Are We Required To Follow Title IV Cash Management Rules For Higher Education Emergency Relief Funds?

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This guidance is not award-year-specific and applies across award years.

This AskRegs Knowledgebase Q&A was updated on January 22, 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 Higher Education Emergency Relief Fund (HEERF) grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (HEERF I funds) and to new funds under the CRRSAA (HEERF II funds).

U.S. Department of Education (ED) guidance does not state that all Title IV cash management rules apply when awarding or disbursing Higher Education Emergency Relief Fund (HEERF) grants (student or institution portions). In Q&A #19 of the Higher Education Emergency Relief Fund (HEERF) Frequently Asked Questions (FAQ) Rollup Document, ED does state that you have to follow the Title IV cash management rules related to the payment method you’re using to deliver the grant funds to students (for example, rules related to debit or payment cards). Also, in the HEERF II Frequently Asked Questions ED states that student grants may be credited directly to the student's account with the student's voluntary written consent.

Otherwise, in the Grant Award Notification that schools receive from, it states that schools must follow cash management requirements under OMB Uniform Guidance. If you have questions about OMB Uniform Guidance, you will need to discuss them with your school's business office or legal counsel, as this is not NASFAA's area of Title IV expertise. We know that the National Association of College and University Business Officers (NACUBO) is tracking this issue and we hope to receive more guidance. If or when that happens, we will update this AskRegs Knowledgebase Q&A and post it in Today's News.

Also see the following AskRegs Knowledgebase Q&As:

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.