Methodology for Calculating Allocations for Section 18004(a)(2) of the CARES Act
Summary
Department of Education methodology, revised as of May 22, 2020, for the CARES Act section 18004(a)(2) share of the Higher Education Emergency Relief Fund: 7.5% of the $13.95 billion, or $1.05 billion, for additional awards to institutions under parts A and B of titles III and V and subpart 4 of part A of title VII of the Higher Education Act, split by each program's share of Further Consolidated Appropriations Act, 2020 funding. The Department used the formula applied to the first 90% of funding, but at the unanimous request of all 35 eligible grantees it revised the Tribally Controlled Colleges and Universities allocations to follow the section 316 formula, with an equal base award and the rest by Indian student count. A chart lists amounts such as $197.1 million for Developing Hispanic-Serving Institutions and $148.6 million for the Strengthening Institutions Program.
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“Methodology for Calculating Allocations for Section 18004(a)(2) of the CARES Act.”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-methodology-for-calculating-allocations-www-ed-gov-386152f188/
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Methodology for Calculating Allocations for Section 18004(a)(2) of the CARES Act
(revised as of May 22, 2020 1)
The CARES Act provided $13.95 billion for the Higher Education Emergency Relief Fund
(HEERF) under Section 18004. Section 18004(a)(2) of the Act allocates 7.5% of that amount
($1.05 billion) for additional awards to eligible institutions under parts A and B of titles III and V
and subpart 4 of part A of title VII of the Higher Education Act of 1965, as amended (HEA).
The CARES Act further stipulates that the $1.05 billion must be allocated across these programs
proportionally based on the allocations these programs received in the Further Consolidated
Appropriations Act, 2020 (Public Law 116–94). The 11 grant programs that are covered by the
named parts of the HEA and which were funded for fiscal year 2020, are described further in the
chart below.
In distributing funding to institutions under the programs, except the American Indian Tribally
Controlled Colleges and Universities (TCCU) program, referenced in Section 18004(a)(2), the
Department adopted the same formula used to distribute the first 90% of the HEERF funding in
Section 18004(a)(1)
(https://www2.ed.gov/about/offices/list/ope/heerf90percentformulaallocationexplanation.pdf).
The formula was applied separately to all eligible grantees within each of the 10 program
funding amounts. An institution that would be eligible to receive grant funds under the
eligibility criteria/requirements for several of the 10 programs, notwithstanding any limits in
those programs that would exist for those grant awards on concurrent funding and waiting
periods, will receive a Section 18004(a)(2) grant award that aggregates the amounts the
institution would receive under the formula for each program, following the rules described in
the bullet points and chart further below.
The Department originally applied the same methodology to determine the grant awards for
institutions eligible by way of their eligibility for the TCCU program. However, based on the
request and unanimous support of all 35 eligible grantees for the TCCU program, the
Department has revised its methodology to use the formula described in Section 316 of the HEA
to distribute Section 18004(a)(2) grant awards to eligible institutions under the TCCU program.
The Department believes that this change is reasonable, as the statutory formula was the product
of careful negotiations between the Federal and Tribal governments and aligns with the TCCUs’
shared cultural priorities of community and equity – in this case, that each TCCU first receive a
base award of an equal amount and that the remainder of the funding is distributed based on each
TCCU’s total Indian student count. This formula is important to the TCCUs because it ensures
that even small institutions receive an award sufficient to address each institution’s needs. The
formula recognizes the unique needs of small, rural, or remote institutions serving students who
often live across very large Indian reservations (several of which are larger than five states).
1
This document has been revised to reflect changes in how the Department is allocating funds among American
Indian Tribally Controlled Colleges and Universities (TCCUs), for reasons explained in the document.
The change in the methodology for institutions whose section 18004(a)(2) grant award is based
upon their eligibility for the TCCU program does not affect the 18004(a)(2) grant award amounts
for institutions whose eligibility for these grant awards are based on the other 10 grant programs.
The rules for grant awards are as follows:
• HBCUs: For the 3 programs that support Historically Black Colleges and Universities
(HBCUs) (the green rows in the chart below), eligible entities are limited to institutions
that meet certain specific statutory definitions. For HBCUs that receive funding under
more than one HBCU program, allocations were combined into a single Section
18004(a)(2) grant. The Section 18004(a)(2) grant amounts awarded to institutions that
meet the requirements for these 3 programs do not include amounts from any of the other
8 grant programs discussed in the other bulleted paragraphs.
• TCCUs: For the program that supports American Indian Tribally Controlled Colleges
and Universities (TCCUs)(the blue row below), the Department distributed funding to
institutions based on the formula described in Section 316 of the HEA. Section
18004(a)(2) grant amounts awarded to TCCUs do not include amounts from any of the
other 10 programs discussed in the other bulleted paragraphs. Eligibility to participate in
this program is limited to those institutions named in statute (the Equity in Educational
Land-grant Status Act of 1995) or that receive funding under the Tribally Controlled
Colleges and Universities Assistance Act of 1978.
