This AskRegs Knowledgebase Q&A was updated on May 12, 2021 to include guidance in the May 11, 2021 Higher Education Emergency Relief Fund (HEERF) III Frequently Asked Questions and the May 14, 2021 Final Rule as it relates to 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).
Yes. According to the U.S. Department of Education’s (ED’s) Final Rule, any individual who is or was enrolled at an eligible institution on or after March 13, 2020 is now eligible for HEERF I, HEERF II, and HEERF III student grants. In other words, it applies retroactively to all students and for all three HEERF programs.
This means that schools can award HEERF I, HEERF II, and HEERF III to students who are not enrolled in Title IV-eligible programs. This includes nondegree, noncredit, and continuing education students, students who are simultaneously enrolled in high school and college, students who have graduated or withdrawn, and so on.
Reference the Final Rule and Q&A #7 and #8 in the above-referenced HEERF III FAQ, as well as Q&A #22 in the revised HEERF II Frequently Asked Questions.
This guidance and Final Rule represents a break from the Trump administration's previous interpretation, which held that students needed to be Title IV-eligible students in Title IV-eligible programs to qualify for HEERF grants. See AskRegs Q&A, Must a Student Be Title IV-Eligible To Receive a HEERF I, HEERF II, or HEERF III Grant?, for historical background information.
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