American Council on Education, Association for Public & Land-Grant Universities Estimate New HEERF Allocations

By Rachel Gentry, NASFAA Policy & Federal Relations Staff

Two higher education groups, the American Council on Education (ACE) and the Association for Public & Land-Grant Universities (APLU), have simulated the distribution of the new Higher Education Emergency Relief Fund (HEERF) dollars and published estimated allocation amounts that institutions may receive from the $20.2 billion pot of funds set aside for public and private nonprofit institutions in recent legislation. 

Following months of negotiations, Congress passed and President Donald Trump signed into law in December the Consolidated Appropriations Act, 2021, a massive package of legislation that included fiscal year (FY) 2021 funding, additional pandemic relief, and a number of higher education-related policy changes. Included in the FY 2021 omnibus was the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act, which provided $22.7 billion to the HEERF established in the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The bill sets aside 89% of the higher education funds, or $20.2 billion, for public and private nonprofit institutions. 

ACE and APLU’s simulations estimate the distribution of $20.2 billion in relief funding among approximately 3,500 public and private, not-for-profit colleges and universities. Neither simulation includes estimates of the funds institutions may receive from the bill’s other pots of higher education funding, such as the $1.7 billion for minority-serving institutions (MSIs), the $113.5 million for institutions with the greatest unmet need related to the pandemic, and the $681 million for proprietary institutions. 

ACE’s simulated distribution includes estimates, organized alphabetically by state, of the total allocation institutions may expect to receive from the new HEERF funds, as well as estimates of the minimum amount institutions may be required to spend on student grants. 

APLU’s interactive tool also provides estimates of the total HEERF allocations that institutions may receive, and allows users to search and filter by state, institution name, and congressional district.

The two simulations used the same methodology to calculate the allocations, resulting in nearly identical estimates. The only difference between the methodology used in each simulation, and cause of any variation between the results, is that APLU's tool does not include allocations for approximately 50 exclusively-online institutions that were ineligible for CARES Act funds, while ACE's simulation does include estimates for these online-only schools. The exclusion of these schools from APLU's simulation is not expected to have a substantial impact on the institutional estimates included in the tool, and estimated allocations for online-only institutions can be found in ACE's distribution.

Importantly, the allocations included in both simulations are only estimates, and final allocation amounts have not yet been determined by the Department of Education (ED). While the methodology used in these analyses was largely modeled after the methodology used by ED to determine CARES Act allocations, it is not known if ED will use this methodology or a different one to distribute the new HEERF dollars. ACE and APLU’s estimates are meant to provide institutions with a ballpark sense of how much they may receive from the new HEERF funds. ED’s methodology, and consequently the final amounts received by individual institutions, may differ from these simulations. These estimates should be used for general planning purposes only, and NASFAA will publish additional information on the final HEERF allocations as it becomes available.

As a reminder, the CRRSA allocation formula differs from that of the CARES Act, which used only full-time equivalent (FTE) enrollment, whereas the new formula also takes into account student headcount. The $20 billion for public and private nonprofit institutions, or 89% of the total higher education funds, is allocated using the following formula:

  • 37.5% on FTE enrollment of Pell Grant recipients who were not enrolled exclusively in distance education courses prior to the qualifying emergency 
  • 37.5% on headcount enrollment of Pell Grant recipients who were not enrolled exclusively in distance education courses prior to the qualifying emergency 
  • 11.5% on FTE enrollment of non-Pell Grant recipients who were not enrolled exclusively in distance education courses prior to the qualifying emergency
  • 11.5% on headcount enrollment of non-Pell Grant recipients who were not enrolled exclusively in distance education courses prior to the qualifying emergency; 
  • 1% based on FTE enrollment of Pell Grant recipients who were exclusively enrolled in distance education course prior to the qualifying emergency
  • 1% based on headcount of Pell Grant recipients who were exclusively enrolled in distance education courses prior to the qualifying emergency

Unlike the CARES Act, the CRRSA does not require that 50% of an institution’s funds be spent on student grants. It does, however, require that institutions spend the same dollar amount on student grants as they were required to spend under the CARES Act. The allowable uses for the new funds are more flexible than in the CARES Act, with institutions permitted to use their funds to defray expenses associated with COVID-19, including lost revenue, reimbursements for expenses already incurred, technology costs associated with the transition to distance education, faculty and staff training, and payroll. Institutions may also use their funds to carry out student support activities authorized by the Higher Education Act (HEA), or to provide emergency grants to students (including those enrolled exclusively in distance education). Student grants may be used to cover any component of a student’s cost of attendance (COA), or for emergency costs that arise due to COVID-19, including tuition, food, housing, health care and child care. Notably, the bill includes no student eligibility requirements, however, institutions are required to prioritize grants to students with exceptional financial need, such as those who receive Pell Grants.

NASFAA expects ED to release more information about the distribution of the additional HEERF funds in the near future. Stay tuned to Today’s News and NASFAA’s Consolidated Appropriations Act, 2021 web center and COVID-19 Web Center for updates and developments on the status of the omnibus spending bill and pandemic relief funds. If you have questions about the provisions included in the FY 2021 omnibus, please contact us at policy@nasfaa.org.

 

Publication Date: 1/8/2021


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