#RealCollege Statement on U.S. Department of Education Guidance Regarding Higher Education Emergency Relief Fund III

#RealCollege Statement on U.S. Department of Education Guidance Regarding Higher Education Emergency Relief Fund III

This statement should be attributed to Sara Goldrick-Rab and Carrie R. Welton.

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May 12, 2021

Yesterday, the U.S. Department of Education (ED) released new guidance regarding the third round of Higher Education Emergency Relief Fund (HEERF III) relief funds allocated from the American Rescue Plan Act (ARP). This guidance signifies a significant shift toward ensuring all students, including those who are not are eligible for federal financial aid, have their education supported. It also clarifies how best to use funds to help students stay enrolled and meet their basic needs. This guidance comes at a vital time: a growing body of evidence shows that emergency aid is an effective and efficient way to help students stay enrolled and graduate. Ensuring all students are eligible is crucial in building a more equitable higher education system and economic recovery.

Expansion of Eligibility to Non-Title IV Students

The Hope Center is thrilled that ED has issued a new final rule that reverses the prior administration’s claim that students must be eligible for Title IV financial aid to receive HEERF emergency grant aid. Now, all students with exceptional need, including undocumented, Deferred Action for Childhood Arrivals (DACA), and those unable to fill out a FAFSA, may receive emergency grant aid. The Hope Center has been a vocal advocate for this policy change since the onset of the pandemic. More students will now have access to critical assistance to mitigate the financial impact of the ongoing COVID-19 pandemic and support their educational success.

Clarification that HEERF Funds are Emergency Aid, Not Financial Aid

Through this guidance, ED has made clear that funds received through HEERF are separate from Title IV financial aid and are meant to provide students with maximum allocable discretion on how they use their funds. This shift represents a positive step toward trusting students to address their needs while allowing institutions flexibility in utilizing relief funds. For example, ED has explicitly stated that funds can be allocated to students who have experienced “significant unexpected expenses, such as the loss of employment (either for themselves or their families), reduced income, or food or housing insecurity.” They further clarify that funds can be used for any component of a student’s cost of attendance or for emergency costs such as food, housing, health care (including mental health care), or childcare.

Additionally, ED has affirmed that students have discretion about how they receive HEERF grants. Students can also apply additional emergency aid dollars to discharge student debt or unpaid account balances. ED recommends that institutions use the institutional (or non-emergency aid) portion of HEERF funds to discharge student debts, so students can access transcripts, re-enroll, or even transfer to another institution.

Proactive Outreach on Financial Aid Appeals and Re-enrolling Students

We were pleased to see the American Rescue Plan Act included our recommendation that institutions proactively inform students about their ability to appeal if their financial circumstances have changed. ED has clarified that institutions must directly communicate to students through email, phone, in-person, or other means. It is not sufficient to post opportunities to receive financial aid adjustments via the school website. We believe this will make it more likely that those who have been most affected by the pandemic will take advantage of the financial aid appeals process.

Finally, institutions are encouraged to use the institutional portion of their HEERF allocation to re-engage and re-enroll students who may have dropped out for any reason since the onset of the pandemic in March 2020. HEERF funds may be used for academic, mental health, and other supports that help students stay enrolled or other activities that may smooth the transition back to school for students who have left. HEERF funds may not be used for advertising or marketing, nor made a condition of enrollment. We encourage institutions to leverage this opportunity to expand or create programs that improve basic needs such as food, housing, and childcare that support students’ ability to focus on learning.

Maximizing Relief for #RealCollege Students

Through the CARES Act, the Coronavirus Response and Relief Supplemental Appropriations Act, and now the American Rescue Plan Act, Congress has helped address the unimaginable pain and disruption of the COVID-19 pandemic. We are grateful to the Department of Education for correcting the exclusionary policies of the previous administration to ensure all students are recognized and valued.

Moving forward, we encourage ED and Congress to work together on other proven strategies to support #RealCollege students. Including permanently expanding emergency aid and dismantling restrictions on education in public assistance programs. These improvements will address the pervasive inequality that preceded the pandemic that has harmed the educational attainment and economic mobility of marginalized and minoritized students, parenting students, undocumented students.

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