Articles & Insights May 06 2020
Allocation Methodology

Department of Education will distribute payments from the HEERF to institutions through same funds distribution system that the institution receives Title IV federal student aid.

The $14.25 billion HEERF will be distributed in the following manner:

  • $9.6 billion – Relative share of full-time enrollment of Pell Grant recipients who are not exclusively enrolled in distance learning courses prior to the pandemic
    [Section 18004(a)(1)]
  • $3.2 billion – Relative share of full-time enrollment of non-Pell Grant recipients who are not exclusively enrolled in distance learning courses prior to the pandemic
    [Section 18004(a)(1)]
  • $1.06 billion – supplemental appropriation for HEA’s Historically Black Colleges and Universities and Hispanic-Serving Institutions programs [Section 18004(a)(2)]
  • $356 million – FIPSE allocation by DOE based on greatest unmet needs related to COVID-19
    - Priority given to institutions who do not receive at least $500K from other elements of the Fund [Section 18004(a)(3)]
Allowable Use of Funds

Generally, may be used for any expenses incurred after March 13, 2020 that the recipient has a reasoned basis for concluding represent a clear nexus to significant changes to the delivery of instruction due to COVID-19. An institution may also use funds received to reimburse itself for refunds made to students for housing, food, or other services that recipient could no longer provide; or for hardware, software, or internet connectivity that recipient may have purchased on behalf of students. Funds should be utilized within 1 year of receipt.

Institutions who received funds under Section 18004(a)(1) must expend at least 50% of provided funds to provide financial aid grants to students. Those who received funds under Section 18004(a)(2) and Section 18004(a)(3) are not bound to the requirement to expend at least 50% of provided funds as student aid.

Eligible student aid expenses include but are not limited to:

  • Food
  • Housing
  • Course Materials
  • Technology
  • Health Care
  • Child Care
Unallowable Use of Funds

Funds received cannot be used for endowments, capital outlays associated with athletics, sectarian instruction or religious worship; or for payments to contractors that provide pre-enrollment recruitment activities. Other unallowable use of funds includes for senior administrator and/or executive salaries, benefits, bonuses, contracts, incentives; stock buybacks, shareholder dividends, capital distributions, and stock options; and any other cash or other benefit for a senior administrator or executive.

Reporting Requirements

Recipient of funds must supply quarterly reports to Secretary detailing use of funds. DOE may require additional reporting in future, at its discretion.

How to Access Funds

To access funds, Recipients must sign and submit a Certification Agreement, SF 424 and SF 424 Supplemental and submit via grants.gov under the opportunity for which they are attempting to access funds. NOTE: You must sign and submit the Certification and Agreement that correspondence with your grant opportunity.

If you do not have a Grants.gov account, you may create an account at the following link: https://www.grants.gov/web/grants/applicants/registration.html

You can contact the Grants.gov Help Desk at 1-800-518-4726 or support@grants.gov if you have any questions regarding registration.

After you create a Grants.gov account, you can access Grants.gov locate the Funding Opportunity by selecting the Applicant Tab, then How to Apply for Grants.

  1. Select Applicant tab
  2. Select How to Apply for Grants
  3. Select Search for Opportunity Package
  4. Enter Opportunity Number
  5. Select Search

Items you will need to submit

  1. Certification and Agreement for the Funding Opportunity you are seeking funding for
  2. Application for Federal Assistance (SF-424)
  3. Department of Education Supplemental Information Form for the SF-424

A copy of these forms and instructions on how to complete them are included in this HEERF Application Package

We hope you found this brief informative. If you or your institution has questions regarding how your HEERF payments can be utilized, or if you are interested in learning more about other Federal Assistance opportunities available through the CARES Act and subsequent COVID-19 appropriations, contact us at covidhelp@wittobriens.com.