On Tuesday, the Department of Education (ED) released new guidance on the third round of Higher Education Emergency Relief Fund (HEERF) grants authorized by the American Rescue Plan. The department also released institutional allocations for HEERF III grants to public and nonprofit institutions, as well as proprietary institutions.
In this latest guidance, the department provided additional ways in which institutions can utilize the recently enacted $36 billion in emergency grants to support vulnerable students, monitor and suppress the coronavirus, and re-engage students whose education was disrupted by the pandemic. In a shift from the previous administration, the guidance, including a new final rule on student eligibility, also allows undocumented students, those enrolled in the Deferred Action for Childhood Arrivals (DACA) program, and international students to access the emergency grants.
"Denying emergency grants to DACA and undocumented students wasn't just legally questionable, it was a moral failing," said NASFAA President Justin Draeger. "I'm relieved and thankful to see that corrected today."
The final rule now defines student eligibility for the grants as "any individual who is or was enrolled at an eligible institution on or after March 13, 2020, the date of declaration of the national emergency due to the coronavirus." Therefore, it is no longer required that students be (or could be) Title IV-eligible, as they were for funds issued through the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Newly published FAQs answer the question on whether emergency grants can be used for DACA, undocumented, and international students plainly, stating:
"The Department's final rule on student eligibility for HEERF states that all students who are or were enrolled in an institution of higher education during the COVID-19 national emergency are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. That includes citizens, permanent residents, refugees, asylum seekers, Deferred Action for Childhood Arrival (DACA) recipients, other DREAMers, and similar undocumented students.
International students may also receive HEERF. However, as noted in Questions 11 and 12, institutions must ensure that funds go to students who have exceptional need. The Department encourages institutions to prioritize domestic students, especially undergraduates, in allocating this funding. This includes citizens, permanent residents, refugees, asylum seekers, DACA recipients, other DREAMers, and similar undocumented students."
The guidance highlights ways in which institutions can spend their student and institutional allocations, and reiterates that schools may not use HEERF grant funds to advertise or recruit students by promoting the opportunity to receive a student emergency financial aid grant, nor may schools include HEERF grants in their financial aid packaging, as they are not considered financial aid.
Of particular note for financial aid offices, the new FAQs also define the direct outreach required by aid offices to notify students about the opportunity for adjustments via Professional Judgment due to unemployment or other circumstances. "Direct outreach" requires an institution to actively engage aid applicants, and should be more than a "passive notification," according to ED.
NASFAA has begun analyzing the new guidance, along with the final rule, and updating its COVID-19 Web Center and AskRegs Knowledgebase, and publishing new guidance in Today's News over the coming days. In addition, join the NASFAA staff for a webinar reviewing this new guidance on Friday, May 21.
"With this action, thousands of institutions will be able to provide direct relief to students who need it most, so we can make sure that we not only recover from the pandemic, but also build back even stronger than before," said Education Secretary Miguel Cardona.
ED aims for the additional guidance to help better target resources to all students with exceptional financial need and signify a broader commitment to providing support, resources, and guidance to institutions, students, and communities throughout the pandemic.
For more details on HEERF guidance visit NASFAA's COVID-19 Web Center and follow our Higher Education Emergency Relief Fund (HEERF) Reference Pages.
Publication Date: 5/11/2021