ED Releases Further Guidance on Use of CARES Act Emergency Funding for Students, Institutions – NASFA
The Department of Education (ED) on Tuesday announced that more than $6 billion is now available to institutions as part of the funding allocated in the Higher Education Emergency Relief Fund (HEERF), and provided additional guidance on how emergency grant funding may be allocated for students, specifically noting that students must be Title IV eligible to receive the funds.
Schools immediately questioned whether they would need to have a FAFSA on file in order to disburse CARES Act emergency funds to students. While ED’s guidance does state that a FAFSA is not required, having one on file would be the only practicable way for an institution to determine that a student is eligible to participate in the student aid programs and meet all applicable eligibility requirements. NASFAA has already reached out to ED regarding the scope of ED’s statement that 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.”
The guidance addressed several outstanding questions, such as clarifying that students who were enrolled exclusively in online programs on March 13 (the date of President Donald Trump’s national emergency proclamation) are not eligible to receive the emergency grants, that institutions may not use the student portion of funding to reimburse themselves for tuition or room and board refunds, and that the student grants may not be used to cover outstanding balances on a student account.