CLIENT ALERT: DOE Announces New Policy Guidance for HEERF Grant Recipients to Further Assist Students, Federal Student Aid Applications, and Institutions of Higher Education

By Published On: April 6, 2021

The U.S. Department of Education released new policy guidance that will allow colleges and universities to use stimulus funds for a variety of student needs, including cancelling student debt in certain cases. According to the agency, this flexibility includes “financial aid grants to dual enrollment, continuing education, non-degree seeking, or non-credit students, as well as to a broad range of students with exceptional needs, such as certain refugees or persons granted asylum.”  Colleges can also use the funds to “reimburse themselves for lost revenue while supporting students during the pandemic, including discharging unpaid institutional balances so students can resume their studies and subsidizing childcare services for student parents.”  The guidance also provides for outreach initiatives for expanded student access to federal nutritional assistance programs.

Building upon the program established in the Coronavirus Aid, Relief, and Economic Security (CARES) Act, this new HEERF guidance reflects a change in the Department’s prior position, which previously only allowed funds received under the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), to be used for costs incurred on or after December 27, 2020, the date of the enactment of the CRRSAA.  Grantees will now have the flexibility to charge costs back to March 13, 2020, the date the COVID-19 pandemic was declared a national emergency.

The U.S. Department of Education also provided guidance and examples to help institutions better understand the scope of reimbursing, calculating, and reporting for lost revenue under the HEERF grant programs.

The latest guidance and examples are available on the U.S. Department of Education’s website:

Additionally, the National Association of Student Financial Aid Administrators (NASFAA) published a helpful table comparing the three phases of funding.  While it does not answer all questions, it is a helpful introduction for any practitioner.

NEW WEBINAR: We understand that institutions of higher education may need to reassess strategic planning and measures to mitigate the risks of accepting HEERF funds in light of these regulatory changes.  To assist in this effort, FTLF is delighted to invite you to join us on May 4, 2021, for a complimentary webinar* to gain more insight into these new developments in higher education federal pandemic relief, including the new Phase III of the program, and key program benefits and regulatory compliance requirements in the context of a new Administration.  In this webinar, we will expand upon and clarify several aspects of the HEERF requirements and share updates in the HEERF federal pandemic relief programs since FTLF provided an overview webinar on July 27, 2020.  Learn More or Register Here.

* This is a complimentary webinar.  There is no registration fee for this course, but you will need to create an account on the FTLF Learning Center.  Please contact us if you need assistance.


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