This guidance is not award-year-specific and applies across award years.
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 student grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), HEERF II student grants under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021), and HEERF III student grants under the American Rescue Plan Act of 2021 (ARP). In other words, this applies retroactively to all students and for all three HEERF programs.
This means that schools can retroactively award HEERF I, HEERF II, and HEERF III grants to students who have left school for any reason during the period of the COVID-19 national emergency beginning on March 13, 2020. This includes students who have graduated or withdrawn and for whom the school wants to make a retroactive HEERF award under its awarding policies.
Reference the Final Rule and Q&A #7 and #8 in the above-referenced HEERF III FAQ, as well as Q&A #22 in the revised HEERF II Frequently Asked Questions.
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