Student Portion of Higher Education Emergency Relief fund (HEERF)
The Coronavirus Aid, Relief, and Economic Security (CARES) Act includes a Higher Education Emergency Relief Fund (HEERF) that provides more than $14 billion in emergency funding to higher education. Of those funds, more than $6 billion must go directly to students in the form of emergency financial aid grants (HEERF-student share) for expenses related to the disruption of campus operations due to the COVID-19 crisis. On April 9, 2020, the ED published a list of individual institutional allocations, a certification form that must be signed and returned in order to access the funds, and a letter from Secretary Betsy DeVos outlining ED's implementation of the CARES Act program. On April 21, 2020, ED released additional clarification on student eligibility and allowable uses of HEERF-student share funds.
Not Title IV Aid, but Title IV Eligibility Required: While HEERF-student share dollars are not Title IV aid, ED's final rule published June 17 states that students must meet Title IV eligibility requirements in order to receive HEERF emergency grants.
Expense v. Need: HEERF-student share dollars are to aid students for expenses related to the disruption of campus operations due to the coronavirus; this is different than a change in a student's financial need due to COVID-19, which could be a result of a loss of income rather than new expenses.
Direct to Students: Institutions must pay HEERF-student share emergency grants directly to students and may not apply the grants toward outstanding institutional charges.
IGlobal University completed to provide all the HEERF fund as of 4/30/2021
Frequently Asked Questions and Answers
Q: Which students are eligible to receive HEERF-student emergency funds?
A: The April 21 guidance, as well as the June 17 final rule, states that students must meet Title IV eligibility requirements in order to receive HEERF emergency funds. After confirming the Title IV eligibility requirements, the institution retains discretion over which students will receive HEERF-student share funds. According to the certification agreement, institutions are required to comply with "all applicable laws including non-discrimination laws" when determining who will receive the emergency grants. Beyond that stipulation, there are no further prohibitions of specific students in the certification agreement. Therefore, any Title IV-eligible student may receive HEERF-student share funds, unless prohibited by another law, which would include DACA students, undocumented students and international students.
There have been many questions about awarding HEERF-student share funds to international students, online students, and undocumented students.
International and Undocumented Students: ED's April 21 guidance states that students must meet Title IV eligibility requirements in order to receive HEERF-student share funds. Therefore, international and undocumented students are not eligible to receive emergency grants.
Online Students: Students who were enrolled exclusively in online programs on March 13 (the date of President Trump's national emergency proclamation) are not eligible for HEERF-student share funds, per ED's April 21 guidance.
Q: Do we have to have a student's Free Application for Federal Student Aid (FAFSA) on file in order to disburse HEERF-student funds to students?
A: While ED's guidance does not require a FAFSA, having one on file would be the only practicable way for an institution to determine that a student is eligible to participate in the Title IV programs and meet all of applicable student eligibility requirements. Without having a FAFSA on file, schools would need to verify that a student meets the Title IV eligibility criteria. In its HEERF FAQ document, ED states the following: "The criteria to participate in programs under Section 484 of the [Higher Education Act (HEA)] include but are not limited to the following: U.S. citizenship or eligible noncitizen; a valid Social Security number; registration with Selective Service (if the student is male); and a high school diploma, GED, or completion of high school in an approved homeschool setting." Beyond this guidance, a school will need to make its own decisions on how to document if a student is or could be Title IV-eligible when awarding HEERF grants to students.
Institutions that choose to take advantage of ED's non-enforcement policy applicable for disbursements prior to June 17 and not limit eligibility only to students who meet the Section 484 student eligibility requirements must still consider, with the assistance of legal counsel, the applicability of the Personal Responsibility and Work Opportunity Reconciliation Act, and whether and how they will document student citizenship status.
Q: What eligibility criteria are in section 484 of the Higher Education Act (HEA)?
A: Section 484 of the HEA states that Title IV eligible students must:
Be enrolled or accepted for enrollment in a degree or certificate program.
Not be enrolled in elementary or secondary school.
For currently enrolled students, be making satisfactory academic progress.
Not owe an overpayment on Title IV grants or loans.
Not be in default on a Title IV loan.
File "as part of the original financial aid application process" a certification that includes
A statement of educational purpose.
Be a U.S. citizen or national, permanent resident, or other eligible noncitizen.
Have returned fraudulently obtained Title IV funds if convicted of or pled guilty or no contest to charges.
Not have fraudulently received Title IV loans in excess of annual or aggregate limits.
Have repaid Title IV loan amounts in excess of annual or aggregate limits if obtained inadvertently.
Have Selective Service registration verified.
Have Social Security Number verified.
Not have a federal or state conviction for drug possession or sale, with certain time limitations.
Q: Is verification a student eligibility requirement under section 484 of the HEA?
A: The verification requirements are not included in HEA Section 484, however, the V4 and V5 selection groups include re-submission of the statement of educational purpose, which is in Section 484.
Q: Given all the uncertainty over the student eligibility requirements, how should we proceed?
A: Lacking further guidance, the most conservative approach for institutions seeking to distribute HEERF dollars within the near future would be to limit eligibility to students who have already met all Title IV eligibility requirements by completing a FAFSA and resolving all C codes and completing verification, if selected by ED.
Institutions that choose to take advantage of ED's non-enforcement policy applicable for disbursements prior to June 17 and not limit eligibility only to students who meet the Section 484 student eligibility requirements must still consider, with the assistance of legal counsel, the applicability of the Personal Responsibility and Work Opportunity Reconciliation Act.
Q: Can a school reimburse itself for any funds it has spent on students related to COVID-19, including refunds for room and board?
A: Institutions may not use the student portion of the HEERF funds to reimburse themselves for tuition or room and board refunds. Schools may use the institutional portion of the HEERF funds to reimburse themselves for refunds made to students on or after March 13, 2020, issued for room and board, tuition, and other fees as a result of significant changes to the delivery of instruction, due to the novel coronavirus.
Q: Can schools apply student emergency grants to a student's account in order to pay off outstanding balances?
A: ED has made clear that the emergency cash grants to students cannot be applied toward outstanding balances, and must be disbursed directly to students, using means such as check, electronic funds transfer, payment app, or pre-loaded debit card. Additionally, HEERF-student funds may pass through an institution's student information system/student accounts system as long as the funds are set up as to not pay the student's account balance.
Q: Can institutions use HEERF-student funds to reimburse themselves for emergency cash grants that a school has already disbursed to students?
A: Institutions may use HEERF-student funds to reimburse themselves if they provided an emergency grant to a student that meets the same eligibility criteria of HEERF grant funds on or after March 27 — the day the CARES Act became law. In such instances, ED would consider the institution to have made an advance payment of HEERF dollars to students in anticipation of receipt of the federal deposit.
Q: Can schools use HEERF-student funds to cover the cost of resources the school provided directly to students, such as giving a student a computer or internet hotspot or filling an on-campus food pantry?
A: No, the HEERF funds must be distributed to students in the form of cash grants. The funds must go from the school