More Guidance Provided on CARES Act Funding

The Department of Education issued a new set of ten Frequently Asked Questions related to the Higher Education Emergency Relief Fund (HEERF) in the CARES Act.  

Although much of this information was understood previously, the ten questions cover the following:

• Institutions have until September 30, 2022 to spend HEERF funds. This seems to be the final deadline for use of funds.  The Certification and Agreement allows institutions to use funds within a year of signing the agreement. At the same time, the department maintains a note on the CARES website that they will “soon” issue a deadline for application for the institutional funds. Emergency grants are not limited to students who were enrolled during the time the national emergency was declared. The department recognizes that student expenses related to the disruption of campus activities and the delivery of education may carry over into the summer and fall.
• Colleges and universities can use the institutional portion of relief funds for emergency student grants for summer and fall terms.
• Institutions can use funds under the Minority-Serving Institutions (MSI) portion and the FIPSE portion of HEERF funds for grants for students during the summer and fall terms.
• Funds from the both the student and institutional tranches of HEERF CANNOT be used to provide student scholarships.  Grants to students must be emergency grants related to the disruption of instruction.  
• Funds from the MSI and FIPSE portions of HEERF CAN be used to provide students emergency grants or scholarships. Student scholarships are allowed because these funds can be used for “grants to students for any component of the student’s cost of attendance.”
• Institutions making scholarships using the MSI or FIPSE portions of HEERF funds may also use such funds for advertising costs associated with making information available about those scholarships.  
• Institutions may use HEERF funds (except for the 50% student grant portion) to pay salaries and benefits for dining hall and dorm employees as a “cost associated with the significant delivery of instruction due to the coronavirus.” 
• Institutions can use HEERF funds (except for the 50% student grant portion) to purchase additional supplies and equipment, including more laptops for example, to accommodate online learning as a result of the disruption of instruction. 
• Regarding revenue losses, institutional recipients of MSI and FIPSE funds must be able to provide documented proof of such losses upon the request of the department. Documentation will need to demonstrate the decreases in revenue based on a decline in enrollment, student fees, facility revenue, summer program revenue, etc. because of the coronavirus. 

In related news, the department is continuing its systemic review of guidance previously issued during the coronavirus pandemic to provide institutions with flexibility in handling various regulatory situations in light of the evolving crisis.  This week the return of Title IV funds for circumstances related to the pandemic, as well as addressing some issues on overlapping terms was extended until December 31, 2020.