Is a Student Who Is Simultaneously Enrolled In High School and College Eligible For HEERF I, HEERF II, Or HEERF III Funds?

KA-34780 Helpfulness Rating 885 page views

This AskRegs Knowledgebase Q&A was updated on March 19, 2021 to include guidance in the revised Higher Education Emergency Relief Fund (HEERF) II Frequently Asked Questions, as it relates to spending leftover HEERF I student grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), HEERF II funds under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021), and HEERF III funds under the American Rescue Plan Act of 2021 (ARP).

Unspent HEERF I Funds as of December 27, 2020, HEERF II Funds, and HEERF III Funds
Yes. Schools can award leftover (unspent) HEERF I funds, HEERF II funds, and HEERF III funds to students who are simultaneously enrolled in high school and college.

HEERF I Funds Spent Prior to Passage of CRRSAA on December 27, 2020
No. Effective with publication of the June 17, 2020 Interim Final Rule, only students who were or could be eligible to participate in the Title IV programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (HEA) [20 USC 1091(a)], could receive HEERF I emergency grants to students. To be a Title IV-eligible student under Section 484, among several other criteria, the student must not be enrolled in elementary or secondary school. Therefore, students who are simultaneously enrolled in high school and college were not eligible for HEERF I grants.

The Title IV-eligibility requirement was not new on June 17, 2020. It first appeared in the U.S. Department of Education's (ED's) April 21, 2020 Frequently Asked Questions about the Emergency Financial Aid Grants to Students under Section 18004 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Be sure to review AskRegs Q&A, Must a Student Be Title IV-Eligible To Receive a Higher Education Emergency Relief Fund Grant?, for historical information about enforcement of this provision.


AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.