Frequently Asked Questions — Using Pandemic Relief Funds to Provide Incentives to Students

Summary

Frequently Asked Questions on using American Rescue Plan and other pandemic relief funds to provide incentives to students to get the COVID-19 vaccination. The document covers the Department of the Treasury's Coronavirus State and Local Fiscal Recovery Funds, ESSER and GEER funds, and Higher Education Emergency Relief Funds (HEERF). It states that an LEA may use ESSER or GEER funds to provide reasonable incentives to students and their household members to get vaccinated, and that an institution of higher education may use HEERF institutional grant funds to provide reasonable incentives to current students, faculty, and staff. It lists requirements for a HEERF vaccine incentive program, including that incentives be reasonably proportional to the expected public health benefit.

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                                  Frequently Asked Questions
      Using American Rescue Plan and Other Pandemic Relief Funds to Provide
             Incentives to Students to Get the COVID-19 Vaccination

Listed below are some frequently asked questions about acceptable uses of American Rescue
Plan (ARP) funds under the U.S. Department of the Treasury’s Coronavirus State and Local
Fiscal Recovery Funds and the U.S. Department of Education’s Education Stabilization Fund1 to
support COVID-19 vaccinations for students.

Other than statutory and regulatory requirements included in the document, the contents of this
guidance do not have the force and effect of law and are not meant to bind the public. This
document is intended only to provide clarity to the public regarding existing requirements under
the law or agency policies.

State and Local Fiscal Recovery Funds

May recipients use funds from the Coronavirus State and Local Fiscal Recovery Funds
administered by the U.S. Department of the Treasury to pay for vaccine incentive
programs (e.g., cash or in-kind transfers, lottery programs, or other incentives for
individuals who get vaccinated)?

Yes, under the U.S. Department of the Treasury’s Coronavirus State and Local Fiscal Recovery
Funds interim final rule published in the Federal Register on May 17, 2021 (86 FR 26786),
recipients may use Coronavirus State and Local Fiscal Recovery Funds to respond to the
COVID-19 public health emergency, including expenses related to COVID-19 vaccination
programs. See 31 CFR 35.6(b)(1)(i). The cost of programs that provide incentives reasonably
expected to increase the number of people who choose to get vaccinated, or that motivate people
to get vaccinated sooner than they otherwise would have, are an allowable use of funds so long
as such costs are reasonably proportional to the expected public health benefit.

Elementary and Secondary School Emergency Relief (ESSER) and Governor’s Emergency
Education Relief (GEER) Funds

May a local educational agency (LEA) use ESSER or GEER funds to provide incentives to
students and members of their households to get vaccinated against COVID-19?

Yes, an LEA may use ESSER (ESSER I, ESSER II, or ARP ESSER) or GEER (GEER I or
GEER II) funds to provide reasonable incentives to students, consistent with state parent or
guardian medical consent laws, , and their household members to get vaccinated. Providing
reasonable incentives to students, including those enrolled in pre-kindergarten and K-12 (if
1
 The Education Stabilization Fund includes Elementary and Secondary School Emergency Relief (ESSER).
Governor’s Emergency Education Relief (GEER), and Higher Education Emergency Relief (HEER) funds awarded
under the Coronavirus Aid, Relief, and Economic Security (CARES) Act (ESSER I, GEER I, and HEER I); the
Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, 2021 (ESSER II, GEER II, and
HEER II); and the ARP Act (ARP ESSER and HEER III).
eligible for vaccination), and their household members to get vaccinated against COVID-19 is
allowable because it is a strategy that an LEA may implement in alignment with the Centers for
Disease Control and Prevention (CDC) guidance on vaccinations, increase vaccination rates in
the community and therefore bolster public health, and reduce risk of transmission and serious
disease as students and staff return to or continue in-person instruction

To the extent practicable, LEAs should provide information about vaccination incentives written
in a language that parents can understand or, if it is not practicable to provide written translations
to a parent with limited English proficiency, be orally translated for such parent. In addition,
LEAs should provide the information using auxiliary aids and services and in an alternative
format accessible to a parent who is an individual with a disability covered under Section 504 of
the Rehabilitation Act of 1973.

