This AskRegs Knowledgebase Q&A was updated on June 10, 2021 to include a cross-reference to a Q&A addressing whether HEERF I and HEERF II funds must be spent before drawing down HEERF III funds.
The following guidance relates to HEERF I funds under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), HEERF II funds under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021), and HEERF III funds under the American Rescue Plan Act of 2021 (ARP).
Deadline to Apply for HEERF III Funds
For institutions that received HEERF II funds, applications are not required to receive supplemental awards under HEERF III. Public and nonprofit Institutions that did not previously receive CRRSAA funding must submit their separate applications for the ARP student aid portion and institutional portion of Section 314(a)(1) funds by August 11, 2021. Likewise, proprietary institutions must submit their applications for the ARP student aid portion of Section 314(a)(4) funds by August 11, 2021. Information on how to apply may be found on the U.S. Department of Education's (ED's) ARP: American Rescue Plan Fund page.
Additionally, schools that previously received HEERF II grant funds and are receiving an ARP (a)(1) or (a)(4) supplemental award(s) are required to start drawing down funds from both the student and institutional portions of HEERF III funds within 90 days of receiving their respective supplemental HEERF III Grant Award Notifications (GANs). According to Q&A #2 of the HEERF III FAQs:
"Please note that drawing down any amount of these supplemented funds constitutes your institution’s acceptance of the applicable terms and conditions under the ARP and as described in the Supplemental Agreements that will be emailed to the Project Director separately. For reference, examples of the new Supplemental Agreements for the Student Aid Portion and Institutional Portion grants are available in our notice announcing the availability of these new funds in the ARP (a)(1) notice inviting applications (NIA) published in the Federal Register here."
Reference Q&A #2, #3, #4, and #5 in the Higher Education Emergency Relief Fund (HEERF) III Frequently Asked Questions for more details on how to apply for these funds.
Deadline to Apply for HEERF II Funds
For institutions that received HEERF I funds, applications were not required to receive supplemental awards under HEERF II. Public and nonprofit Institutions that did not previously receive CARES Act funding were required to submit their applications for the CRRSAA student aid portion and institutional portion of Section 314(a)(1) funds by April 15, 2021. Likewise, proprietary institutions were required to submit their applications for the CRRSAA student aid portion of Section 314(a)(4) funds by April 15, 2021. Information on how to apply may be found on the ED's CRRSAA: Higher Education Emergency Relief Fund page.
Additionally, schools that previously received HEERF I grant funds under the CARES Act were required to start drawing down funds from both the student and institutional portions of HEERF II funds within 90 days of receiving their respective supplemental HEERF II GANs. According to the Notice Inviting Applications for Funds, the following applies to both supplemental HEERF II student and institutional grant funds:
"Recipient acknowledges that its failure to draw down any amount of its supplemental grant funds within 90 days of the date of this supplemental award will constitute nonacceptance of the terms, conditions, and requirements of this Supplemental Agreement and of these supplemental grant funds. In such event, the Department, in its sole discretion, may choose to deobligate these supplemental grant funds or take other appropriate administrative action, up to and including terminating the grant award pursuant to 2 CFR 200.340."
Remember, the school cannot simply draw down it's entire HEERF student and institutional allocations at once. See AskRegs Q&A, Should HEERF Funds Be Drawn Down From G5 As They Are Awarded Or In a Lump Sum?, for more information.
Deadline to Apply for HEERF I Funds
The September 4, 2020 Federal Register Notice extended the application deadline for HEERF I grants under Sections 18004(a)(1), 18004(a)(2), and 18004(a)(3) of the CARES Act until September 30, 2020. Applications are no longer being accepted for HEERF I funds. It extended all deadlines noted below.
Deadlines Prior to the September 4, 2020 extension: In order to receive funds from HEERF I, institutions that did not initially apply to receive allocations were required to do so no later than Saturday, August 1, 2020. ED published a notice in the Federal Register establishing the deadline date on June 24, 2020. Application procedures are outlined on ED's CARES Act: Higher Education Emergency Relief Fund website. See also AskRegs Q&A, How Do We Apply For Higher Education Emergency Relief Funds On Grants.gov?
The August 1 deadline applied to the HEERF funds with following Catalog of Federal Domestic Assistance (CFDA) numbers:
There was an exception for potentially-eligible schools that were not allocated funds in the original formula-based allocation table under Section 18004(a)(1) of the CARES Act. Those schools could apply for the reserve fund and needed to submit the Funding Certification and Agreement form for both the student and institutional portion of funds no later than August 15, 2020. See NASFAA Today's News article, Schools That Were Not Allocated CARES Funding Can Now Apply for Reserve Funds, for additional information that needed to be submitted to HEERF@ed.gov by August 15.
Schools that received funds under Section 18004(a)(3) also were required to submit a completed Budget and Expenditure Reporting form by August 30, 2020 if that funding fell into any of the following categories:
ED has notified presidents of potentially-eligible institutions that fall into one or more of these four categories of the reporting requirements. See Today's News article, ED Releases Information About Application Process for Additional HEERF Funding for Needy Institutions.
NASFAA has confirmed with ED that the September 4 Federal Register Notice also extended the deadline for the Budget and Expenditure Reporting until September 30, 2020.
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