Department of Education Guidance
January 14, 2021 Electronic Announcement
U.S. Department of Education
PRESS RELEASE: U.S. Department of Education Quickly Makes Available More Than $21 Billion in Taxpayer Funds to Support Continued Education at Colleges, Universities (EA ID: OPE Announcements-21-01)
The U.S. Department of Education announced today that an additional $21.2 billion is now available to institutions of higher education (IHEs) to serve students and ensure learning continues during the COVID-19 pandemic. This funding is allocated to the Higher Education Emergency Relief Fund II (HEERF II) by the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), which was signed into law by President Donald J. Trump on Dec. 27, 2020.
The CRRSAA appropriated $82 billion for education, and the Department has made available all but $1.9 billion of that funding in the 18 days since the law was enacted. Earlier this year, former Secretary DeVos expeditiously provided $30.75 billion for education through the Coronavirus Aid, Recovery, and Economic Security (CARES) Act.
Today’s announcement awards $20.5 billion to public and non-profit colleges and universities and $681 million to proprietary schools. Public and non-profit schools can use their awards for financial aid grants to students, student support activities, and to cover a variety of institutional costs, including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll. Proprietary schools must use their awards exclusively to provide financial aid grants to students.
“The Department is working quickly, yet again, to ensure taxpayer-funded COVID relief allocated by Congress gets to those who need it most. I would encourage leaders of our higher education institutions to use this funding as former U.S. Secretary of Education Betsy DeVos suggested during the first round of relief—to support students who are struggling financially in the wake of this pandemic and to build IT and distance learning capacity for now and in preparation for the future,” said Acting U.S. Secretary of Education Dr. Mitchell "Mick" Zais.
Allocations to institutions are based on a formula that includes the relative shares of Federal Pell Grant recipients, the relative shares of non-Pell Grant recipients, and the relative shares of Federal Pell and non-Pell Grant recipients exclusively enrolled in distance education prior to the coronavirus emergency.
CRRSAA continues to support the important work of addressing students’ unmet needs by providing a minimum amount of funding that each institution must devote towards financial aid grants to students. In addition, funds received for students enrolled exclusively in distance education and all funding awarded to proprietary institutions may be used only for financial aid grants to students. The small number of institutions that owed an excise tax on their endowments for tax year 2019 will only be entitled to receive half-awards and will be required to spend the vast majority of it on financial aid grants for students.
Public and private non-profit IHEs that already have approved CARES Act HEERF awards are not required to submit a new or revised application to receive additional funding under the CRRSAA. Public and private nonprofit IHEs that did not receive HEERF Student Portion and/or Institutional Portion awards under the CARES Act, as well as proprietary institutions, may apply for funding under the CRRSAA via Grants.gov.
The Department is also working expeditiously to allocate the remaining funding provided to IHEs under the CRRSAA and will provide details on how eligible institutions may apply for this additional emergency funding in the coming days.
For more information on HEERF II and the CRRSAA please visit our website here.
May 6th 2020 Electronic Announcement - Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act” or the “Act”)), Pub. L. No. 116-136, 134 Stat. 281 (March 27, 2020), directs institutions receiving funds under Section 18004 of the Act to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the Higher Education Emergency Relief Fund (“HEERF”). Section 18004(c) of the CARES Act requires institutions to use no less than 50 percent of the funds received from Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students for expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student’s cost of attendance such as food, housing, course materials, technology, health care, and child care). On April 9, 2020, the Department published documents related to the Emergency Financial Aid Grants, including a letter from Secretary Betsy DeVos, a form Certification and Agreement for signing and returning by institutions to access the funds, and a list of institutional allocations under 18004(a)(1).
The Certification and Agreement directs each institution applying for HEERF funds to comply with Section 18004(e) of the CARES Act and submit an initial report (the “30-day Fund Report”) to the Secretary thirty (30) days from the date of the institution’s Certification and Agreement to the Department. The Department will provide instructions for providing the required information to the Secretary in the near future. In the meantime, each HEERF participating institution must post the information listed below on the institution’s primary website. The Department would like to receive the most current information from the date when the institution received its allocation for emergency financial aid grants to students, and the institution should have received its allocation within a few days after submitting the Certification and Agreement. Accordingly, the following information must appear in a format and location that is easily accessible to the public 30 days after the date when the institution received its allocation under 18004(a)(1) and updated every 45 days thereafter:
- An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students.
