Can We Hold Higher Education Emergency Relief Fund Monies In an Interest-Bearing Account?

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This AskRegs Knowledgebase Q&A was updated on January 20, 2021 to reflect requirements under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021). The same rules apply to both Higher Education Emergency Relief Fund (HEERF) grants under the CARES Act (HEERF I funds) and to new funds under the CRRSAA (HEERF II funds).

Yes, in fact, the school must maintain any drawn down HEERF I or HEERF II funds in an interest-bearing account. Remember that the school should only be drawing down HEERF I grants under the CARES Act or HEERF II grants under the CRRSAA as the school has immediate needs to disburse those funds directly to students or to pay institutional costs. That is, the school should not be drawing down funds in advance of meeting immediate needs. An immediate need is an obligation that must be paid within 3 calendar days for institutional funds and within 15 calendar days for student funds. Failure to pay out the grant funds within the specified number of days after drawing down from G5 may result in the school being subjected to heightened scrutiny by the U.S. Department of Education (ED) and/of the Office of Inspector General.

If there is any interest of $500 or more, that interest must be returned to ED.

See the following HEERF II grant certifications and agreements for more on grant administration:

HEERF I Source: Office of Postsecondary Education Higher Education Programs Technical Assistance Higher Education Emergency Relief Fund webinar, June 23, 2020.

See also AskRegs Knowledgebase Q&A, Should HEERF Funds be Drawn Down From G5 as They are Awarded or in a Lump Sum?

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