Methodology for Calculating Allocations Under the American Rescue Plan Act of 2021 (Published July 29, 2021)
Summary
A methodology document, Methodology for Calculating Allocations Under the American Rescue Plan Act of 2021 pursuant to Section 314(a)(2) of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021, published July 29, 2021. It states that 7.5 percent ($2.97 billion) of the Higher Education Emergency Relief Fund funds under the American Rescue Plan Act is allocated pursuant to section 314(a)(2) for additional awards to eligible institutions. It describes the formulas for the Strengthening HBCUs and HBCU Masters programs, HBGIs and TCCUs, and eligibility rules for 11 grant programs. A chart lists funding levels, including $1,270 million for Strengthening Historically Black Colleges and Universities and $421.6 million for the Strengthening Institutions Program.
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“Methodology for Calculating Allocations Under the American Rescue Plan Act of 2021 (Published July 29, 2021).”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-methodology-for-calculating-allocations-www-ed-gov-5559fd8ccb/
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Methodology for Calculating Allocations Under the American
Rescue Plan Act of 2021 pursuant to Section 314(a)(2) of the
Coronavirus Response and Relief Supplemental Appropriations
Act, 2021
Published July 29, 2021
Of the funds available for the Higher Education Emergency Relief Fund (HEERF) under the
American Rescue Plan (ARP) Act (Pub. L. 117-2), 7.5 percent ($2.97 billion) is allocated
pursuant to section 314(a)(2) of the Coronavirus Response and Relief Supplemental
Appropriations Act, 2021 (CRRSAA) 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). As under CRRSAA, these ARP funds must be allocated across these
programs proportionally based on the relative share of funding 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 below.
Allocation Methodology
Strengthening HBCUs and HBCU Masters Programs
Section 314(a)(2)(A) of CRRSAA established a new formula for distribution of funds to
institutions eligible under the Strengthening Historically Black Colleges and Universities
(HBCUs) program authorized by part B of title III of the HEA and the HBCU Masters program
authorized by subpart 4 of part A of title VII of the HEA. Section 2003(3) of the ARP amended
the formula described in 314(a)(2)(A)(iii) to stipulate that any HBCU “that has a total
endowment size of less than $1,000,000 (including an institution that does not have an
endowment) shall be treated by the Secretary as having a total endowment size of $1,000,000.”
For each of these two funding streams (the $1.27 billion provided for the Strengthening HBCUs
program and the $38.9 million provided for the HBCU Masters program), the formula distributes
70 percent of funding according to each institution’s relative share of Pell Grant recipients in
attendance at the end of the school preceding the beginning of the most recent fiscal year, 20
percent according to each institution’s relative share of total students enrolled at the end of that
school year, and 10 percent according to an endowment factor using a ratio of the total sum of
HBCU endowments to each institution’s endowment. The Department used the data HBCUs
reported for CRRSAA to calculate allocations.
In accordance with 2003(3) of the ARP, and consistent with the approach the Department
adopted for HBCU allocations under CRRSAA 314(a)(2) through the final rule published April
22, 2021, the Department assigned an endowment value of $1,000,000 to any HBCU reporting
an endowment value of less than $1,000,000. The Department then generated ratios for each
eligible institution equivalent to the sum of all HBCU endowments divided by each institution’s
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endowment value. Then the Department calculated each HBCU’s share of the sum of these
endowment ratios. This share was then multiplied by the total amount allocated to this factor.
HBGIs
As provided under CRRSAA section 314(a)(2)(B), to calculate awards for Historically Black
Graduate Institutions (HBGIs) identified in section 326 of the HEA, the Department calculated
each institution’s total share of funding provided to HBGIs in the Further Consolidated
Appropriations Act, 2020, and applied that percentage to the amount of funding allocated to the
HBGI program under CRRSAA section 314(a)(2) as modified by section 2003(2) of the ARP
($328.3 million) to determine each institution’s HBGI award.
TCCUs
As provided in section 314(a)(2)(C) of CRRSAA, the Department used the formula described in
section 316(d)(3) of the HEA to calculate awards for eligible institutions under the American
Indian Tribally Controlled Colleges and Universities (TCCU) program. The Department used
data reported by TCCUs to calculate these allocations – the same data used to calculate their
awards under CRRSAA.
MSI/SIP
For the other seven programs funded under ARP pursuant to section 314(a)(2) of CRRSAA, the
statute directs the Department to use the allocation formula in section 314(a)(1) of the CRRSAA.
This formula methodology is described in detail here. The formula was applied separately to
each of the amounts provided for the seven programs (shown in the chart below) to determine
allocations for each eligible grantee. Institutions that receive allocations under more than one of
these programs will receive a total award that aggregates the amounts the institution is to receive
from each program. As under the Department’s methodology under section 18004(a)(2) of the
CARES Act and section 314(a)(2) of CRRSAA, the Strengthening Institutions Program (SIP)
formula awards are reserved for institutions that are eligible only for SIP. Please see the chart
below for a more detailed explanation.