- The total amount of funds that the institution will receive or has received from the Department pursuant to the institution’s Certification and Agreement [for] Emergency Financial Aid Grants to Students.
- The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day Report and every 45 days thereafter).
- The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act.
- The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act.
- The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act.
- Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants.
*Note: In preparing the 30-day Fund Report, institutions should use data suppression and other methodologies to comply with, and protect the personally identifiable information from student education records, under the Family Educational Rights and Privacy Act (20 U.S.C. § 1232g; 34 CFR Part 99). For example, the Department does not expect institutions to report information about a group of 10 or fewer students. For example, if the total number of eligible students, the total of number of students who received Emergency Financial Aid Grants, or the difference between the two numbers is less than 10, then the institution should not display the number of students or the amount of Emergency Financial Aid Grants to students on publicly available website(s) controlled by the institution.
Institutions that accurately report the information listed above will meet the initial reporting requirements. For subsequent reports and reporting for other related HEERF programs, the Department will notify participating institutions of the Department’s preferred reporting method. The Department may choose to collect additional information from institutions in accordance with the reporting requirement stated at Section 18(e) of the CARES Act and the Certification and Agreement.
For more information on the HEER, please visit the Department’s CARES Act: Higher Education Emergency Relief Fund page.
If you have questions about the information in this announcement, contact HEERF@ed.gov
Participants from the U.S. Department of Education
Betsy DeVos, U.S. Secretary of Education
Mark Brown, chief operating officer, Federal Student Aid
Scott Stump, assistant secretary, Office for Career, Technical, and Adult Education
For more information on all the efforts the Department is taking to address the COVID-19 national emergency, visit ed.gov/coronavirus.
For more information about COVID-19, please visit the following websites: coronavirus.gov, cdc.gov/coronavirus/2019-ncov/index.html and usa.gov/coronavirus.
March 5th 2020 Electronic Announcement - In response to growing concerns related to Coronavirus (COVID-19) the Department of Education released guidance through an electronic announcement. We encourage all our schools to read through this guidance so your students can benefit from the flexibilities provided if they encounter any of the scenarios outlined.
April 1st, 2020 - Readout of the U.S. Department of Education’s COVID-19 Conference Call with Higher Education Stakeholders
WASHINGTON – U.S. Secretary of Education Betsy DeVos, along with several senior Department officials, held a conference call today with higher education leaders to provide an update on the Trump Administration’s whole-of-government response to the coronavirus (COVID-19) national emergency.
The Secretary began the call by welcoming the participants, including state higher education executive officers, college and university presidents, accreditors, and leaders of national higher education organizations, and thanking them for their continued work on behalf of students.
The Secretary then briefed the group on the Department’s quick action to provide regulatory flexibility so that colleges and universities could move classes online to limit disruptions to student learning and prevent the spread of COVID-19. She also discussed the increased, temporary flexibilities given to accreditors so that they could provide short-term approval for distance learning programs and courses, conduct virtual site visits, and extend accreditation terms or provide good cause extensions during this national emergency.
She then turned the call over to Chief Operating Officer Mark Brown of the office of Federal Student Aid who briefed participants on the immediate action the Department took to provide student loan relief to borrowers including setting student loan interest rates to 0%, suspending student loan payments, and stopping wage garnishments. He also discussed the six-month extension to those actions provided by the recently enacted Coronavirus Aid, Relief, and Economic Security (CARES) Act.
Assistant Secretary Scott Stump of the Office for Career, Technical, and Adult Education discussed new flexibilities announced for Perkins V plan submission deadlines for community and technical colleges as they apply for federal support for career and technical education programs. Additionally, he summarized a recent set of FAQS that provide clarification, flexibilities, and supports to state adult education offices as states seek to provide continuity of operations for adult learners during the COVID-19 outbreak.
This call is part of the Department’s ongoing communications with K-12 and higher education stakeholders regarding the Administration’s education-related coronavirus actions.
Oct 7th, 2020 Electronic Announcement Update
The Office of Postsecondary Education maintains a website containing frequently asked questions (FAQs) that pertain to the COVID-19 pandemic and the CARES Act. The COVID-19 Title IV Frequently Asked Questions website can be accessed at: https://www2.ed.gov/about/offices/list/ope/covid19faq.html.
We recently posted a new FAQ to that website on the provisions of the CARES Act related to Return of Title IV Funds (Return of Title IV Funds / Question #2).
