This AskRegs Knowledgebase Q&A was updated on May 14, 2021 to include guidance in the May 11, 2021 Higher Education Emergency Relief Fund (HEERF) III Frequently Asked Questions, as it relates to leftover 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).
No. 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). See Q&A #18 in the Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document.
However, HEERF I funds that remained unexpended as of December 27, 2020, HEERF II funds, and HEERF III funds 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 HEERF III Frequently Asked Questions:
“13. Question: How may students use their financial aid grants?
Answer: Emergency financial aid grants may be used by students for any component of their 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. Students determine how they may use their emergency financial aid grant within the allowable uses.”
Update Note: This AskRegs Q&A was updated on January 20, 2021 to reflect requirements that CRRSAA rules apply to both leftover HEERF I funds after December 27, 2020 and to new HEERF II funds.
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