Can Online Students Receive Higher Education Emergency Relief Funds?

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This AskRegs Knowledgebase Q&A was updated on January 22, 2021 to reflect requirements under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) under Section 314 of the Consolidated Appropriations Act, 2021. Unless specifically indicated below, the CRRSAA rules apply to both leftover Higher Education Emergency Relief Fund (HEERF) grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (HEERF I funds) after December 27, 2020 and to new funds under the CRRSAA (HEERF II funds).

HEERF II and Leftover HEERF I Funds Spent on or After December 27, 2020
Yes. Unlike the CARES Act, the CRRSAA authorizes grants to students exclusively enrolled in distance education. This expanded eligibility applies to both new funds under the CRRSAA (HEERF II funds) and leftover funds under the CARES Act (HEERF I funds) awarded after December 27, 2020.

In addition, the CRRSAA allocation formula factors in an institution's distance education students, and allows exclusively online institutions that were ineligible for funding under the CARES Act to apply for HEERF II grant funds.

HEERF I Funds Spent Before December 27, 2020
Whether online students could receive HEERF I funds prior to December 27, 2020 depended on whether the student was enrolled exclusively in an online program on March 13, 2020 at an institution that provided both online and ground-based (residential or face-to-face) education.

Current and incoming students were eligible for HEERF I student grants under the CARES Act if they were not enrolled exclusively in an online program on March 13, 2020. This eligibility also extended to future terms/payment periods, regardless of whether the student later enrolled exclusively in an online program.

Students were not eligible for HEERF I grants if they were enrolled exclusively in an online program on March 13, 2020.

Not all programs are exclusively online or exclusively ground-based (i.e., hybrid programs). What mattered in those instances was how the student enrolled in the program. For example, the school offered a program in which students were allowed to take courses entirely online, but some or all of those same courses could also be taken in-seat residentially. Students who were taking a combination of online and ground-based classes in the program on March 13, 2020 were eligible for HEERF I grants.

Let's now say that students were also allowed to enroll in the exclusively online version of that same program with the intent to take every course online, such as students who were 1,000 miles away from campus and could not complete the program any other way than exclusively online. These students were not eligible for HEERF I grants.

As another example, let’s say a program was intentionally designed as a hybrid program, and students were exclusively ground-based one term and then exclusively online the next. On March 13, 2020, they happened to be in the online portion. However, since the program itself was not exclusively online, those students were eligible for HEERF I grants provided they met all other eligibility criteria.

If the students were not enrolled exclusively in an online program before March 13, 2020, they were not considered to be enrolled exclusively in an online program just because the school later moved all residential classes to online instruction due to COVID-19, as allowed under the March 5, 2020 Electronic Announcement. Those students could still receive a HEERF I grant.

An online program is one that meets the definition of distance education under 34 CFR 600.2.

See also AskRegs Q&A, Can We Hold HEERF Student Grants For an Upcoming Term Or Award Year, Or For Incoming Freshmen?

Note: This AskRegs Q&A was previously updated to clarify the eligibility of online students for HEERF I grants in future terms, and to clarify that ED's guidance in the Frequently Asked Questions about the Emergency Financial Aid Grants to Students regarding an online student's eligibility for HEERF I grants remained in place, even though ED's May 21, 2020 statement indicated that its guidance lacked "the force and effect of law" and ED "will not initiate any enforcement action based solely on" that guidanceED's May 21st statement did not appear to extend eligibility to students if they were enrolled exclusively in an online program on March 13, 2020.

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