If you have questions about the information provided on the COVID-19 Frequently Asked Questions website, or about Department’s COVID-19 policy guidance in general, please contact us via email at COVIDfirstname.lastname@example.org.
April 3rd, 2020 Electronic Announcement Update - In addition to the guidance released on March 5th, 2020, the Department of Education released updated guidance on April 3rd 2020. It is key to note that The Department is reviewing the CARES Act and intends to provide additional guidance on the Department’s COVID-19 webpage soon.
One of the key takeaways from this updated guidance is the flexibility on clearing V4 and V5 verification groups. Until further notice, Campus Ivy will accept statement of identifications that are not notarized, as well as expired government identification to clear these groups. The expired identification must be expired within the timeframe of the COVID-19 emergency.
April 3rd, 2020 WASHINGTON — U.S. Secretary of Education Betsy DeVos announced today more than $6 billion will be distributed immediately to colleges and universities to provide direct emergency cash grants to college students whose lives and educations have been disrupted by the coronavirus outbreak. The funding is available through the Higher Education Emergency Relief Fund authorized by the Coronavirus Aid, Relief, and Economic Security (CARES) Act, signed into law by President Donald J. Trump less than two weeks ago.
For full details on the guidance provided today, you can visit the Department of Education CARES ACT website.
April 21st, 2020 WASHINGTON — U.S. Secretary of Education Betsy DeVos announced today the release of the second half of the Emergency Grant Funds for Institutions. Section 18004(c) of the CARES Act allows your institution to use up to one-half of the total funds received under Section 18004(a)(1) to cover any costs associated with significant changes to the delivery of instruction due to the coronavirus.
May 15th 2020 Electronic Announcement. UPDATED Guidance for interruptions of study related to Coronavirus (COVID-19)
The Department appreciates that postsecondary institutions and their students face continued challenges resulting from the novel coronavirus disease (COVID-19) pandemic. This guidance provides updated information that expands upon the Department’s March 5, 2020 and April 3, 2020 guidance. Here, we provide additional regulatory flexibilities due to the President’s declaration of a national emergency due to COVID-19 and provide information about the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. No. 116-136, signed by President Trump on March 27, 2020. We will provide additional guidance on our COVID-19 webpage as needed.
Accrediting agency virtual evaluation visits
We are extending through December 31, 2020, the flexibilities provided in the March 17, 2020, guidance permitting accrediting agencies to conduct virtual site visits. We remind accrediting agencies that an on-site visit must follow a virtual site visit, in a timeframe that is reasonably practicable, and may be performed by staff or a trained site visitor and need not repeat the full review. A focused site-visit to confirm the presence of facilities viewed during the virtual site visit and, if required by the accrediting agency, the opportunity to randomly select students to interview as part of the normal site visit process, is sufficient to meet the Department’s requirements for an on-site visit following a full virtual site visit.
We are aware of the need for institutions to plan how they will offer instruction for upcoming periods of enrollment. Many institutions have informed us of their intent to offer both the summer and fall terms using distance education. To provide the necessary flexibility for institutions to make timely decisions, we are expanding the broad approval for the use of distance education as provided in the April 3, 2020, EA to include payment periods that overlap March 5, 2020, or that begin on or between March 5, 2020, and December 31, 2020.
Normally, an institution offering a program via distance education must be accredited for distance education by an agency that has distance education in the scope of its recognition by the Secretary. The Department has interpreted this requirement to apply when an institution offers a program where at least 50% of the program is offered through distance education. The Department is waiving this requirement under the Higher Education Relief Opportunities for Students (HEROES) Act for payment periods that begin on or before December 31, 2020 as outlined above.
Financial Statement and Compliance Audit Requirements
The Secretary is exercising her authority under Section 2 of the HEROES Act to extend the financial statement and compliance audit deadlines by six months.
Institutional Eligibility – Change of Ownership
Typically, the Department issues a temporary Program Participation Agreement (PPA) to extend the participation of an institution while its change of ownership application is pending, and the institution must submit additional information to the Department. This information includes approvals from the institution’s accrediting agency and State, as well as a same day balance sheet prepared under required financial standards, and is typically due by the end of the month following the change of ownership. However, as a result of the COVID-19 national emergency, the Department recognizes that States, accrediting agencies, and auditors may need additional time to review and prepare this information due to the COVID-19 pandemic. Therefore, the Secretary is exercising her authority under Section 2 of the HEROES Act to provide an additional six months for the institution to provide the required information.
