On December 27, the President signed the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), expanding COVID-19 pandemic relief to a host of sectors and industries, including educational institutions. The bill provides almost $82 billion for pre-K-12 schools and universities, including $21 billion for colleges and universities available through the Higher Education Emergency Relief Fund II (HEERF II).
This most recent round of funding appears to have greater flexibility on how institutions can use the funds. With these new campus health funds available, colleges and universities are anxious to access and understand how to use them. As the government works to finalize application and distribution, we've done our homework on what you need to know.
1. Who can apply for HEERF II funds?
Institutions of Higher Education (IHEs) and post-secondary vocational institutions (i.e., community colleges and vocational schools) found in the funding allocation table may apply for these funds. Unlike with the CARES Act funding, online-only institutions may also apply. As with the original CARES Act HEERF funding, institutions with higher numbers of full-time Pell Grant recipients will receive priority.
IHEs who received funding in the original CARES Act do not need to reapply. As of January 15, supplemental funds were automatically distributed according to the allocation table. The Project Director identified in the institution's current Grant Award Notification (GAN) should receive an email detailing the additional funds. However, grantees who have not completed quarterly and/or annual reporting requirements may see a delay in receiving funds until those requirements are met.
Institutions who received only the Student Aid Portion under the CARES Act may complete a new application for the Institutional Portion only. Such institutions will receive a supplemental Student Aid Portion similar to those who initially received funding for both portions.
Proprietary institutions have a separate application, listed on the Department of Education website.
2. What can the funds be used for on campus?
The funds' goal is to defray additional expenses incurred by the institution due to the COVID-19 pandemic. Funding in the Institutional Aid Portion may cover:
- Lost revenue or reimbursement of already incurred expenses
- Tech costs associated with the transition to distance learning
- PPE, sanitization and other protective measures to ensure campus safety
- Faculty training
As with the original CARES Act funding, the CRRSAA funds have a Student Aid Portion to provide financial aid grants to students, but this new iteration adds students enrolled in distance learning to this group. The Act also included more specifics on what "financial aid" can contain. Financial aid can include help with:
- Cost of attendance
- Food and housing
- Health Care (including mental health care)
In a change from previous stipulations, students who are not eligible for financial aid due to reasons such as academic performance or loan default can receive grants through CRRSAA funding.
Lastly, CRRSAA funds can be used to support activities authorized by the Higher Education Act related to the coronavirus. This opens up additional spaces for institutions applying as they may use provisions from the 1965 act and its eight provisions to justify need.
Additionally, any funds remaining from CARES Act Institutional Portion funding may now be used for any activities outlined in the updated CRRSAA.
3. Where is the application available?
Information on the application is available now and can be found on the Department of Education website here. There are separate applications for the Student Aid and Institutional Portions and a separate Proprietary Institution application.
Applicants must apply within 90 days of application opening to be considered. The application opened on January 15, meaning all applicants have until April 15 to complete their submissions. Once the 90-day window has closed, all remaining funds not committed will be reallocated to the current grantees. No application extensions will be granted.
4. Are there any restrictions on the funds?
Yes, the majority of IHE applicants must still reserve "the same amount" of funds it received from CARES Act funding for emergency financial aid grants to students.*
Currently, all HEERF funds must be used by September 30, 2022.
The majority of new restrictions apply to the Student Aid Portion:
- IHEs paying excise tax based on investment income under IRC 4968 will have its allocation reduced by 50%, and all funds must be used for student emergency financial aid grants**
- IHEs may not condition student grant funding on "continued or future enrollment in the institution"
- Student grants may not be used to "satisfy a student's outstanding balance" unless a student has given their written consent
- IHEs may not condition a grant on the stipulation that a student gives their written consent to use a grant to satisfy their balance
- Grantees are "under an obligation to minimize time" between receiving Student Aid Portion funds and distributing them to students – the Department of Education will review those who have not distributed funds within 15 days of receiving
* Note that the 50% rule (requiring 50% of all funds received to go to student emergency grants) is no longer in place but has been changed to be the same monetary amount as previous funding rather than a percentage of the new funding.
**This restriction can be waived by the Secretary under special circumstances, such as when taxable assets are unable to be liquified to defray costs.
5. Where can I go for more information?
Updates will be provided on the U.S. Department of Education website here. The Department also released its own FAQ, addressing common questions and concerns around the new funding, which can be accessed here. Additionally, the Department released a Fact Sheet detailing the differences between HEERF and HEERF II here.
For more information on how to apply your HEERF funding to vetted health and wellness innovations for your campus, get in touch with the experts at HORAN. Our Campus Health Solutions team is poised to guide you through impactful solutions and get you in touch with experienced partners to help your campus thrive.
Let us quickly guide you to the best options for your unique campus community: fill out a simple contact form or get in touch with Chris Mihin, HORAN Campus Health Vice President and Managing Principal, at ChrisM@horanassoc.com or 513.702.3707