution’s submission of its certification and agreement forms. All information pertaining to certification and agreement forms are available here.

Additional NACUBO Resources

COVID-19 Resources

COVID-19 Department of Education Resources

COVID-19 Employer and Tax Resources

Other COVID-19 Federal Guidance

COVID-19 Webcast Series

COVID-19 Telephone Town Halls

COVID-19 Campus Checklists

COVID-19 Accounting Tutorials

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