Medical College Admissions Test (MCAT)
The Department is aware that the American Association of Medical Colleges has temporarily ceased offering the MCAT exam, which means that some medical schools may be required to accept applicants without the benefit of including an MCAT score in the admissions process. The Secretary is exercising her authority under Section 2 of the HEROES Act to waive the MCAT requirement for foreign graduate medical school admissions for students admitted to medical school during an admissions year in which the MCAT was unavailable to students for some period of time during that year due to COVID-19 related interruptions.
Verification of High School (or Equivalent) Completion Status
Official documentation of high school completion or documentation of the equivalent of high school completion may be difficult for FAFSA applicants to obtain during this national emergency. For applicants in verification groups V4 or V5, institutions should use documentation of an applicant’s high school completion status that it may already have obtained for other purposes (e.g., documentation maintained in its admissions office). Where an applicant is unable to obtain such documentation and an institution does not already have such documentation, it may accept a signed and dated statement from the applicant in which he or she truthfully attests to his or her secondary school completion or the equivalent. The statement must indicate whether a high school diploma or the equivalent was obtained and date of completion (or approximate date). This guidance applies until December 31, 2020, for both the 2019-2020 and 2020-2021 award years.
In addition, institutions that require (as a result of their own policies) an official transcript to verify a student’s eligibility for Title IV participation that are unable to obtain a transcript after making a reasonable effort to do so institutions may accept a signed and dated statement from the applicant in which he or she truthfully attests to his or her secondary school completion. While this attestation does not obviate institutional requirements to meet applicable state authorizing agency or accrediting agency requirements regarding proof of high school or equivalent completion status, the Department is granting authority to accrediting agencies to implement temporary changes to its policies regarding verification of high school completion for the time period covered by this guidance, and any extensions to the time frame granted by the Department in the future.
CARES Act Information
Paycheck Protection Program (PPP)
The Department is aware that institutions receiving loans from the Small Business Administration through the PPP under §1102 of the CARES Act have an opportunity to have up to the full amount of the loan principal forgiven by meeting certain employment requirements. Therefore, as long as an estimate of the amount of forgiveness of PPP loan funds the institution expects to earn, or the actual amount of loan forgiveness provided is identified on an institution’s audited financial statements for the year in which the loan was received, and attested to by the institution’s auditor, the Department will exclude that portion of the PPP loan from total liabilities and increase the institution’s equity or net assets by that amount in calculating the institution’s composite score.
Student Workers and PPP Loan Eligibility
As directed in Interim Final Regulations located at https://home.treasury.gov/system/files/136/IFR-Nondiscrimination-and-Additional-Eligibility-Criteria.pdf, student workers generally count as employees when deter mining the number of employees for PPP loan eligibility, unless (a) the applicant is an institution of higher education, as defined in regulation at 34 C.F.R. § 675.2, and (b) the student worker’s services are performed as part of a Federal Work-Study Program or a substantially similar program of a State or political subdivision thereof. Institutions of higher education must exclude work study students when determining the number of employees for PPP loan eligibility and must also exclude payroll costs for FWS students from the calculation of payroll costs used to determine their PPP loan amount. For more information on the PPP, please visit www.sba.gov/paycheckprotection or www.treasury.gov/cares.
Higher Education Emergency Relief Fund (HEERF) and Emergency Financial Aid Grants to Students
The IRS provides additional information on the tax treatment of student funds here.
Federal Student Aid Program Information
Campus-Based Waivers/Reallocation and FSEOG Emergency Aid Grants
Section 3503 of the CARES Act waives the institutional share (match) requirement associated with the Federal Work-Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) programs for the 2019-2020 and 2020-2021 award years. An institution may reimburse itself from the FWS allocation for the nonfederal portion of wages paid to students on or after March 13, 2020. Likewise, an institution may, for all disbursements of FSEOG made on or after March 13, 2020, reimburse itself from the FSEOG allocation for the nonfederal portion of FSEOG awards contributed through a fund-specific match. Additionally, this section permits an institution to transfer up to 100 percent of its unexpended FWS allocation to FSEOG.
The CARES Act (Section 3504) further provides that an institution of higher education may use any amount of its FSEOG allocation (including funds transferred from FWS) to award emergency financial aid grants to assist undergraduate or graduate students for unexpected expenses and unmet financial need as the result of a qualifying emergency. Eligibility for grants is determined by each institution within the parameters established in the CARES Act (grants to be made for unexpected expenses and unmet financial need).
