Do Students Have To Be Pell-Eligible To Receive Higher Education Emergency Relief Funds?

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This AskRegs Knowledgebase Q&A was updated on January 19, 2021 to reflect requirements under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) under 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. Students do not have to be eligible for Federal Pell Grants in order to receive HEERF I grants under the CARES Act or HEERF II funds under CRRSAA for students. That is merely a suggestion for one place you can choose to start when awarding HEERF grants. Also, there is no requirement to award a certain percentage of either HEERF I or HEEERF II grants to Pell-eligible students.

However, it is important to note that unlike the CARES Act, CRRSSA requires that institutions prioritize students with exceptional need when making grants of remaining HEERF I funds (unexpended prior to December 27, 2020) and HEERF II funds. See the following from 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):

“4. Question: What are the requirements for making financial aid grants to students?

Answer: Unlike the CARES Act, the CRRSAA requires that institutions prioritize students with exceptional need, such as students who receive Pell Grants, in awarding financial aid grants to students. However, students do not need to be only Pell recipients or students who are eligible for Pell Grants. In addition, the CRRSAA explicitly provides that financial aid grants to students may be provided to students exclusively enrolled in distance education.

Institutions may not (1) condition the receipt of financial aid grants to students on continued or future enrollment in the institution, (2) use the financial aid grants to satisfy a student’s outstanding account balance, unless it has obtained the student’s written (or electronic), affirmative consent, or (3) require such consent as a condition of receipt of or eligibility for the financial aid grant.

Institutions should carefully document how they prioritize students with exceptional need in distributing financial aid grants to students, as the Department intends to establish reporting requirements regarding the distribution of financial aid grants to students consistent with section 314(e) of CRRSAA.”

The school decides which students receive HEERF grants, as well as the amount of each award, after reviewing the Recipient’s Funding Certification and Agreement for Emergency Financial Aid Grants to Students, the CRRSAA Certification and Agreement for Public and Nonprofit Institutions Grant Funds for Students, the CRRSAA Certification and Agreement for Proprietary Institution Grant Funds for Students, and the Frequently Asked Questions about the Emergency Financial Aid Grants to Students.

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