Can a Student Who Has Graduated Or Withdrawn Retroactively Receive HEERF I, HEERF II, and HEERF III Student Grant Funds?

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This guidance is not award-year-specific and applies across award years.

This AskRegs Knowledgebase Q&A was updated on May 12, 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. 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 This includes students who have graduated or withdrawn and for whom the school wants to make a retroactive HEERF award under its awarding policies.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.

Update Notes:

  • This Q&A was previously updated on March 1, 2021 to include guidance NASFAA received from ED about spending leftover HEERF I student grants under the CARES Act and HEERF II student grants.
  • Prior to this March 1, 2021 Q&A update, NASFAA had confirmed that students who were enrolled at the time of the COVID-19 disruption on campus, but who had since graduated (e.g., spring 2020), could receive HEERF grants. We remained uncertain about students who had withdrawn.
  • This AskRegs Q&A was previously updated to reflect the June 17, 2020 Interim Final Rule. See 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.