The US Department of Education posted new guidance about increased flexibility for using funds received by institutions of higher education under the Higher Education Emergency Relief Fund (HEERF) grant programs. These updates reflect a change in the Department’s prior position, which allowed funds received under the Coronavirus Response and Relief Supplemental Appropriations Act of 2021 (CRRSAA), to be used only for costs incurred on or after December 27, 2020, the date the CRRSAA was enacted. Grantees will now have the flexibility to charge costs back to March 13, 2020, the date the national emergency was first declared. 

The Department also supplemented this policy change with:

1. Guidance on how grantees may calculate and charge “lost revenue” to their HEERF awards, and
2. Additional Frequently Asked Questions (FAQs) for the section 314(a)(1) Public and Private Nonprofit Institution Grants and (a)(4) Proprietary Institution Grant Funds for Students.

These updates are as follows: 

• Federal Register Notice of Interpretation (NOI). The Department published a notice regarding the allowable period for which grantees may charge costs and lost revenue to their HEERF grant. That period is now from March 13, 2020 onward. The NOI is effective as of March 22, 2021.
• HEERF Period of Allowable Expenses G5 Notice. Along with the Federal Register NOI, above, the linked updated notification details specific, corresponding changes to the Grant Award Notification documents to amend the allowable period of expenditures back to March 13, 2020.
• HEERF Lost Revenue FAQs. This new set of FAQs responds to the large number of questions the Department received from HEERF grantees regarding how institutions may calculate and account for lost revenue they incurred as a result of COVID-19.
• Updated FAQs for CRRSAA (a)(1). These FAQs contain conforming updates to allow for expenditures incurred back to March 13, 2020, as well as the addition of new FAQs including guidance on whether HEERF funds may be used to support non-degree seeking, non-credit, dual enrollment, and continuing education students, among others.
• Updated FAQs for CRRSAA (a)(4). As with the (a)(1) FAQs, the Department made conforming edits to allow recipients of (a)(4) Proprietary Institution Grant Funds for Students to reimburse themselves for financial aid grants to students made as far back as March 13, 2020, where those grants were not covered with prior CARES Act funds. This guidance applies to all HEERF grant funds, including unspent CARES Act funds, CRRSAA funds, and American Rescue Plan Act funds.

Please contact AACOM Government Relations at aacomgr@aacom.org with questions or for further information.

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