Institutions may contract with scholarship-granting organizations for the purpose of accepting applications from or disbursing FSEOG Emergency Aid Grants to students, provided students receive the entire amount of the grant with no FSEOG funds used to pay for such contracts.
FSEOG awarding rules, i.e., exceptional need, with grants made first to Pell eligible students having the lowest Expected Family Contributions, are waived for the purpose of making FSEOG Emergency Aid Grants. FSEOG Emergency Aid Grants are not considered Estimated Financial Assistance.
Leaves of Absence (LOA)
Section 3508 of the CARES Act waives the requirement for term-based programs that a student returning from an approved leave of absence (LOA) must resume training at the same point in the academic program that he or she began the LOA. This flexibility makes it practical to use LOAs for term-based institutions for students who are unable to continue attending due to a COVID-19 related circumstance. The tuition and fees component of the cost of attendance (COA) for any subsequent term or award year in which a student returns from the approved LOA may not include the tuition costs for coursework he or she was taking when the LOA began. However, the COA for a subsequent term or academic year may include living expenses even if the student is enrolled in no additional credits. Additionally, credits associated with the coursework a student is completing upon return from an approved LOA may count toward that student’s enrollment status.
Institutions that have not previously had a formal written policy regarding approved LOAs may adopt one, even on a temporary basis. The policy must require all requests for leaves of absence to be submitted in writing and include the reason for the student’s request. Normally, such requests are expected to be received and approved prior to the student beginning any LOA.
However, for all leaves of absence granted as the result of COVID-19 related circumstances, an institution may approve, and students may begin, a leave of absence prior to submitting a written request for an LOA (LOA requests must be obtained subsequently). For example, an institution offering a program for which distance education is not a viable option may decide to suspend the program on a temporary basis placing all students on approved LOAs. The institution would then solicit LOA requests from those students.
Return of Title IV Funds (R2T4)
Section 3508 of the CARES Act directs the Secretary to waive the statutory requirement for institutions to return Title IV funds as the result of student withdrawals related to a qualifying emergency. For any student who begins attendance in a payment period or period of enrollment that begins on or includes March 13, 2020, and subsequently withdraws from the period as a result of COVID-19-related circumstances, an institution is not required to return Title IV funds.
This includes students who withdrew during the applicable period for whom the institution has already performed an R2T4 calculation and returned funds. Where returns have already been made, the institution should re-disburse Title IV funds to those students, making required adjustments in COD, crediting students’ ledger accounts, and requesting any necessary funds from G5. In the case of withdrawn students for whom no returns have been made, the institution should:
- Perform an R2T4 calculation in order to determine the amount of Title IV funds that would otherwise have to be returned;
- Make no adjustments to COD as a result of the withdrawal;
- Make no adjustments (as the result of the withdrawal) to the amount of Title IV aid credited to the student’s ledger account.
If an affected student withdraws prior to some or all her Title IV aid having been disbursed (a situation that would normally result in a post-withdrawal disbursement), the institution should proceed with making any remaining disbursements for the payment period, and then follow steps one through three above. To determine whether a student has withdrawn from a payment period or period of enrollment, please refer to 34 CFR 668.22.
The CARES Act also directs the Secretary to waive student grant overpayments that result from the R2T4 process for students who withdraw as a result of COVID-19-related circumstances. If a student’s grant overpayment has been waived in accordance with this provision, an institution is not required to notify the student or the National Student Loan Data System (NSLDS) of the overpayment or refer any portion of the overpayment to the Department. In addition, an institution must not apply any Title IV credit balance to pay down the grant overpayment. An institution must document in the student’s file when it applies this waiver as a result of the CARES Act. If an institution has already returned the amount of a student overpayment on behalf of a student, it should re-request those funds in the same manner as described above for Title IV funds that the institution was otherwise required to return under normal R2T4 requirements.
Interaction with Tuition Refund Requirements
The Department’s R2T4 provisions do not affect institutional refund policies. However, some institutions or states may have policies requiring the refund of some or all of a student’s tuition charges if the student withdraws during a certain period of time. If a student who qualifies for CARES Act R2T4 relief withdraws and is granted a tuition refund, the refund may create a Title IV credit balance that must be provided to the student within 14 days.
