Ppr Int Aa94C010F30A2510 Frequently Asked Questions About The Emergency Financial Aid To S - Ppr Int Aa94C010F30A2510 Frequently Asked.

Summary

Frequently asked questions on the emergency financial aid grants to students under Section 18004 of the CARES Act, part of the Higher Education Emergency Relief Fund, which directs institutions to use no less than 50 percent of the funds received under Sections 18004(a)(1) and 18004(c) for such grants. The 13 answers say institutions may not reimburse themselves from these funds for refunds, laptops or campus wages, may not use them to pay a student’s outstanding balance, and may reimburse only their own emergency grants made on or after March 27, 2020 that meet the Act’s terms. Only students who are or could be eligible for programs under Section 484 of the Higher Education Act may receive grants, and, at institutions offering both online and ground-based education, students enrolled exclusively online on March 13, 2020 are not eligible. Grants must reach students unencumbered.

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                           Higher Education Emergency Relief Fund
  Frequently Asked Questions about the Emergency Financial Aid Grants to Students
under Section 18004 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act

The CARES Act, which establishes and funds the Higher Education Emergency Relief Fund
(HEERF), directs institutions of higher education (“institutions”) to use no less than 50 percent of
funds received under Sections 18004(a)(1) and 18004(c) of the CARES Act to provide emergency
financial aid grants to students for expenses related to the disruption of campus operations due to
coronavirus. These FAQs address only those funds provided by the Secretary to an institution for
emergency financial aid grants to students under Sections 18004(a)(1) and 18004(c) of the CARES
Act.
1)     Can institutions that have provided refunds to students for room and board, tuition,
       and other fees (such as activities fees) reimburse themselves from the funds for the
       emergency financial aid grants to students?
       No. The CARES Act requires institutions to use no less than 50 percent of HEERF funds
       received under Sections 18004(a)(1) and 18004(c) of the CARES Act to provide
       emergency financial aid grants to students. These funds distributed by the Department
       represent the 50 percent minimum of each institution’s HEERF funds under Section
       18004(a)(1) of the CARES Act for these emergency financial aid grants to students.
       Section 2 of the Funding Certification and Agreement for the Emergency Financial Aid
       Grants to Students states: “Recipient shall not use [these] funds to reimburse itself for any
       costs or expenses, including but not limited to any costs associated with significant changes
       to the delivery of instruction due to the coronavirus and/or any refunds or other benefits
       that Recipient previously issued to students.”
       Institutions will have more flexibility in the use of the portion of the HEERF that is made
       available to cover an institution’s costs associated with significant changes to the delivery
       of instruction due to the coronavirus. The Department will provide a Frequently Asked
       Questions (FAQ) document regarding the allowable uses of funds for an institution’s costs
       shortly after making those funds available to institutions.


2)     Can institutions that have provided information technology hardware (such as
       laptops, hotspot internet devices, etc.) and other related equipment to students
       reimburse themselves from the funds for the emergency financial aid grants to
       students?
       No. The CARES Act requires institutions to provide the emergency financial aid grants to
       students. Section 2 of the Funding Certification and Agreement for the Emergency
       Financial Aid Grants to Students states: “Recipient shall not use [these] funds to reimburse
       itself for any costs or expenses, including but not limited to any costs associated with
       significant changes to the delivery of instruction due to the coronavirus and/or any refunds
       or other benefits that Recipient previously issued to students.”

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     Institutions will have more flexibility in the use of the portion of the HEERF that is made
     available to cover an institution’s costs associated with significant changes to the delivery
     of instruction due to the coronavirus. The Department will provide a FAQ document
     regarding the allowable uses of funds for an institution’s costs shortly after making those
     funds available to institutions.


3)   Can institutions that have provided institutionally-funded emergency grants to
     students as a result of COVID-19 reimburse themselves from the funds for the
     emergency financial aid grants to students?
     The only institutionally-funded emergency grants to students that are eligible for
     reimbursement from the funds for emergency financial aid grants to students under the
     CARES Act are grants: 1) for authorized expenses related to the disruption of campus
     operations due to coronavirus as set forth in Section 18004(c) of the CARES Act; 2) made
     to students eligible to receive emergency financial aid grants under the CARES Act; and
     3) made on or after March 27, 2020, the date the CARES Act was enacted. An institution
     must use no less than 50 percent of funds provided pursuant to Sections 18004(a)(1) and
     18004(c) for emergency financial aid grants to students. An institution must document that
     reimbursements for institutionally-funded emergency grants to students are made in
     accordance with the CARES Act.


4)   Can institutions that have continued to pay student workers from institutional funds
     for campus jobs reimburse themselves from the funds for the emergency financial aid
     grants to students?
     No. The CARES Act requires institutions to provide the emergency financial aid grants to
     students, and institutions may not use that portion of the HEERF set aside for emergency
     financial aid grants to students for this purpose. The Department notes that Congress has
     provided additional flexibility to institutions relating to the Federal Work-Study (FWS)
     Program, including that institutions may continue to pay FWS wages to students for the
     remainder of the current academic year in instances in which those students’ jobs were
     interrupted as a result of the national emergency due to the coronavirus, as long as those
     students had started employment prior to this national emergency. The CARES Act also
     waives the non-federal wage match requirement for institutional and non-profit employers
     of FWS students. Please see the Department’s Guidance for Interruptions of Study Related
     to Coronavirus, which provides additional information about the FWS Program.
     The Department will provide a FAQ document regarding the allowable uses of funds for
     an institution’s costs associated with significant changes to the delivery of instruction due
     to the coronavirus shortly after making those funds available to institutions.




