Methodology for Calculating Allocations Under Section 314(a)(2)
Summary
Department of Education methodology for allocating Higher Education Emergency Relief Fund money under section 314(a)(2) of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021, published February 25, 2021 and updated July 27, 2021. It sets aside 7.5 percent, or $1.70 billion, for institutions in named Higher Education Act programs, divided by each program's share of fiscal year 2020 funding. For the Strengthening HBCUs stream of $727.9 million and the HBCU Masters stream of $22.3 million, 70 percent is distributed by Pell Grant recipients and 10 percent by endowment ratios, with a minimum endowment value of $1,000,000 used after rulemaking for institutions reporting less. Historically Black Graduate Institutions share $188.2 million, and the Strengthening Institutions Program is listed at $241.7 million.
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“Methodology for Calculating Allocations Under Section 314(a)(2).”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-methodology-for-calculating-allocations-www-ed-gov-85044a7285/
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Methodology for Calculating Allocations Under Section 314(a)(2)
Coronavirus Response and Relief Supplemental Appropriations Act, 2021
Published February 25, 2021
Updated July 27, 2021
Of the funds available under the Coronavirus Response and Relief Supplemental Appropriations
Act, 2021 (CRRSAA) for the Higher Education Emergency Relief Fund (HEERF), 7.5 percent
($1.70 billion) is allocated under section 314(a)(2) 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 CRRSAA further stipulates that the $1.70
billion 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) establishes 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. For each of the two funding streams (the $727.9
million provided for the Strengthening HBCUs program and the $22.3 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 data collected from HBCUs to calculate these allocations. The Department
initially delayed award of the 10 percent of funds to be allocated based on endowment values to
allow for time to conduct rulemaking to finalize implementation of this formula factor. The
rulemaking was necessary, in part, because several institutions reported an endowment of $0,
which generates an undefined ratio for them when taking the sum of the endowment values
divided by each institution’s endowment value. Pursuant to this final rule, and consistent with
the approach Congress adopted in the American Rescue Plan, the Department set a minimum
endowment value of $1,000,000 and used that value for any institution that reported a lower
endowment. The Department then generated ratios for each eligible institution equivalent to the
sum of all HBCU endowment values divided by each institution’s 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.
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HBGIs
As provided under 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 section 314(a)(2)
funding allocated to the HBGI program ($188.2 million) to determine each institution’s HBGI
award.
TCCUs
As provided in section 314(a)(2)(C), 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.
MSI/SIP
For the other seven programs funded under section 314(a)(2) 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, the Strengthening
Institutions Program (SIP) formula awards are reserved for institutions that are eligible only for
SIP. Please see the chart below for more 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 CRSSAA. The allocations based on the formulas
described in sections 314(a)(2)(A) and 314(a)(2)(B) are combined into a single 314(a)(2)
grant. The section 314(a)(2) 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.
• TCCUs: As directed in section 314(a)(2)(C) of the 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
2
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 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 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 2020 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
The Department used the Fiscal Year (FY) 2020 Eligibility Matrix because the process for
designating eligible institutions for FY 2021 under the titles III and V programs will not be
completed until April 2021. Institutions that do not receive funding under section 314(a)(2) but
that are designated as eligible institutions through the FY 2021 designation process will have the
opportunity to apply for funds under a forthcoming CRRSAA section 314(a)(3) funding
opportunity.
As with the HEERF grant program authorized under the CARES Act, and with the funds
provided under 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 section
314(a)(3) of the CRRSAA provides funding that shall be allocated to institutions of higher
education that the Secretary determines have, after allocating other funds available under section
314, the greatest unmet needs related to coronavirus. This will include eligible institutions that
did not otherwise receive an allocation under section 314(a)(2) of the CRRSAA.
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Program 314(a)(2) Eligibility Criteria 1
Funding Level
Strengthening Historically Black $727.9 million “Part B” institutions as described in section 322(2) of the HEA, excluding institutions receiving
Colleges and Universities their own direct appropriation under CRRSAA
(Strengthening HBCUs) Program
Master's Degree Programs at $22.3 million Institutions named in section 723(b)(1) of the HEA
Historically Black Colleges and
Universities (HBCU Master’s) Program
Strengthening Historically Black $188.2 million Institutions named in section 326(e)(1) of the HEA
Graduate Institutions (HBGIs) Program
American Indian Tribally Controlled $82.1 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) $29.6 million Institutions designated as eligible in FY 2020 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 $41.1 million Institutions designated as eligible in FY 2020 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- $10.0 million Institutions designated as eligible in FY 2020 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 $10.0 million Institutions designated as eligible in FY 2020 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 $320.7 million Institutions that have been designated as eligible in FY 2020 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 $28.8 million Institutions designated as eligible in FY 2020 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 $241.7 million Institutions designated as eligible in FY 2020 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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