For example, consider a student who withdraws during the first week of a semester as a result of COVID-19 disruptions. The student was originally charged $10,000 in tuition and received $5,000 in Pell Grant funds and $3,500 in a Subsidized Direct Loan. When the student withdraws, the tuition refund policy will result in a refund of $9,000 in tuition, leaving only $1,000 in charges on the student’s account. Furthermore, because R2T4 requirements will be waived, the student will still have a total of $8,500 in Title IV funds on his or her account, resulting in a Title IV credit balance of $7,500 that must be paid to the student within 14 days of the refund.
Institutions may choose to amend tuition refund policies to all students in a given program if such changes are documented and disclosed to students, although students may have rights under state law to enforce an institution’s refund policy for a payment period that was started under an existing refund policy. An institution may not amend its tuition policy on a student-by-student basis based on the amount of Title IV aid that the student receives as a credit balance as a result of the CARES Act R2T4 waiver.
The CARES Act requires an institution to report to the Department information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn). The Department has determined that reporting requirements under the CARES Act include:
· Identifying information for each student for whom R2T4 was waived under the CARES Act;
· The payment period “begin” and “end” dates for the period that the student did not complete as a result of the COVID-19 emergency;
· The amount of Title IV grant or loan assistance (other than Federal Work Study funds) that each such student received for the payment period in which he or she withdrew; and
· The total amount of Title IV grant or loan assistance that each institution has not returned to the Secretary as a result of the CARES Act provisions.
Institutions should retain this information for each student who withdraws and qualifies for an R2T4 waiver under the CARES Act, and should plan to provide, for each student, identifying information, payment period begin and end dates, and information regarding the Title IV grant and loan disbursements (except for Federal Work Study) that the student received for the payment period.
In order to fulfill the third reporting requirement, an institution must determine the total amount of grant and loan assistance that otherwise would have been returned, identified in Step 5 of the R2T4 calculation, had the calculation been performed. Therefore, it will continue to be necessary for institutions to perform an R2T4 calculation for each student covered by the CARES Act R2T4 waiver.
Upon receipt of information from an institution indicating that a covered student has withdrawn, the Department will cancel the entire amount of any disbursement of a Direct Loan borrowed by the student or his or her parent for the payment period or period of enrollment. Additionally, under Sections 3506 and 3507 of the CARES Act, the Department will exclude from a student’s Subsidized Loan usage and Pell Grant lifetime eligibility used (LEU) any payment period that the student does not complete due to a qualifying emergency. Additionally, the Department will cancel disbursements of TEACH Grants received by a covered student for the payment period or period of enrollment from which the student withdrew and restore grant eligibility for that amount.
The Department is developing the process by which institutions will fulfill the reporting requirements described above and will provide additional guidance about these requirements in the future. Note that because it will take time to develop a reporting process and provide relief from Pell lifetime eligibility requirements, subsidized usage requirements, and loan obligations in these circumstances, we ask institutions and students to be patient while we develop a process to provide this relief.
Qualification for R2T4 Relief
Any institution that moved students from ground-based instruction to distance learning, closed campus housing or other campus facilities, or experienced other interruptions in instruction may consider all withdrawals from students enrolled in ground-based instruction during the covered period to have been the result of circumstances related to the COVID-19 national emergency. For institutions that did not undergo changes in educational delivery or campus operations as a result of the COVID-19 emergency, the institution will be required to obtain a written attestation (including by email or text messages) from the student explaining why the withdrawal was the result of the COVID-19 emergency. Institutions must also obtain written attestations from students who withdrew from distance education programs explaining why the withdrawal was the result of the COVID-19 emergency.
Allowable circumstances include, but are not limited to, illness of the student or family member, need to become a caregiver or first responder, loss of childcare, economic hardship, inability to access wi-fi due to closed facilities, or an increase in work hours as a result of the COVID-19 emergency. Information (which in the judgment of the institution is reliable) provided by the family member of a withdrawn student whom the institution is unable to contact is acceptable for documentation purposes.
Satisfactory Academic Progress (SAP)
Section 3509 of the CARES Act allows institutions to exclude from the quantitative component (pace measurement) of satisfactory academic progress (SAP) attempted credits a student was unable to complete as a result of the COVID-19 national emergency. It is not necessary for a student to have filed a SAP appeal for an institution to exercise this flexibility. However, to exclude attempted credits from SAP, an institution must have reasonably determined that the student’s failure to complete those credits was the result of a COVID-19 related circumstance. Allowable circumstances include, but are not limited to, illness of the student or family member, need to become a caregiver or first responder, economic hardship, added work hours, loss of childcare, inability to continue with classes via distance education, inability to access wi-fi due to closed facilities. If an institution temporarily ceases operations during a period of enrollment, attempted credits for all affected students (specific to that enrollment period) may be excluded.