• MSIs: For the 6 programs in which eligibility is based, in part, on meeting a specific
minority enrollment threshold (the orange rows in the chart below), the Department
identified the universe of eligible institutions from the Department’s Minority Serving
Institution (MSI) Grant Eligibility Matrix 2020. The Eligibility Matrix identifies
institutions that have been designated for Fiscal Year (FY) 2020 as eligible under the
titles III and V programs and that meet the minority enrollment threshold for particular
programs. For the institutions that meet the requirements for more than one program,
allocations are combined into a single grant made available under this subsection. The
Section 18004(a)(2) grant amounts awarded to institutions that meet the requirements for
these 6 programs do not include amounts from any of the other 5 grant programs
discussed in the other bulleted paragraphs.
• SIP: For the Strengthening Institutions Program (SIP) (the gray row in the chart below),
the universe of eligible entities was limited to those institutions that have been
designated as an eligible institution in FY 2020 under the titles III and V grant programs
under the HEA and that did not receive any Section 18004(a)(2) funding through any of
the other 10 grant programs discussed in the other bulleted paragraphs.
• Under each of the programs in which the eligible entities are not specifically named in
statute (in the orange and gray rows of the chart below) , the Department has reserved
2% of the funding so that institutions that believe they are eligible, including eligible
branch campuses whose parent institution is not eligible for Section 18004(a)(2) grants,
may request funding and submit the requisite data. The Department will provide
information on how to request funds from this reserve in the near future.
18004(a)(2)
Funding Level
Number of
(inclusive of 2% 2
Program Eligibility Criteria Eligible
reserve amounts
Institutions 3
in select
programs)
Strengthening
Historically Black
Colleges and “Part B” institutions as described
$447.5 million 96
Universities in section 322(2) of the HEA
(Strengthening
HBCUs) Program
Strengthening
Historically Black Institutions named in section
$115.7 million 24
Graduate Institutions 326(e)(1) of the HEA
(HBGIs) Program
Master's Degree
Programs at
Historically Black Institutions named in section
$13.7 million 18
Colleges and 723(b)(1) of the HEA
Universities (HBCU
Master’s) Program
Institutions that qualify for
funding under the Tribally
Controlled College or University
American Indian Assistance Act of 1978 or the
Tribally Controlled Navajo Community College
Colleges and $50.5 million Assistance Act of 1978; are cited 35
Universities (TCCUs) in section 532 of the Equity in
Program Educational Land Grant Status
Act of 1994; or are designated as
eligible for funding by the Bureau
of Indian Education
2
Any reference to requirements established in specific HEA programs do not include those programs’ concurrent
funding limits or waiting period requirements, which are not being applied for the purposes of the Section
18004(a)(2) grant awards.
3
There may be some overlap in these totals, due to some institutions’ eligibility for allocations related to more than
one of the 11 HEA programs within each applicable group of programs (HBCUs and TCCUs, MSIs, or SIP). Please
also note that the totals in this column may change as the Department updates its knowledge as to the schools
eligible for Section 18004(a)(2) funds, such as updates to account for closed institutions. Please refer to the
allocation table for the Section 18004(a)(2) funds for current totals and listings of schools.
Institutions designated as eligible
in FY 2020 for titles III and V
programs and that have
Predominantly Black
Institutions Program - enrollment of undergraduate
$18.2 million students that is at least 40 percent 80
Formula Grants
(PBIs) black American, and that have at
least 1,000 undergraduate
students
Institutions designated as eligible
in FY 2020 for titles III and V
Alaska Native and programs and that have
Native Hawaiian enrollment of undergraduate
$25.2 million 16
Serving Institutions students that is at least 20%
(ANNH) Program Alaska Native or 10% Native
Hawaiian students
Institutions designated as eligible
in FY 2020 for titles III and V
Asian American- and
Pacific Islander- programs and that have an
serving Institutions $6.1 million enrollment of undergraduate 160
(AANAPISI) students that is at least 10% Asian
Program American and Native American
Pacific Islander
Institutions designated as eligible
in FY 2020 for titles III and V
Native American-
Serving Nontribal programs and that have an
$6.1 million enrollment of undergraduate 29
Institutions
(NASNTI) Program students that is at least 10%
Native American
Institutions that have been
designated as eligible in FY 2020
Developing Hispanic- for titles III and V programs and
Serving Institutions $197.1 million that have an enrollment of 419
(DHSI) Program undergraduate students that is at
least 25% Hispanic
Promoting Institutions designated as eligible
Postbaccalaureate in FY 2020 for titles III and V
Opportunities for $17.7 million programs and that have an 183
Hispanic Americans enrollment of undergraduate
(PPOHA) Program students that is at least 25%
Hispanic and that offer a
postbaccalaureate program
Institutions designated as eligible
in FY 2020 for titles III and V
programs and that did not receive
18004(a)(2) grant awards as a
Strengthening result of not meeting the
Institutions Program $148.6 million requirements for the 1,027
(SIP) Strengthening HBCUs, HBGIs,
HBCU Master’s, TCCUs, PBIs,
ANNH, AANAPISI, NASNTI,
DHSI, and/or PPOHA programs
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