Guidance Updated for Higher Education Emergency Relief Fund

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On June 16, 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). 

Updated Information

Deadline to Spend: Institutions must spend HEERF funds by September 30, 2022. ED highlighted the urgency to distribute the emergency financial aid grants to students enrolled during the spring term immediately. If funds remain after distribution to the spring-enrolled students, institutions may provide emergency financial aid to students during the summer or fall terms using the same distribution formula. 

Summer & Fall Terms: ED allows the institution to disburse emergency financial aid grants to “eligible students enrolled during subsequent terms … even if they were not enrolled during the spring 2020 term.” This also applies to the institutional relief portion of §18004(a)(1).

Student Scholarships: ED clarified that funds distributed under §18004(a)(1) aren’t eligible for scholarships. However, funds distributed under §18004(a)(2) and §18004(a)(3) are eligible for student scholarships. These funds are specifically “for grants to students for any component of the student’s cost of attendance.” 

Dining & Residence Hall Staff: Updated guidance allows the institutional relief funds to cover the salaries and benefits of dining hall and residence hall staff who would have been paid through student housing fees. ED considers COVID-19 disruption to have a “reasoned basis with respect to the salaries and benefits for employees that work in dining halls and dorms.” 

Lost Revenue: Institutions receiving §18004(a)(2) and §18004(a)(3) CARES Act funds are eligible to reimburse themselves for lost revenue related to COVID-19. ED requires documentation demonstrating year-over-year decreases in revenue that are the result of a decline in enrollment, fees, housing and meal plans, parking, facility revenues, or a decline in summer programs and other activities disrupted by COVID-19.

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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