Methodology for Calculating Allocations Under Section 314(a)(4)
Summary
This is a document titled Methodology for Calculating Allocations Under Section 314(a)(4) of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021, published January 14, 2021. It states that, of the Higher Education Emergency Relief Fund (HEERF) funds under the Act, 3% ($680,914,080) will be awarded to proprietary institutions of higher education based on three formula factors weighted 75%, 23%, and 2%. It explains that the first and third factors concern enrollment of Federal Pell Grant recipients and the second concerns students who were not Federal Pell Grant recipients, with each split evenly between total enrollment and full time equivalent (FTE) enrollment. It says the Department approximated the factors using IPEDS and Federal Student Aid Pell Grant data for the 2018/19 award year, and that no reserve is being withheld under Section 314(a)(4).
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“Methodology for Calculating Allocations Under Section 314(a)(4).”
Original at www.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/department-of-education-methodology-for-calculating-allocations-www-ed-gov-9764620ce0/
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Methodology for Calculating Allocations Under Section 314(a)(4)
Coronavirus Response and Relief Supplemental Appropriations Act, 2021
Published January 14, 2021
Of the funds available for the Higher Education Emergency Relief Fund (HEERF) under the Coronavirus
Response and Relief Supplemental Appropriations Act (Pub. L. 116-260) (CRRSAA), 3%
($680,914,080) of the funds will be awarded to proprietary institutions of higher education (IHEs), as
defined in sections 102(b) of the Higher Education Act of 1965, as amended (HEA), based on three
formula factors:
(1) 75% of the funds will be awarded to IHEs based on each IHE’s relative share of enrollment of
Federal Pell Grant recipients who were not enrolled exclusively in distance education courses
prior to the coronavirus emergency, split evenly between total (i.e., headcount) enrollment and
full time equivalent (FTE) enrollment;
(2) 23% of the funds will be awarded to IHEs based on each IHE’s relative share of enrollment of
students who were not Federal Pell Grant recipients and who were not enrolled exclusively in
distance education courses prior to the coronavirus emergency, split evenly between total
enrollment and FTE enrollment; and
(3) 2% of the funds will be awarded to IHEs based on each IHE’s relative share of enrollment of
Federal Pell Grant recipients who were enrolled exclusively in distance education courses prior to
the coronavirus emergency, split evenly between total enrollment and FTE enrollment.
The first and third factors primarily allocate funds based on undergraduate enrollment since Federal Pell
Grant eligibility is limited to undergraduate students who have not earned a baccalaureate degree or a first
professional degree, as well as students in certain postbaccalaureate teacher education programs. The first
factor only includes enrollment of students NOT exclusively enrolled in distance education courses prior
to the qualifying emergency while the third factor ONLY includes enrollment of students exclusively
enrolled in distance education courses prior to the qualifying emergency. The second factor allocates
funds based on undergraduate and graduate enrollment, excluding any students enrolled exclusively in
distance education courses prior to the qualifying emergency.
Because of the limitations of available data preclude calculating current amounts for the factors listed
above, the U.S. Department of Education (the Department) approximated the factors using the best
available data from ED’s Integrated Postsecondary Education Data System (IPEDS) and Pell Grant
Volume data provided by the Office of Federal Student Aid (FSA).
The first factor was determined as follows. The relative share of undergraduate students awarded Federal
Pell Grants as reported in IPEDS for the 2018/19 award year was adjusted based on the institution’s share
of total Federal Pell Grant recipients as reported by FSA for the 2018/19 award year. The FTE
enrollment of these Federal Pell Grant recipients was approximated by looking at the ratio in IPEDS
between 2018/19 FTE undergraduate enrollment and 2018/19 undergraduate total enrollment. To
approximate total and FTE enrollment of Federal Pell Grant recipients who were not enrolled exclusively
in distance education, the estimated total and FTE enrollment of Federal Pell Grant recipients was
1
multiplied by the percentage of fall 20181 undergraduate degree/certificate-seeking students not enrolled
exclusively in distance education as reported in IPEDS. The first factor was weighted evenly between
total enrollment and FTE enrollment
The second factor was determined by subtracting the approximated total and FTE enrollment of Federal
Pell Grant recipients (if any) from the total 2018/19 total and FTE enrollment of students as reported in
IPEDS and then multiplying the difference by the percentage of fall 2018 undergraduate, graduate, and
professional students not enrolled exclusively in distance education as reported in IPEDS. Each
institution’s relative share of the resulting enrollment was used to calculate their share of the second
factor. The second factor was weighted evenly between total enrollment and FTE enrollment.
The third factor was determined as follows. The relative share of undergraduate students awarded Federal
Pell Grants as reported in IPEDS for the 2018/19 award year was adjusted based on the institution’s share
of total Federal Pell Grant recipients as reported by FSA for the 2018/19 award year. The FTE
enrollment of these Federal Pell Grant recipients was approximated by looking at the ratio in IPEDS
between 2018/19 FTE undergraduate enrollment and 2018/19 undergraduate total enrollment. To
approximate total and FTE enrollment of Federal Pell Grant recipients who were enrolled exclusively in
distance education, the estimated total and FTE enrollment of Federal Pell Grant recipients was multiplied
by the percentage of fall 2018 undergraduate degree/certificate-seeking students enrolled exclusively in
distance education as reported in IPEDS. The third factor was weighted evenly between total enrollment
and FTE enrollment.
The Department notes that, unlike the initial Section 18004(a)(1) allocation for the CARES Act, no
reserve is being withheld under Section 314(a)(4).
Some additional points to note:
The data used to determine distance education participation are based on a fall unduplicated
enrollment which is different from FTE enrollment and, in the case of the total FTE enrollment,
also different from FTE enrollment for a 12-month period. The unduplicated enrollment is a
simple headcount of students enrolled in classes; whereas the FTE enrollment counts part-time
students in accordance with their enrollment rate.
Allocation amounts were calculated at the 6-digit OPEID.
Some data was adjusted based on available information regarding change of ownership or
affiliation.
For some IHEs, the approximated FTE enrollment of Federal Pell Grant recipients exceeded the
total FTE enrollment. For these IHEs, the total non-Pell FTE enrollment was set to 0, making the
IHE ineligible for the second factor.
The ratio of FTE undergraduate enrollment to undergraduate headcount enrollment was capped at
100 percent.
Schools that are currently ineligible or for whom IPEDS data was unavailable are excluded from
the allocation table.
There may be some currently participating and eligible schools which may be excluded from this
formula, in particular schools that recently gained eligibility and did not participate in Title IV
during the 2018/19 award year.
1
While IPEDS data is available for 2018/19 headcount enrollment, FTE enrollment, and student financial aid
recipients, fall 2019 enrollment data is not expected to be available until February 2020. As a result, the most recent
IPEDS fall enrollment data available (which is used to determine exclusive enrollment in distance education
courses) is fall 2018 enrollment data.
2
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