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

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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 following rules apply to both Higher Education Emergency Relief Fund (HEERF) grants under the CARES Act (HEERF I funds) and to funds under the CRRSAA (HEERF II funds).

There has not been any specific written guidance to date from the U.S. Department of Education (ED) concerning the handling of unclaimed Higher Education Emergency Relief Fund (HEERF) student grants (HEERF I or HEERF II). However, our understanding is that the requirement that funds not be permitted to escheat to the state applies broadly to all federal funds, not only Title IV funds, and HEERF would therefore be included.

According to past webinar guidance from ED, 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 award HEERF student grant funds after drawing them down from G5. It is NASFAA's understanding that you should award 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.

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