On April 21, the Department of Education issued two Frequently Asked Questions documents in order to provide guidance on a number of questions related to the allocation of emergency grant funds to students and institutional funds under the CARES Act.

The FAQ about the Emergency Financial Aid Grants to Students clarifies the following topics:

  • Institutions that have provided refunds to students for room and board, tuition and other fees cannot reimburse themselves from the funds intended for the emergency financial aid grants to students.

  • Institutions that have provided information technology hardware and other related equipment cannot reimburse themselves from the funds intended for the emergency financial aid grants to students.

  • Reimbursement guidelines for institutionally-funded emergency grants to students

  • Institutions that have continued to pay student workers from institutional funds for campus jobs cannot reimburse themselves from the funds intended for the emergency financial aid grants to students.

  • Institutions cannot use the funds to pay outstanding or overdue students bills, i.e. satisfy a student’s outstanding account balance.

  • Data that the Department of Education will require after disbursement of emergency financial aid grants.

  • Obligations that an institution must meet to pay employees upon accepting funds for the emergency financial aid grants to students.

  • Treatment of incarcerated students who are participating in the Second Chance Pell Experimental Site initiative.

  • Student eligibility to receive emergency financial aid grants under the CARES Act (note: DACA students are ineligible to receive emergency grant funds).

  • Inclusion of CARES Act funding in an institution’s 90/10 calculation.

  • How institutions can make the payment of emergency financial aid grant funds to students.

  • Student eligibility to receive emergency financial aid grants under the CARES Act for students enrolled in institutions that provide both online and ground-based education.

The FAQ about the Institutional Portion of the Higher Education Emergency Relief Fund clarifies the following topics:

  • Requirements to enter into the Funding Certification and Agreement for Emergency Financial Aid Grants to Students as a condition to receive funds under the CARES Act.

  • Reimbursement guidelines for refunds to students for room and board, tuition and other fees under the Institutional Costs portion of the CARES Act.

  • Reimbursement guidelines for refunds to institutions for the purchase of laptops, hotspots and other information technology equipment under the Institutional Costs portion of the CARES Act.

  • Use of the Institutional Costs portion of the CARES Act to make further emergency grants to students.

  • Use of the Institutional Costs portion of the CARES Act to make emergency financial grants to students who were enrolled in online programs at institutions who offer both online and on-ground instruction.

  • Use of the Institutional Costs portion of the CARES Act to award scholarships for future academic terms.

  • Use of the Institutional Costs portion of the CARES Act to pay an OPM provider for added costs of transitioning to distance learning instruction.

  • Data requirements for institutions following disbursement of funds.

Read our previous posts on this topic here and follow our federal education stimulus tracker here.