NASFAA Higher Education Emergency Relief Fund III (HEERF III) Reference Page

This page contains information related to the Higher Education Emergency Relief Funds III (HEERF III) created under the American Rescue Plan (ARP). Check back often as NASFAA will continue to update this reference page as any new guidance becomes available. Updates will be marked below in red . More information and resources on how the novel coronavirus is impacting student financial aid as well as information about the HEERF grants made available through the CARES Act in early March 2020 and the CRRSA Act in late December 2020, can be found on NASFAA's COVID-19 Web Center. NASFAA has also created a comparison chart that outlines the requirements and allowable uses for all three HEERF fund allocations.

Overview

The American Rescue Plan (ARP) included additional COVID-19 relief for institutions of higher education. This new COVID stimulus bill included $40 billion for higher education institutions and students, using the same Higher Education Emergency Relief Fund (HEERF) model established in the Coronavirus Aid, Relief and Economic Security (CARES) Act.

NASFAA has created a one-pager which summarizes reporting guidelines for all three HEERF (CARES, CRRSA, ARP) grants.

Allowable Uses

The ARP HEERF III funds require that 50% of an institution's funds be spent on student grants, with the exception of for-profit institutions, which must spend 100% of their funds on student grants. In addition, the allowable uses of funds are nearly identical to the CRRSA HEERF II funding as illustrated below.

Student Portion

Institutions may award student grants for:

• • Any component of their cost of attendance
  • Emergency costs that arise due to coronavirus, such as: tuition; food; housing; health care (including mental); child care

  Institutional Portion

  Institutions may use the grants toward:

  Defray expenses associated with coronavirus including:

  • • Lost revenue
    • Reimbursement for expenses already incurred
    • Technology costs associated with a transition to distance education
    • Faculty and staff trainings
    • Payroll
    • Make additional financial aid grants to students

    Institutions must use a portion of their allocation for:

    • • Implementing evidence-based practices to monitor and and suppress coronavirus in accordance with public health guidelines; and
      • Conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances

      The American Rescue Plan included two new spending requirements for HEERF III institutional share dollars.

      • • Institutions are now required to spend a portion of their institutional share to implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines, and to conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment by requesting professional judgment (PJ). These requirements do not apply to institutions that choose to use all of their institutional share allocation to make student emergency grants.

        Frequently Asked Questions and Answers

        Q: Which students are eligible to receive HEERF III emergency funds?

        A: Similar to the HEERF II funds, the HEERF III funds include no student eligibility requirements either. However, institutions are required to prioritize grants to students with exceptional financial need, such as those who receive Pell Grants. The HEERF III funds can be awarded to online students as well. Eligible student groups include citizens, permanent residents, international students, refugees, asylum seekers, DACA recipients, other DREAMers, and similar undocumented students.

        Q: I'm a proprietary school. What can I use my funds for?

        A: While $396 million is allocated for use by for-profit, or proprietary institutions, any funds received by proprietary institutions would only be allowed to be used for emergency grants for students. See the chart above for allowable uses for students.

        Q: Do I need to draw down my HEERF III funds by a certain deadline?

        A: Schools that previously received either HEERF I or HEERF II funds are required to start drawing down funds from both the student and institutional portions of HEERF II funds within 90 days of receiving their respective supplemental HEERF II award notifications. ED has not yet issued guidance on the amount of time institutions have to begin drawing down HEERF III funds. Additionally, schools should not simply draw down it's entire HEERF III student and institutional allocations at once. All HEERF funds must be drawn down only as necessary to meet immediate cash need for spending the funds. That is, schools must spend funds for student grants within 15 calendar days of drawing down those funds from G5, whereas funds used for purposes other than the awarding of student grants must be spent within three calendar days of draw down.

        Q: Will HEERF emergency grants be counted as income for the calculation of Expected Family Contribution (EFC) or estimated financial assistance (EFA)?

        A: No. Emergency financial aid grants made by a federal agency, State, Indian
        tribe, higher education institution or scholarship-granting organization (including a tribal organization) to a student because of an event related to the COVID-19 national emergency are not included in the student's gross income.

        Q: How long does my institution have to spend our HEERF III funds?

        A: Institutions generally must expend their HEERF grant funds within one year
        from the date when the Department processed the most recent obligation of funds for each specific grant. Thus, institutions that received a supplemental award under ARP have one year to spend all remaining CRRSAA, CARES, and new ARP funds for each grant from the date their ARP supplemental award is made. The specific period of performance will be indicated in Box 6 of your institution’s GAN.

        Q: If I received funds through the CARES Act or the CRRSA Act do I need to do anything to receive my HEERF III allocation?

        A: No, if your public or non-profit institution received funding through either the CARES or CRRSA Act you do not need to do anything to receive your institutions allocation.

        To assist with management and oversight, proprietary institutions must first submit the Required Proprietary Institution Certification form signed by the proprietary institution’s President or CEO and any owners with at least 25% ownership in the institution. Proprietary institutions must submit the form by August 11, 2021, as specified in the Federal Register. Once that certification document has been completed, institutions must email it to [email protected].

        Q: What are the reporting requirements for the HEERF III funds?

        A: Institutions will be required to post the Quarterly Institutional Public Reporting Form and Quarterly Student Public Reporting Form for HEERF III funds to their websites by the tenth day following the end of each calendar quarter. ED acknowledges that because it never affirmatively established HEERF II reporting requirements, it is extending the deadline by which institutions must submit retroactive reports for HEERF II to the end of the second calendar quarter, which is June 30, 2021. The reporting period for the HEERF II and III annual reports will begin on April 11, 2022 and end on May 6, 2022. The annual performance report covers activities funded between January 1 through Dec. 31, 2021.

        NASFAA has created a one-pager which summarizes reporting guidelines for all three HEERF (CARES, CRRSA, ARP) grants.

        Q: I haven't finished spending my HEERF I or HEERF II funds yet, do I still have to follow the specific rules for those funds or are they all compiled under HEERF III rules now?

        A: All remaining HEERF funds, regardless of distributing programs, are now compiled under HEERF III rules.

        ED specifies that the following previously-issued guidance applies in whole or in part to HEERF III, unless superseded by the text of the American Rescue Plan:

        • Lost Revenue FAQs (issued on March 19, 2021)
        • CRRSAA HEERF II (a)(1) FAQs (issued on January 14 and updated March 19, 2021)
        • CRRSAA HEERF II (a)(4) FAQs (issued on January 14 and updated March 19, 2021)
        • HEERF CARES Act Rollup FAQs (issued Oct. 14, 2020 and revised January 28, 2021)
        • HEERF Grant Program Auditing Requirements Letter (issued on March 8, 2021)

        Publication Date: 2/2/2023