This guidance is not award-year-specific and applies across award years.
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. Students do not have to be eligible for Federal Pell Grants in order to receive HEERF grants. Also, there is no requirement to award a certain percentage of either HEERF I , HEERF II, or HEERF III grants to Pell-eligible students.
However, it is important to note that unlike the CARES Act, the CRRSSA and ARP require that institutions prioritize students with exceptional need when making grants of leftover HEERF I funds (unexpended as of December 27, 2020) and HEERF II or HEERF III funds. See the following excerpt from Q&A # 7 in the HEERF III Frequently Asked Questions:
"As under the CRRSAA, institutions are directed with the ARP funds to prioritize students with exceptional need, such as students who receive Pell Grants or are undergraduates with extraordinary financial circumstances in awarding emergency financial aid grants to students.
Beyond Pell eligibility, other types of exceptional need could include students who may be eligible for other federal or state need-based aid or have faced significant unexpected expenses, such as the loss of employment (either for themselves or their families), reduced income, or food or housing insecurity."
The school decides which students receive HEERF grants, as well as the amount of each award, after reviewing the respective Certification and Agreement and Frequently Asked Questions applicable to each grant program.
For additional guidance review AskRegs Q&A: Must a Student Be Title IV-Eligible To Receive a HEERF I, HEERF II, or HEERF III Grant?
Update Note: This Q&A was updated on January 19, 2021 to reflect requirements under CRRSAA. Unless specifically indicated, the CRRSAA rules apply to both leftover HEERF I grants after December 27, 2020 and to HEERF II funds.
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