Regarding the effect of excluding attempted credits on maximum timeframe, SAP regulations require that the pace at which students progresses through the program ensures completion of that program within the maximum timeframe. A four-year program consisting of 120 credit hours with a maximum timeframe of 180 credit hours (150 percent of program length) must have a pace of 66.666 percent (rounded to 67 percent), cumulatively measured at each interval, to ensure students complete within maximum timeframe. For example, the pace of a student who has completed 78 of 120 attempted hours is 65 percent (78/120), below what is necessary to be making SAP. However, if 12 credits the student attempted but was unable to complete in spring of 2020 are excluded due to a COVID-19 related circumstance, the pace becomes 72 percent (79/108) and he or she is making SAP. The 12 credits are effectively excluded from the maximum timeframe as well as the measurement of pace.
Title IV, HEA Programs
Teacher Education Assistance for College and Higher Education (TEACH) Grant Program
The CARES Act provides that, if previously qualifying teaching service becomes part-time or is temporarily interrupted as a result of a qualifying emergency, that teaching service is considered full-time and fulfills the service obligation requirement under section 420N of the Higher Education Act of 1965, as amended.
Currently, under 34 CFR 686.40, for purposes of completing and documenting the teaching service obligation, an elementary or secondary academic year may be counted as one of the TEACH grant recipient’s four complete elementary or secondary academic years if the grant recipient’s employer considers that he or she has fulfilled the contract requirements for the academic year for the purposes of salary increases, tenure, and retirement in circumstances where the grant recipient is unable to complete an elementary or secondary academic year due to:
· A condition that is a qualifying reason for leave under the Family and Medical Leave Act of 1993 (FMLA) (29 U.S.C. 2612(a)(1) and (3)).
· A call or order to Federal or State active duty, or Active Service as a member of a Reserve Component of the Armed Forces named in 10 U.S.C. 10101, or service as a member of the National Guard on full-time National Guard duty, as defined in 10 U.S.C. 101(d)(5).
The CARES Act provides that, during a qualifying emergency, the Department may modify the categories of extenuating circumstances under which a recipient of a TEACH Grant who is unable to fulfill all or part of the recipient’s teaching service obligation may be excused from fulfilling that portion of the service obligation. A TEACH Grant recipient who was performing qualifying service that was interrupted due to the COVID-19 national emergency will receive credit for a full year of his or her service obligation.
Key things to note:
- Your institution must have entered into the Funding Certification and agreement for Emergency Financial Aid Grants to Students before submitting the second Certification and Agreement for Recipient’s Institutional Cost. A copy of the Institutional agreement can be retrieved here.
- The Secretary encouraged schools to use these funds to expand your remote learning programs, build your IT capacity to support such programs, and train faculty and staff to operate effectively in a remote learning environment. She also encouraged schools to use these funds if possible, to give additional aid to your students. A copy of the Secretary’s letter can be read here.
- Institutions cannot use these funds for expenditures toward senior administrator and/or executive salaries, benefits, bonuses, contracts, incentives; stock buybacks, shareholder dividends, capital distributions, and stock options; and any other cash or other benefit for a senior administrator or executive.
- You must submit this new Certificate and Agreement to the grants.gov website [https://www.ed.gov/about/offices/list/ope/caresact.html] The Opportunity Grant Id number is ED-Grants-042120-004, the steps on gants.gov are very similar to the steps for the student portion of the funds.
- There are additional FAQs provided by the Department for both the Student and the Institution portion of the funds.
- The final institutional allocated amounts are also provided on the Department’s COVID page and can be viewed here.
- Campus Ivy would like to clarify that while a student does not need to be a Title IV recipient to receive these funds, they must be Title IV eligible. This is defined as a student with a completed Free Application for Federal Student Aid (FAFSA) or one who is eligible to complete the FAFSA. Therefore, students that are not eligible for the grant would be international students, or ineligible non-residents, or individuals that do not have a high school diploma or its equivalent, etc.
Campus Ivy COVID Webinar
Scroll down for most recent webinars
Campus Ivy hosted a webinar on March 30th, 2020, to arm our schools with the right tools to package their students remotely. The webinar covered using the mobile friendly Campus Ivy Core Student Portal effectively.
