Overview on the Higher Education Emergency Relief Fund under the American Rescue Plan Act of 2021 for Proprietary Institutions — Office of Postsecondary Education (May 2021)

Summary

Slide presentation dated May 2021 from the Office of Postsecondary Education (OPE): an overview of the Higher Education Emergency Relief Fund (HEERF) under the American Rescue Plan Act of 2021 for proprietary institutions. It describes the ARP as a $40 billion investment in higher education that provides close to $400 million to students enrolled at proprietary institutions. It says proprietary colleges must submit a new Proprietary Institution Certification Form, signed by the president or CEO and any owners with at least 25% ownership, before receiving an award, and email it by August 11. It says colleges may not condition emergency grants to students on continued enrollment or use them to pay a student's outstanding balance without consent, and that marketing and recruitment are impermissible uses of HEERF funds.

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  OFFICE OF POSTSECONDARY EDUCATION (OPE)
OVERVIEW ON THE HIGHER EDUCATION EMERGENCY RELIEF FUND UNDER THE AMERICAN RESCUE PLAN ACT OF 2021 FOR
                                      PROPRIETARY INSTITUTIONS

                                            MAY 2021
AGENDA
     Introductions
     About the American Rescue Plan Funding
     Equitable Eligibility – Students with Exceptional Needs
     Recovery
        – Emergency Financial Aid
        – Retention
     Transparency & Accountability
     Tools & Resources
     Discussion (Q&A)




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DISCLAIMER

    This document is being used in support of a live
    discussion. As such, it does not necessarily express
    the entirety of that discussion nor the relative
    emphasis of topics therein.
    Institutions are encouraged to carefully review the
    Department’s full guidance at the end of this
    presentation and on the ARP HEERF III website.




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AMERICAN RESCUE PLAN (ARP)
The ARP is a $40 billion investment in America’s institutions of higher
education – double the first two COVID recovery packages combined.
The total $76 billion investment helps:
 Mitigate the negative impact of the pandemic on students’ educational
   attainment.
 Target resources to students with greatest need.
 Support students’ ability to meet basic needs.
 Support for staffing, teaching, student support services, and
   educational programs/courses.
 Support campus safety measures and protocols.
 Comply with guidelines on allowable expenses and reporting
   requirements.


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AMERICAN RESCUE PLAN (ARP)

ARP is also one of the largest, single, investments ever made in
American higher education--for both students and institutions. It
provides resources for many of our nation's most under-resourced
institutions that educate the students most impacted by the
pandemic. These investments include:
 More than $10 billion to Community Colleges,
 More than $2.6 billion to Historically Black Colleges and Universities
  (HBCUs) and more than $6 billion to minority-serving institutions (MSIs),
 It also provides close to $400 million to students enrolled at
  proprietary institutions.




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OBLIGATING FUNDS
 We will supplement your existing awards: Proprietary colleges must
  first submit the HEERF required Proprietary Institution Certification
  Form. The Department will then make supplemental awards to your
  existing CRRSAA student portion grant.
 Applying for a new award: If you did not apply for CRRSAA you
  may apply for ARP funding via grants.gov.
 More than a year to spend: Once obligations are made, your college
  will have a full year to spend both your existing CRRSAA funds and
  new ARP funds. Colleges can also request a no-cost extension for an
  additional year (FAQ questions #39, 40, and 41).




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PRIORITIZING EXCEPTIONAL NEEDS
 All students, regardless of citizenship, qualify (our new eligibility rule
  can be found here)
 Colleges can use various ways to identify exceptional need, including:
     – Pell grant recipients,
     – Information on the FAFSA (FASFA is not required for HEERF funds), or
     – Alternative information, such as significant unexpected expenses either
       for themselves or their families, including the loss of employment, reduced
       income, or food or housing insecurity.
 An analysis by the Government Accountability Office found about 50
  percent of colleges in a sample did not report requiring a FAFSA.
 Colleges are expected to establish a transparent process for assessing
  need.
 See FAQ questions #7-9 for more information on eligibility and
  greatest need.

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EQUITABLE RECOVERY – EMERGENCY AID

     When making HEERF emergency financial grants to student’s
      colleges must not:
        – Condition the receipt of emergency financial aid grants to students
          on continued or future enrollment in the institution,
        – Use the emergency financial aid grants to satisfy a student’s
          outstanding account balance, unless it has obtained the student’s
          written (or electronic), affirmative consent, or
        – Require such consent as a condition of receipt of or eligibility for the
          emergency financial aid grant.
     See FAQ questions #7-19, 22, 27 for more information on
      emergency financial aid grants to students and marketing.




