This AskRegs Knowledgebase Q&A was updated on May 13, 2021 to include guidance in the May 11, 2021 Higher Education Emergency Relief Fund (HEERF) III Frequently Asked Questions and the May 14, 2021 Final Rule as it relates to HEERF I grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), HEERF II grants under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021), and HEERF III grants under the American Rescue Plan Act of 2021 (ARP).
Yes. According to the U.S. Department of Education’s (ED’s) Final Rule, any individual who is or was enrolled at an eligible institution on or after March 13, 2020 is now eligible for HEERF I, HEERF II, and HEERF III student grants. According to the HEERF III FAQs and the Final Rule, this is true regardless of whether the student completed a FAFSA or is eligible for Title IV federal student aid. And, it applies retroactively to all students and for all three HEERF programs.
This includes those who are not meeting Title IV satisfactory academic progress (SAP) standards, as long as the school prioritizes the receipt of leftover HEERF I funds, HEERF II funds, and HEERF III funds based on exceptional need and awards the funds to cover any component of the student's cost of attendance (COA) or emergency costs that arise due to Coronavirus (i.e., the allowable uses under the CRRSAA and ARP).
Reference the Final Rule and Q&As #7 and #8 in the HEERF III Frequently Asked Questions, as well as Q&A 16 of the revised HEERF II Frequently Asked Questions.
This guidance and Final Rule represents a break from the Trump administration's previous interpretation, which held that students needed to be Title IV-eligible students in Title IV-eligible programs to qualify for HEERF grants. See AskRegs Q&A, Must a Student Be Title IV-Eligible To Receive a HEERF I, HEERF II, or HEERF III Grant?, for historical background information.
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