Do Higher Education Emergency Relief Fund Grants To Students Have To Cover Expenses In the Cost Of Attendance?

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This AskRegs Knowledgebase Q&A was updated on January 20, 2021 to reflect requirements under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021). Unless specifically indicated below, the CRRSAA rules apply to both leftover Higher Education Emergency Relief Fund (HEERF) grants under the CARES Act (HEERF I funds) after December 27, 2020 and to new funds under the CRRSAA (HEERF II funds).

No. According to guidance NASFAA has received from the U.S. Department of Education (ED), HEERF I grants to students do not have to cover expenses in the student's cost of attendance (COA), but schools are required to pay the grant funds directly to students to cover expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student’s COA such as food, housing, course materials, technology, health care, and child care).

However, HEERF I funds under the CARES Act that remained unexpended as of December 27, 2020 and HEERF II funds authorized under CRRSAA may be used to make grants to students for any component of the student’s COA or for emergency costs that are related to the Coronavirus. That is, the expense does not have to be directly related to a disruption of campus operations due to Coronavirus and it does not have to cover an expense in the COA.

See the following from the Higher Education Emergency Relief Fund (HEERF) II Public and Private Nonprofit Institution (a)(1) Programs (CFDAs 84.425E and 84.425F) Frequently Asked Questions (updated March 19, 2021):

“9. Question: How may students use their financial aid grants?

Answer: Financial aid grants for students may be used for any component of the student’s cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care (including mental health care) or child care.”

Reference the Recipient’s Funding Certification and Agreement for Emergency Financial Aid Grants to Students, the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Certification and Agreement (CFDA 84.425Q) ((a)(4) Program) Proprietary Institution Grant Funds for Students, the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Certification and Agreement (CFDA 84.425E) ((a)(1) Student Aid Portion) Public and Nonprofit Institution Grant Funds for Students (updated March 19, 2021), and the Higher Education Emergency Relief Fund (HEERF) II Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program) Frequently Asked Questions (updated March 19, 2021).

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.