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EQUITABLE RECOVERY – EMERGENCY AID

     The Department may determine an institution has failed to
      prioritize students with exceptional need if the institution
      established preconditions for students to receive emergency
      financial aid grants, such as:
        – Establishing a minimum GPA,
        – Imposing other academic, athletic performance, or good standing
          requirements,
        – Requiring continued enrollment in the institution, or
        – Requiring the student to first pay any outstanding debt or balance.
     See FAQ questions #7-19 for more information on
      emergency financial aid grants to students.



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REMINDERS – STUDENT GRANTS

  Direct “marketing and recruitment” activities are an
   impermissible use of HEERF funds (see FAQ questions #22
   and 27).
  Institutions cannot include the amount of a HEERF student
   emergency financial aid grant in students’ financial aid
   award package (see FAQ question #17).




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TRANSPARENCY AND ACCOUNTABILITY
HEERF PROPRIETARY INSTITUTION CERTIFICATION FORM

   To assist with management and oversight of HEERF funds,
    proprietary colleges must complete a new Proprietary
    Institution Certification Form before receiving an obligation
    (i.e., either a supplemental award if the institution already
    has a CRRSAA a4 grant or a new award if applying for a4
    HEERF grant funds for the first time).
   The form must be signed by the institution’s President or CEO,
    and any owners with at least 25% ownership in the institution.
   Institutions must email the completed form by August 11 to the
    Department at HEERFARP4@ed.gov
   Also see FAQ questions #4 and 5.



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TRANSPARENCY AND ACCOUNTABILITY
HEERF PROPRIETARY INSTITUTION CERTIFICATION FORM

 What kinds of signatures for the form are acceptable?
  A classic “wet” signature, that is, someone prints off the form, signs
    it, scans it, and emails the Department.
  A picture signature (such as a JPG of their real signature imposed
    on the signature line).
  “signed certificate” e-signature done through Adobe.
 Please note the Department will not accept typed signatures for this
 form. The purpose of the form is to establish that the individual
 signing the document intended to be bound to the responsibilities and
 requirements described in the form.




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TRANSPARENCY AND ACCOUNTABILITY
HEERF PROPRIETARY INSTITUTION CERTIFICATION FORM

  What does “ownership” mean?
  As described in the form, we want first-line owners, or their
  authorized representatives (in the case of corporate entity
  ownership), with 25% or more ownership to sign. The form does
  not collect second or third (or deeper) line ownership, even if
  those lines of ownership ultimately lead to an induvial or entity
  that may, together, have 25% or more ownership.




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TRANSPARENCY AND ACCOUNTABILITY
REPORTING, AUDITS, FUND DECLINES

   Quarterly Reporting: Grantees receiving ARP funds must continue
    to adhere to the two quarterly reporting requirements originally
    implemented through the CARES Act. Next deadline to post
    quarterly reports is July 10 (FAQ #36).
   Annual Reporting: More information to follow, but we plan to
    have institutions report on calendar year 2021 early next year
    (FAQ #37).
   Voluntary Decline of HEERF Grant Funds: Any institution may
    voluntarily decline its full award or a portion of its award in the
    next three months so those funds can be redistributed by formula
    to institutions with greater need (FAQ #6).
   Audits (FAQ #38).
   Also see FAQ questions #49 and 50.


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RESOURCES

 HEERF Customer Care Center
   – Email: HEERF@ed.gov and Phone: 202-377-3711
 ARP home page
   – https://www2.ed.gov/about/offices/list/ope/arp.html
 ARP FAQs (issues on May 11, 2021)
   – https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf
 HEERF Grant Auditing Requirements (issued March 8, 2021)
   – https://www2.ed.gov/about/offices/list/ope/heerfauditlett
      er.pdf
 Proprietary Institution Certification Form
   – https://www2.ed.gov/about/offices/list/ope/arpproprieta
      rycerft.pdf
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RESOURCES

 Email addresses for HEERF documentation
    – HEERF Quarterly Reports: HEERFReporting@ed.gov
    – Voluntary Decline of HEERF Grant Funds:
      HEERFRefund@ed.gov
    – HEERF Proprietary Institution Certification Form:
      HEERFARP4@ed.gov
 Voluntary Decline Form
    – https://www2.ed.gov/about/offices/list/ope/arpheerfiiivol
      untarydecline.pdf




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