This AskRegs Knowledgebase Q&A was updated on June 4, 2021 to note that Higher Education Emergency Relief Fund (HEERF) III Grant Award Notifications went out to schools with incorrect performance period (spend-by) dates and that the U.S. Department of Education (ED) is in the process of manually sending out corrections.
The following guidance 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).
Deadline to Distribute HEERF I, HEERF II, and HEERF III Funds If the School Received All Three Funds
According to Q&A #39 in the May 11, 2021 Higher Education Emergency Relief Fund (HEERF) III Frequently Asked Questions, schools have one year from the date their most recent grant obligation was processed by ED to spend all of their HEERF funds, including funds from prior rounds of funding from HEERF I and HEERF II. So, schools receiving HEERF III funding in May 2021 will have until May 2022 to spend their funding from HEERF I, II, and III. The exact date will appear in Box 6 of school's most recent Grant Award Notification (GAN). ED also reminds institutions of the availability of no-cost extensions (NCEs) and expresses its intent to be “very flexible” in granting initial NCEs.
Note: ED has acknowledged that HEERF III GANs went out with incorrect dates in Box 6. ED is in the process of manually updating these dates, and schools will receive updated GANs with the correct dates. In the meantime, the above guidance still applies.
Remember, the school cannot simply draw down its entire HEERF student and institutional allocations at once. See AskRegs Q&A, Should HEERF Funds Be Drawn Down From G5 As They Are Awarded Or In a Lump Sum?, for more information.
Deadline to Distribute HEERF II Funds If the School Receives No HEERF III Funds
According to Q&A #24 in the revised HEERF II Frequently Asked Questions, if the school received HEERF II funds but no HEERF III funds (or declined HEERF III funds), the school has one year from the date the school's supplemental HEERF II grant obligation was processed to distribute the HEERF II funds. For example, if a school's supplemental HEERF II funds were processed on January 20, 2021, the funds must be spent on or before January 19, 2022. Again, the exact date will appear in Box 6 of the school's most recent GAN for supplemental HEERF II funds. If funds are not spent within the year allotted, a no-cost extension may be requested if applicable.
Historical Note: Early in the HEERF II process, ED sent out some GANs with incorrect dates. ED subsequently sent out corrections to the school's HEERF Project Director. Because the dates of performance were incorrect on the supplemental grants issued in January 2021, an automated email was sent out from G5 requesting clarification from schools on remaining funds so close to grant end date. The "Dear Project Director" email asked three questions about the school's HEERF obligations through the end of the current budget period. According to ED, schools should disregard this email. ED reiterated that it would be correcting the GAN dates for the use of supplemental HEERF II funds.
Deadline to Distribute HEERF I Funds If the School Received No HEERF II or HEERF III Funds
According to the HEERF Supplemental Frequently Asked Questions, which was updated by ED on August 6, 2020 and again on September 8, 2020, the deadline for spending HEERF I student and institutional grants was as follows:
"What is the deadline (project period or period of performance) for institutions to spend Higher Education Emergency Relief Fund (HEERF) funds received under the CARES Act? [see footnote 1]
All institutions were given 1 calendar year (365 days) from the date of award in their HEERF Grant Award Notification (GAN) to complete the performance of their HEERF grant. [see footnote 2] Therefore, for example, if a grantee received a GAN on April 7, 2020, the one calendar year period of performance for their HEERF grant would be through April 6, 2021.
Please note that after the end of the year-long period of performance, grantees have an additional 90 calendar days to liquidate their obligations made during their year-long period of performance as part of the grant closeout procedures (2 CFR § 200.343(b)).
The Department understands that some grantees, even given the emergency nature of the HEERF grant, may be unable to obligate funds by this time. Consequently, no-cost extensions (NCEs) of up to 12 months are available as provided for in 2 CFR § 200.308(d)(2). NCEs may not be exercised merely for the purpose of using unobligated balances. Given the emergency nature of HEERF grants, the Department does not intend an NCE to extend longer than 12 months. HEERF grantees are encouraged to discuss any need for an NCE with their respective program officer well in advance of the end of their grant period of performance.
For general information about grant management, grantee responsibilities, and grant closeout, please consult our guide, Grantmaking at ED, available here.
1 A previous version of the FAQ inaccurately stated that schools had until September 30, 2022 to use HEERF grant funds. This revised version of the answer conforms with the project period listed in the GANs and supersedes the previously provided FAQ.
2 See Box 6 in your HEERF GAN (“Federal Funding Period”). All HEERF grant programs received a 1 calendar year period of performance from their GAN."
Previous Guidance--Two Previous Deadlines: The previous version of the Supplemental FAQs published on June 30, 2020 indicated a deadline of September 30, 2022. Originally, the HEERF Recipient’s Funding Certification and Agreement for Emergency Financial Aid Grants to Students and the Recipient’s Funding Certification and Agreement for the Institutional Portion both state that schools must "promptly and to the greatest extent practicable" distribute HEERF emergency grants by one year from the date they signed the certification. Both previous deadlines are superseded by the new guidance above.
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