Any incentives that an LEA provides with ESSER and GEER funds must meet the requirements
in 2 CFR Part 200, including the requirement that the amount of the incentive be reasonable and
may not violate any other applicable laws or requirements (e.g., incentives may not involve
alcohol per 2 CFR § 200.423). For example, an LEA might host a drawing in which all
vaccinated students are entered to win a prize such as a new tablet, a reasonable cash award,
college scholarship money, or new school supplies and books. Similarly, an LEA might give
each vaccinated student a nominal gift card or any other allowable incentive that is reasonable in
size and scope and likely to lead to an increase in the rate of vaccinations.

GEER I and GEER II funds may also support COVID-19 vaccination efforts, when available for
younger children, in state and local public pre-kindergarten programs that may include programs
located in schools or community-based pre-kindergarten/early childhood education settings.

Additional information on allowable uses of ESSER and GEER funds may be found in the
Department’s Frequently Asked Questions document on Elementary and Secondary School
Emergency Relief Programs and Governor’s Emergency Education Relief Programs. For
example, FAQ B-3 addresses the use of funds to provide COVID-19 vaccinations to teachers,
staff, and eligible students.

Higher Education Emergency Relief Funds (HEERF)

May an institution of higher education (IHE) use its HEERF institutional grant funds
(issued under the CARES Act, the CRRSA Act, or the ARP Act) to provide incentives to
students, faculty, and staff of the institution to get vaccinated against COVID-19?

Yes, an IHE may use HEERF institutional grant funds to provide reasonable incentives to current
students, faculty, and staff of the institution to get vaccinated against COVID-19. Specifically,
CRRSA Act section 314(c)(1), applicable to the CARES Act, the CRRSA Act, and the ARP Act,
allows institutions to “defray expenses associated with coronavirus.” Providing incentives to
current students, faculty, and staff to get vaccinated against COVID-19 is allowable both as a
direct expense that the institution is incurring associated with COVID-19 and as a risk mitigation
strategy to prevent the greater institutional expenses that would occur because of a COVID-19
outbreak on campus.
Incentives to get the vaccine could include paid for time off or sick leave for employees,
vaccination paraphernalia, tuition discounting, and other monetary incentives that are expected to
spread awareness or build confidence in getting vaccinated, among other examples.

Any vaccine incentive program funded in whole or in part using HEERF grant funds must:
   • Provide incentives reasonably proportional to the expected public health benefit (i.e.,
      incentives expected to increase the number of people who choose to get vaccinated, or
      that motivate people to get vaccinated sooner than they otherwise would) consistent with
      the cost principles of the Uniform Guidance in 2 CFR part 200, subpart E.
   • Include only allowable incentives under all applicable laws (e.g., incentives may not
      involve alcohol per 2 CFR § 200.423).
   • Be offered only to currently enrolled students or institutional faculty and staff. While
      institutions of higher education may host vaccination sites that are open to the public and
      local community, HEERF dollars cannot be used as incentives for individuals that are not
      current students, faculty, or staff. If an institution seeks to provide incentives to those
      outside of its IHE community, it should consider whether such expenses may be
      allowable using state, local, or other federal funds.
   • Not be used to recruit, advertise, or market the vaccine incentive program to prospective
      or unenrolled students and not be used to incentivize current or future enrollment
      decisions. See CRRSA Act section 314(d)(3).
   • Only use HEERF institutional funds under the (a)(1), (a)(2), or (a)(3) programs and not
      use any HEERF grant funds that must be used to make emergency financial aid grants to
      students (i.e., Assistance Listing Numbers (ALNs) 84.425E and 84.425Q).
   • Retain documentation to demonstrate how the vaccine incentive program is reasonably
      proportional to the expected public health benefit consistent with ARP section 2003(5)(a)
      and 2 CFR § 200.334.
   • Take reasonable steps to provide meaningful access to its program for limited English
      proficient individuals, by providing access to translated documents, interpreter services,
      or information in the individual’s primary language.

Additional information on allowable uses of HEERF grant funds may be found in the
Department’s HEERF III ARP Frequently Asked Questions Document. For example, section D
of the FAQ Document describes the requirement for IHEs to spend a portion of their HEERF
grant funds to “implement evidence-based practices to monitor and suppress coronavirus in
accordance with public health guidelines.”


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