Eligibility Rules
Eligibility rules for each of the 11 programs are described below:
• HBCUs: For the three 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 and that do not receive their own direct
appropriation under ARP. The allocations based on the formulas described in sections
314(a)(2)(A) and 314(a)(2)(B) of CRRSAA are combined into a single grant. The grant
amounts awarded to institutions that meet the requirements for these 3 programs do not
include amounts from any of the other eight grant programs discussed in the other bulleted
paragraphs.
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• TCCUs: As directed in section 314(a)(2)(C) of CRRSAA, for the program that supports
American Indian Tribally Controlled Colleges and Universities (TCCUs) (the blue row in the
chart below), the Department distributed funding to institutions based on the formula
described in section 316(d)(3) of the HEA. Section 314(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 six 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 2021. The Eligibility Matrix identifies institutions
that have been designated for Fiscal Year (FY) 2021 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 314(a)(2) grant
amounts awarded to institutions that meet the requirements for these six programs do not
include amounts from any of the other five 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 2021 under the titles III and V grant programs under the HEA and
that did not receive any section 314(a)(2) funding through any of the other 10 grant programs
discussed in the other bulleted paragraphs.
Data Notes
As with the HEERF grant program authorized under the CARES Act and CRRSAA, and with the
funds provided to all IHEs under section 2003 of the ARP pursuant to section 314(a)(1) of the
CRRSAA, awards allocated under section 314(a)(2) are generally calculated at the 6-digit
OPEID level. Therefore, branch campus enrollment is reflected in the awards of eligible parent
institutions. However, these allocations also include awards for the MSIs and SIP institutions
that are branch campuses whose parent institutions are not eligible for section 314(a)(2) funding
and that submitted the requisite data to receive awards under the funds reserved under section
18004(a)(2) of the CARES Act. The Department did not reserve section 314(a)(2) funds under
the MSI and SIP formulas. Please note that the ARP provides an additional $197.9 million to be
allocated pursuant to section 314(a)(3) of the CRRSAA -- for institutions of higher education
that the Secretary determines have, after allocating other funds available under the other sections
of 2003 of the ARP, the greatest unmet needs related to coronavirus. This will include eligible
MSI and SIP branch campuses that did not, nor did their parent institutions, otherwise receive an
allocation under section 314(a)(2) of the CRRSAA.
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Program 2003(2) Eligibility Criteria 1
Funding Level
Strengthening Historically Black $1,270 million “Part B” institutions as described in section 322(2) of the HEA, excluding institutions receiving
Colleges and Universities their own direct appropriation under ARP
(Strengthening HBCUs) Program
Master's Degree Programs at $38.9 million Institutions named in section 723(b)(1) of the HEA
Historically Black Colleges and
Universities (HBCU Master’s) Program
Strengthening Historically Black $328.3 million Institutions named in section 326(e)(1) of the HEA
Graduate Institutions (HBGIs) Program
American Indian Tribally Controlled $143.2 million Institutions that qualify for funding under the Tribally Controlled College or University Assistance
Colleges and Universities (TCCUs) Act of 1978 or the Navajo Community College Assistance Act of 1978; are cited in section 532 of
Program the Equity in Educational Land Grant Status Act of 1994; or are designated as eligible for funding
by the Bureau of Indian Education
Predominantly Black Institutions (PBIs) $51.6 million Institutions designated as eligible in FY 2021 for titles III and V programs and that have enrollment
Program - Formula Grants of undergraduate students that is at least 40 percent black American, and that have at least 1,000
undergraduate students
Alaska Native and Native Hawaiian $71.6 million Institutions designated as eligible in FY 2021 for titles III and V programs and that have enrollment
Serving Institutions (ANNH) Program of undergraduate students that is at least 20% Alaska Native or 10% Native Hawaiian students
Asian American- and Pacific Islander- $17.4 million Institutions designated as eligible in FY 2021 for titles III and V programs and that have an
serving Institutions (AANAPISI) enrollment of undergraduate students that is at least 10% Asian American and Native American
Program Pacific Islander
Native American-Serving Nontribal $17.4 million Institutions designated as eligible in FY 2021 for titles III and V programs and that have an
Institutions (NASNTI) Program enrollment of undergraduate students that is at least 10% Native American
Developing Hispanic-Serving $559.3 million Institutions that have been designated as eligible in FY 2021 for titles III and V programs and that
Institutions (DHSI) Program have an enrollment of undergraduate students that is at least 25% Hispanic
Promoting Postbaccalaureate $50.2 million Institutions designated as eligible in FY 2021 for titles III and V programs and that have an
Opportunities for Hispanic Americans enrollment of undergraduate students that is at least 25% Hispanic and that offer a
(PPOHA) Program postbaccalaureate program
Strengthening Institutions Program $421.6 million Institutions designated as eligible in FY 2021 for titles III and V programs and that did not receive
(SIP) 314(a)(2) grant awards as a result of not meeting the requirements for the Strengthening HBCUs,
HBGIs, HBCU Master’s, TCCUs, PBIs, ANNH, AANAPISI, NASNTI, DHSI, and/or PPOHA programs
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Any reference to requirements established in specific HEA programs do not include those programs’ concurrent funding limits or waiting period requirements, which are
generally not being applied for the purposes of the section 314(a)(2) grant awards.
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