Must Schools Return HEERF Student Funds To ED When the Student Fails To Claim the Funds Or Cash the Check?

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, 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).

If HEERF checks are not cashed or funds remain unclaimed after attempts to deliver those funds to the student, the school must either promptly return the funds to ED through G5 or award those funds to another student.

Remember, the school has 15 calendar days to disburse HEERF student grant funds after drawing them down from G5. It is NASFAA's understanding that you should award and disburse those funds from an uncashed check to another student in a timeframe consistent with that same 15-calendar-day period if you do not return them to G5.

See the HEERF III Frequently Asked Questions Q&A #18:

"What steps can my institution take if a student does not cash a check issued for student’s emergency financial aid grant? 

If a student does not cash their emergency financial aid grant check by a reasonable date, the institution may choose to void the check and redistribute the funds to other students by the end of their HEERF grant performance period. Institutions should engage in reasonable attempts to contact a student prior to voiding a check for an emergency financial aid grant and should document the procedures, policies, and general student contact efforts made and followed as part of their administration of their HEERF grants."

Update Note: This Q&A was updated on January 20, 2021 to reflect requirements under CRRSAA,applicable to both HEERF I and HEERF II funds.