Must a Student Be Enrolled In a Title IV-Eligible Program To Receive a HEERF I or HEERF II Grant?

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This AskRegs Knowledgebase Q&A was updated on March 1, 2021 to include guidance NASFAA has received from the U.S. Department of Education (ED) about spending leftover Higher Education Emergency Relief Fund (HEERF I) student grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) as well as HEERF II funds under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021).

HEERF I Funds Remaining Unspent as of December 27, 2020 and HEERF II Funds
No. Schools can award leftover (unspent) HEERF I funds and HEERF II funds to students who are not enrolled in Title IV-eligible programs. This includes nondegree, noncredit, and continuing education students, as well as students who are simultaneously enrolled in high school and college.

This still does not include undocumented, Deferred Action for Childhood Arrivals (DACA), and international students. Per ED, "The Department is exploring additional opportunities – including with other agencies - for colleges to support other vulnerable students (e.g., undocumented, DACA, and international students) during the national coronavirus pandemic emergency." See AskRegs Q&A, Can Undocumented, DACA, and International Students Receive HEERF I or HEERF II Funds? 

HEERF I Funds Spent Prior to Passage of CRRSAA on December 27, 2020
Yes. Effective with publication of the June 17, 2020 Interim Final Rule, the student must:

The requirement to be enrolled in a Title IV-eligible program is new with the publication of the Interim Final Rule. The Title IV eligibility criterion is not new, but is now enforceable by law starting on June 17, 2020. Be sure to review 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 these provisions.

Consult with your U.S. Department of Education (ED) School Participation Division for questions about whether an academic program is a Title IV-eligible program.

Note: This AskRegs Q&A was previously updated to reflect the June 17, 2020 Interim Final Rule.

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.