Does an Institutional Emergency Grant Program Count As Other Financial Assistance?

No. Emergency aid programs administered by the school are not considered other financial assistance (OFA) as long as certain conditions are met. 

Effective with the 2024-25 award year, estimated financial assistance (EFA) will be renamed other financial assistance (OFA), and Section 480(i)(5) of the Higher Education Act of 1965 (HEA), as amended [20 USC 1087vv(i)(5), Amendment of Section] states: "Notwithstanding paragraph (1), emergency financial assistance provided to the student for unexpected expenses that are a component of the student's cost of attendance, and not otherwise considered when the determination of the student's need is made, shall not be treated as other financial assistance for purposes of section 1087kk(a)(3) of this title."

During the U.S. Department of Education's (ED's) webinar, The FAA's Role in FAFSA Simplification, ED stated that "[Y]ou may exclude emergency financial assistance provided to the student for unexpected expenses that are a component of the student's cost of attendance. The emergency does not have to be a federal or state declared emergency or disaster. Your school determines what is meant by an emergency for a specific student situation."

Since ED specifically gives schools the flexibility and discretion to determine what is an emergency for a specific student situation, NASFAA encourages schools to make their own determinations and not to ask for further definition that will restrict other schools' ability to exercise their own flexibility and discretion. We do not expect additional ED guidance on this topic at this time. If/When we receive additional guidance, we will update this Q&A.

See the AskRegs Knowledgebase Q&A, Will Emergency Aid Be Treated As Other Financial Assistance Starting In 2024-25?