Join Us on May 25th For A Comprehensive Review of the New HEERF Guidance! Until then, here is a brief overview of key points of interest:

The new guidance that the U.S. Department of Education posted last week (May 11, 2021) provides a significant amount of new information covering a broad range of topics, but some of the most important are:

• HEERF I Closure
https://www.govinfo.gov/content/pkg/CFR-2014-title2-vol1/pdf/CFR-2014-title2-vol1-sec200-343.pdf

• HEERF II Expenditure of Funds Requirements
https://www2.ed.gov/about/offices/list/ope/crrsaa.html

• HEERF III Allocation of Funds and Application Requirements.html
https://www2.ed.gov/about/offices/list/ope/heerfiiiproprietary.html

Next week, FAME will provide a thorough review of all of these topics and more. Sally and Tom have already reviewed each of the Departments’ two web pages, the two sets of Interim Final Rules, and the new FAQs and are in the process of preparing a comprehensive slide presentation for us for next week. In addition to all of this review, Tom has already submitted a list of questions on some areas where we anticipate that the FAME members, as well as the broader community, would still like additional guidance.

If, in the course of your review of these documents, you have specific questions, please share them with Tom and we will do our best to have them answered by next Tuesday.

For now, several key takeaways for your review include:

The deadline for all title IV eligible proprietary institutions to notify the Department of either your application for or voluntary denial of, the HEERF III emergency relief funds for students is August 11, 2021.
There are different application requirements depending upon whether or not your institution received HEERF II emergency student grants or not, which we will go over. However, regardless of whether or not you applied for or did not apply for HEERF I and II emergency grants, you must actively contact the Department regarding either the acceptance (through application) or voluntary denial (through notification) of HEERF III emergency grants. We will help you make sure you have the information necessary to decide your next steps.

Given the additional guidance related to HEERF II emergency grants, which also applies to HEERF I emergency grants, the Department is being very supportive in the application for extension of the expenditure of HEERF I grants.
There are specific details on how to apply for the extensions, and the Department has provided step-by-step instructions on the process. We will share this information with you and also share anecdotes on specific examples we have heard about.

The new guidance will most likely require all institutions to review and make revisions to their process for determining “Exceptional Need” and the prioritization of students receiving HEERF II and HEERF III emergency student grants.
The addition of new categories of eligible students (e.g. DACA and other immigrant student populations), new Dos and Don’ts in establishing priorities, and other information will necessitate a review of your institutions policies. We will go over all of the information to assist you in thinking through what you need to consider in the development of a compliant policy.

Register Now for This Highly Informative Webinar!