Guidance Updated for Higher Education Emergency Relief Fund

Thoughtware Alert Published: Apr 22, 2020
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On April 21, 2020, the U.S. Department of Education (ED) released additional guidance for higher education institutions related to the Higher Education Emergency Relief Fund (HEERF), which covers distribution of emergency grants to students as defined in Section 18004 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The new guidance updated and supplemented information ED released on April 9, announcing the availability of the first half of the funding authorized by the HEERF that is designated exclusively for emergency grants to students.

Updated Information

Outstanding Balance Due: The CARES Act requires institutions to provide the emergency financial aid grants to students. ED clarified that the student may use his or her emergency financial aid grant for “expenses related to the disruption of campus operations due to coronavirus.” Therefore, emergency grant funds must remain unencumbered. 

Distribution Method: ED allows the institution to disburse aid through checks, debit cards, direct deposit and payment apps that adhere to ED’s requirements for paying credit balances to students. It may involve other disbursement methods, but cannot be encumbered by a past-due balance. ED wrote that “the student must remain unencumbered by the institution; debts, charges, fees, or other amounts owed to the institution may not be deducted from the emergency financial aid grant.”

Exclusively Online: Students enrolled exclusively in online programs on March 13, 2020, are excluded from the distribution. ED provided this clarification to ensure funds were only applied to students who experienced “expenses related to the disruption of campus operations due to coronavirus.” ED reasons that students who were enrolled exclusively in online programs would not have expenses related to the disruption of campus operations due to coronavirus.

Note: During the April 21 call with institutions, ED encouraged all institutions to complete their HEERF application process. As of today, about 50 percent of institutions have completed their request for funding. 

The application process requires each institution to create an account on the website. After creating the account, the institution must first submit the SF-424 form and then submit the Recipient’s Funding Certification and Agreement form.

As with most topics related to COVID-19, changes are being made rapidly. Please note that this information is current as of the date of publication. For more information, reach out to your BKD Trusted Advisor or use the Contact Us form below.

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