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Navigating the COVID-19 Higher Education Emergency Relief Fund

Tim Gaber

Aug 14 2020

3 min read

As the entire world feels the effect of the COVID-19 pandemic, the United States federal government stepped in to enact the CARES Act, which included the Higher Education Emergency Relief Fund (HEERF), in an effort to provide financial relief to institutions and students.

Funds are provided to institutions based on allocations established under a formula in the CARES Act. This formula is weighted significantly by the number of full-time students that are eligible for Pell grants and also considers the population of the school and the number of students that were not enrolled full-time online before the COVID-19 pandemic. In order to access these funds, institutions must complete an application and sign a certificate of funding before the resources are made available through the G5 system.

Student Portion

The CARES Act requires no less than 50 percent of the HEERF funds be made available to students for cost of attendance-related expenses (such as food, housing, childcare, healthcare, and more). Allocation of funds can be determined by the institution. Frequently asked questions regarding the student portion can be found on the Department of Education’s website.

Institutional Portion

Institutions can use their allocated HEERF funds to expand their remote learning or technology capabilities and for related faculty and staff training or support. Funds can also cover student expenses, including housing, food, childcare, and technology support. Any unused funds from the 50 percent institution portion can be used for the student portion. Frequently asked questions regarding the institutional portion can be found on the Department of Education’s website.

Reporting Requirements

The reporting conditions of the CARES Act require institutions that receive more than $150,000 to follow the Federal Spending Transparency Act (“Transparency Act” or FFATA) guidance. Moreover, institutions receiving more than $50,000 ($25,000 student portion and $25,000 institutional portion) are required to report to the Secretary of Education 30 days from the date of certification as well as every 45 days thereafter. The Secretary’s requirement covers the Transparency Act obligations.

The Department of Education is still developing a process for institutions to provide the required reporting data. Until this process is made available, institutions must make this information accessible to the public on the institution’s website, including the following items according to the Office of Postsecondary Education’s electronic announcement:

An acknowledgement that the institution signed the certification and agreement and returned it to the Department, assuring that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students.
The total amount of funds that an institution will receive or already received from the Department pursuant to the institution’s certification and agreement.
The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (as of the 30-day report and every 45 days thereafter).
The estimated total number of students eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants.
The total number of students that received an Emergency Financial Aid Grant under Section 18004(a)(1) of the CARES Act.
The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they receive.
Any instructions or guidance provided by the institution to students concerning the Emergency Financial Aid Grants.

For more information about the HEERF visit the U.S. Department of Education’s website. Please contact our Title IV experts to discuss your situation.

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About the Author

Tim Gaber

Tim Gaber, CPA, is the Leader of Sikich’s Title IV Audit and Consulting Practice, overseeing and managing audits, examinations and other special projects related to a wide range of services. In his leadership position, Tim keeps the practice on top of ever-changing rules and regulations within this sector by developing and providing training to staff and clients.