The Department of Education (ED) has released new guidance for all Higher Education Emergency Relief Fund (HEERF) allocations passed by Congress to date.

One of the biggest items in the new guidance is that the ED has now clearly formalized that all HEERF allocations (from all 3 rounds) are eligible to be used with the guidelines for all permitted uses dating back to March 13, 2020. See the notice below:

Department of Education Notice

In addition, the new guidance clarifies that the one-year spending period that has been applied to each individual HEERF allocation is being reset with the granting of each additional HEERF allocation. As such, schools have one year to spend its remaining HEERF funds (regardless of which round) from the date of its upcoming award notification from the American Rescue Plan.

The ED officially document that all HEERF funds can be used for grants to student, including those that are not Title-IV eligible, such as non-degree-seeking, non-credit, dual enrollment, and continuing education students, as well as students who have left school for any reason during the period of the national COVID-19 emergency that began on March 13, 2020. The updated guidance also allows for grants to qualified aliens.

The ED confirmed that institutions can pay these grants to students using their normal process for providing credit balance refunds to students without obtaining consent from the student. These funds must remain unencumbered by the school. If the school is applying the emergency grant directly to existing balances, the institution must obtain student consent first.

Finally, the Ed also released new Frequently Asked Questions that addresses many of the open questions regarding lost revenue as one of the allowable uses of all HEERF institutional funds. Lost revenue must be directly related to COVID-19 and the calculation can take in account all lost revenues dating back to March 13, 2020. Allowable lost revenues include tuition, room, board, fees, summer camps, bookstore, parking, and other institutional revenue sources that have been impacted. Lost revenue does not have to be associated with, or netted against, expenses and is considered an allowable use for quarterly and annual reporting to ED and on the Schedule of Expenditures of Federal Awards (SEFA).

Lance Mann, CPA, CFE, CGMA
Assurance Director • 502.566.1005