Frequently Asked Questions from Higher Education Institutions about the Student Portion of HEERF Grants Answered

Written by Billy Minch on August 27, 2021

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In response to the COVID-19 pandemic, Congress passed the Higher Education Emergency Relief Fund (HEERF) economic aid packages, which include approximately $77 billion in funding to assist public and private higher education institutions by providing emergency financial aid grants to students and defraying expenses associated with coronavirus.

In many instances, especially in the early months of the pandemic, the answers to some questions were unknown—or at least unclear. The same is true for HEERF grants.

Thankfully, in the later months of 2020 and throughout 2021, the Department of Education has clarified many issues and provided guidance to help point us in the right direction.

All three HEERF grants (HEERF I, HEERF II and HEERF III) require a certain percentage or dollar amount to be used for emergency awards to students (student portion).

Here are the questions we’ve received most about the student portion of HEERF grants—and the answers that matter most to higher education institutions.

I’ve heard contradictory definitions of the term “student” concerning HEERF grants. Is there a revised definition of “student” that applies to all HEERF programs?

A Department of Education ruling on May 14, 2021 clarifies the definition of “student” as used in the HEERF programs as “any individual who is or was enrolled at an eligible institution on or after March 13, 2020, the date of declaration of the national emergency concerning the novel coronavirus disease.”

This revised definition includes citizens, permanent residents, refugees, asylum seekers, Deferred Action for Childhood Arrivals (DACA) recipients, other DREAMers and similar undocumented students.

I’ve heard that student portion emergency grants were only to be given to students eligible to participate in Title IV aid programs and also that any student with exceptional need can receive an emergency aid grant. What’s the right answer?

The Department of Education ruling on May 14, 2021 clarifies that students are NOT required to be eligible for Title IV student financial aid in order to receive HEERF grants.

The ruling directed institutions to prioritize aid to students with exceptional need. Some examples of exceptional need include students who:

  • Receive Pell Grants;
  • May be eligible for other federal or state need-based aid;
  • Have faced significant unexpected expenses, such as loss of employment for themselves or family members; or
  • Have reduced income or food or housing insecurity.

The final ruling also indicates that emergency financial aid grants can be provided to students who are exclusively enrolled in distance education, provided that the institution first prioritizes exceptional need.

Can international students and/or students who are studying abroad receive a student portion HEERF emergency financial aid grant?

International students with exceptional need may receive a HEERF grant. However, the Department of Education encourages institutions to prioritize funding to domestic students.

Students studying abroad would be eligible to receive grants from the institution where they are enrolled provided that they meet the criteria established by the institution prioritizing exceptional need.

In calculating need, should we include a HEERF emergency financial aid grant provided to a student during the 2020-2021 year as a component of a student’s Expected Family Contribution?

An April 3, 2020 communication from the Department of Education indicates that aid received by victims of an emergency from a federal or state entity for the purpose of providing financial relief is not to be counted as income for calculating a family’s Expected Family Contribution (EFC).

Therefore, HEERF emergency financial aid grants should not be counted as income for EFC purposes.

Should we include the HEERF emergency financial aid grant as a component of assistance in an award package?

No, emergency financial aid grants are not financial aid and therefore should not be included in the award letter.

Under all HEERF Acts, students must have discretion about how they receive their emergency financial aid grant, and institutions must receive affirmative written consent from a student before using emergency financial aid grants to satisfy an outstanding student account balance.

Are HEERF emergency financial aid grants to students considered taxable income?

According to an IRS publication dated March 30, 2021, “emergency financial aid grants made by a federal agency…to a student because of an event related to the COVID-19 national emergency are NOT included in the student’s gross income.”

Learn More or Get Assistance with HEERF Grants

Over the past year our higher education team has assisted many institutions in their attempt to understand the various HEERF grant award documents and related FAQs.

If you have questions about HEERF grants or funding, please reach out to your advisor in the Warren Averett Higher Education Practice Group, or ask a member of our team to reach out to you.

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