President Biden signed the American Rescue Plan Act of 2021 into law on March 11, 2021. The Act includes around $1.9 trillion dollars in funding for coronavirus recovery, $39.6 billion of which is appropriated to institutions of higher education under the third installment of the Higher Education Emergency Relief Fund (HEERF). Prior installments of HEERF were incorporated within the Coronavirus Aid, Relief, and Economic Security Act, and the Coronavirus Response and Relief Supplemental Appropriations Act. HEERF III is structured similarly to HEERF II, however there are important differences that institutions must be aware of.
What is the same?
Changes institutions should be aware of
The Department of Education made HEERF III funds available to institutions of higher education on May 11, 2021. In coordination with the release of the funds, the Department released a frequently asked questions document which addresses issues specific to HEERF III and provides additional clarification on matters that would be applicable to all of the HEERF programs. Within the FAQs, the Department provides further guidance on matters including:
Overall, most institutions likely will not find significant changes in the way they expend or account for HEERF funds over that which they experienced under HEERF I and II. Institutions should continue to track all of their coronavirus related expenses and determine whether they can be covered with HEERF funds by consulting the underlying statutes, Department of Education guidance in the form of frequently asked questions, the Department of Education general administrative regulations, and the uniform administrative requirements, cost principles, and audit requirements for federal awards in order to determine whether a cost is allowable. Institutions should also be prepared to follow all reporting requirements as laid out by the Department of Education.