Must the School Hold Higher Education Emergency Relief Fund Monies In an Interest-Bearing Account?

This AskRegs Knowledgebase Q&A was updated on May 13, 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).

Yes, the school must maintain any drawn down HEERF I, HEERF II or HEERF III funds in an interest-bearing account. Remember that the school should only be drawing down HEERF I, HEERF II, or HEERF III grants as the school has immediate needs to obligate those funds 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 15 calendar days for student grant funds and within 3 calendar days for all other uses (including institutional 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 III grant certifications and agreements for more on grant administration:

• American Rescue Plan Act of 2021 Certification and Agreement (ALN 84.425E) (a)(1) Student Aid Portion) PUBLIC AND NONPROFIT INSTITUTION GRANT FUNDS FOR STUDENTS
• American Rescue Plan Act of 2021 Supplemental Agreement (ALN 84.425E) ((a)(1) Student Aid Portion) SUPPLEMENTAL GRANT FUNDS FOR STUDENTS
•  American Rescue Plan Act of 2021 Certification and Agreement (ALN 84.425Q) ((a)(4) Program) PROPRIETARY INSTITUTION GRANT FUNDS FOR STUDENTS
• American Rescue Plan Act of 2021 Supplemental Agreement (ALN 84.425Q) ((a)(4) Program) PROPRIETARY INSTITUTION SUPPLEMENTAL GRANT FUNDS FOR STUDENTS

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

• Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Certification and Agreement (CFDA 84.425E) ((a)(1) Student Aid Portion) PUBLIC AND NONPROFIT INSTITUTION GRANT FUNDS FOR STUDENTS 
• Coronavirus Response and Relief Supplemental Appropriations Act, 2021Supplemental Agreement (CFDA 84.425F) ((a)(1) Institutional Portion) SUPPLEMENTAL GRANT FUNDS FOR INSTITUTIONS
• Coronavirus Response and Relief Supplemental Appropriations Act, 2021 Certification and Agreement (CFDA 84.425Q) ((a)(4) Program) PROPRIETARY INSTITUTION GRANT FUNDS FOR STUDENTS

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?

Note: This Q&A was updated on January 20, 2021 to reflect requirements under CRRSAA and to note the same rules apply to both HEERF I AND HEERF II funds.