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5)   Can institutions use the funds for the emergency financial aid grants to students to
     pay outstanding or overdue student bills to institutions?
     No. The CARES Act requires institutions to provide the emergency financial aid grants to
     students. The institution may not use that portion of the HEERF set aside for emergency
     financial aid grants to students to satisfy a student’s outstanding account balance. The
     Department notes that the student may use his or her emergency financial aid grant for
     expenses related to the disruption of campus operations due to coronavirus.


6)   What data will the Department require institutions to report after disbursement of
     emergency financial aid grants to students?
     As explained in the Funding Certification and Agreement for the Emergency Financial Aid
     Grants to Students, each institution will report to the Secretary the following: how grants
     were distributed to students, how the amount of each grant was calculated, and any
     instructions or directions that the institution gave to students about the grant. Institutions
     must also comply with the reporting requirements under Section 15011 of the CARES Act.
     The Department will publish a notice in the Federal Register to provide instructions to
     institutions on these reporting requirements.


7)   What obligation does an institution have to continue to pay all its employees after
     accepting the funds for the emergency financial aid grants to students?
     The CARES Act requires each institution that accepts funds from the HEERF, including
     funds used to pay emergency financial aid grants, to continue to pay employees and
     contractors to the greatest extent practicable based on the unique financial circumstances
     of each institution; however, institutions may not use emergency financial aid grants to
     students to pay employees and contractors.


8)   Are incarcerated students participating in the Second Chance Pell Experimental Site
     Initiative (ESI) eligible for emergency financial aid grants to students?
     The CARES Act expressly requires that institutions provide the emergency financial aid
     grants to students “for expenses related to the disruption of campus operations due to
     coronavirus (including eligible expenses under a student’s cost of attendance, such as food,
     housing, course materials, technology, health care, and childcare).” If an incarcerated
     individual who is participating in the Second Chance Pell experiment is released from
     incarceration as a result of the national emergency due to the coronavirus, remains enrolled
     as a student in the program under the Second Chance Pell experiment, and has such
     expenses, he or she likely qualifies for an emergency financial aid grant. A person who
     remains incarcerated is unlikely to incur these expenses and would thus be ineligible.
     Accordingly, for students participating in the Second Chance Pell ESI, institutions will
     need to review on a case-by-case basis what, if any, expenses an incarcerated person, or a
     formerly incarcerated person released due to the coronavirus, has incurred due to the
     disruption of campus operations.
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9)    What students are eligible to receive emergency financial aid grants from the
      HEERF?

      Only students who are or could be eligible to participate in programs under Section 484 in
      Title IV of the Higher Education Act of 1965, as amended (HEA), may receive emergency
      financial aid grants. If a student has filed a Free Application for Federal Student Aid
      (FAFSA), then the student has demonstrated eligibility to participate in programs under
      Section 484 the HEA. Students who have not filed a FAFSA but who are eligible to file a
      FAFSA also may receive emergency financial aid grants. The criteria to participate in
      programs under Section 484 of the HEA include but are not limited to the following: U.S.
      citizenship or eligible noncitizen; a valid Social Security number; registration with
      Selective Service (if the student is male); and a high school diploma, GED, or completion
      of high school in an approved homeschool setting.


10)   Will funds provided through the CARES Act be included in an institution’s 90/10
      calculation?

      Funds paid directly to institutions by the Department through the HEERF will not be
      included as revenue for 90/10 purposes.


11)   How must institutions pay the emergency financial aid grants to students?

      Institutions may provide emergency financial aid grants to students using checks,
      electronic transfer payments, debit cards, and payment apps that adhere to the
      Department’s requirements for paying credit balances to students. The disbursement of the
      emergency financial aid grant to the student must remain unencumbered by the institution;
      debts, charges, fees, or other amounts owed to the institution may not be deducted from the
      emergency financial aid grant. The emergency financial aid grant may not be made to
      students through the use of a credit card that can be used only on campus or in a retail outlet
      affiliated with the institution.


12)   At institutions that provide both online and ground-based education, are students
      who were enrolled exclusively in online programs prior to the national emergency due
      to the coronavirus eligible to receive emergency financial aid grants?
      At institutions that provide both online and ground-based education, those students who
      were enrolled exclusively in an online program on March 13, 2020, the date of the
      President’s Proclamation, “Declaring a National Emergency Concerning the Novel
      Coronavirus Disease (COVID-19) Outbreak,” Federal Register Vol. 85, No. 53 at 15337-
      38, are not eligible for emergency financial aid grants. The formula provided by Congress
      for calculating the distribution of funds to institutions excludes students who were
      exclusively enrolled in distance education courses. Additionally, the emergency financial

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      aid grants to students are for expenses related to the disruption of campus operations due
      to coronavirus, and students who were enrolled exclusively in online programs would not
      have expenses related to the disruption of campus operations due to coronavirus.


13)   Where can institutions locate additional resources and information related to
      emergency financial aid grants to students?

      CARES Act grant resources and guidance are located on the Office of Postsecondary
      Education’s webpage: https://www2.ed.gov/about/offices/list/ope/caresact.html.




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