You can view a copy of the webinar at the link below:
The entire webinar video can be viewed here. [https://youtu.be/WKmJ8Q_JEnY]
Campus Ivy Webinar on April 29th, 2020 (3:00PM - 4:30PM), on COVID-19 CARES ACT EMERGENCY GRANT - Student Portion.
The entire webinar video can be viewed here. [https://transcripts.gotomeeting.com/#/s/65e27b5decd637751d6e65441d340fbe177016701a01e1ef6faf9f95ce91d6e8]
Campus Ivy webinar on May 6th, 2020 (2:00PM - 3:30PM), on COVID-19 CARES ACT EMERGENCY GRANT - Institution Portion.
Campus Ivy webinar on May 13th, 2020 (2:00PM - 3:30PM), Rountable discussion on COVID Guidance
Session Recording: https://transcripts.gotomeeting.com/#/s/0fae459c8a509493df4fb5621367384ab8974db9ad6470928e370e71bbd9beaf
Campus Ivy webinar on May 27th, 2020 (2:00PM - 3:30PM), COVID Guidance
Session Recording: https://transcripts.gotomeeting.com/#/s/f8e6a07710ad48e049ab446e39dc07d88c9dbf892aaba7248cca58b3fe2bce77
Campus Ivy webinar on Feb 10th, 2021 (2:00PM - 3:30PM), HEERF Grant II
Session Recording: https://transcripts.gotomeeting.com/#/s/bca886ee45f3a952bf2f76c146f7876f3cb641d98179511c0e595e802a0934ad
Campus Ivy will be presenting additional webinars, look out for the invites to come.
Campus Ivy COVID Guidance
Update on Required CARES Act Quarterly Reporting
Section 15011 of Division B of the Coronavirus Aid, Relief, and Economic Security (CARES) Act requires that a grantee which receives more than $150,000 report to the U.S. Department of Education (Department) on a quarterly basis. The Department, after consultation with the Office of Management and Budget, currently interprets this CARES Act quarterly reporting requirement to be satisfied through existing federal reporting mechanisms. Specifically, CARES Act quarterly reporting requirements are considered to be met under the more frequent, monthly reporting requirements of the Federal Funding Accountability and Transparency Act of 2006 (FFATA), Pub.L. 109-282, as amended by the Digital Accountability and Transparency Act (DATA Act), Pub.L. 113-101.
FFATA is aimed at empowering citizens with information needed to hold the government accountable for the award of taxpayer funds to individual grantees. Towards this end, FFATA requires that information on federal awards (federal financial assistance and expenditures) be made available to the public via a single, searchable website, which is www.USASpending.gov.
Through the FFATA Subaward Reporting System (FSRS), federal prime awardees (i.e., prime contractors and prime grants recipients, including CARES Act grantees for the programs listed below) capture and report subaward and executive compensation data regarding first-tier subawards to meet FFATA reporting requirements on a monthly basis. The following data elements are collected through FSRS about subawards greater than $25,000:
- Name of entity receiving award
- Amount of award
- Funding agency
- North American Industry Classification System (NAICS) code for contracts / Catalog of Federal Domestic Assistance (CFDA) program number for grants
- Program source
- Award title descriptive of the purpose of the funding action
- Location of the entity (including congressional district)
- Place of performance (including congressional district)
- Unique identifier of the entity and its parent
- Total compensation and names of top five executives (same thresholds as for primes)
CARES Act grantees under the following programs must meet their monthly reporting requirements under FFATA to meet their Section 15011 requirements under the CARES Act for quarterly reporting:
· Higher Education Emergency Relief Fund (CFDA 84.425E, 84.425F, 84.425J, 84.425K, 84.425L, 84.425M and 84.425N)
· Governor’s Emergency Education Relief Fund (CFDA 84.425C)
· Elementary and Secondary School Emergency Relief Fund (CFDA 84.425D)
· Gallaudet University Grant (CFDA 84.910B)
· Howard University Grant (CFDA 84.915A)
· Education Stabilization Fund – Reimagine Workforce Preparation Discretionary Grant (ESF-RWP) (CFDA 84.425G)
· Education Stabilization Fund – Rethink K-12 Education Models Discretionary Grant (CFDA 84.425B)
· Project School Emergency Response to Violence (Project SERV) (CFDA 84.184C)
· Education Stabilization Fund Program Outlying Areas-State Educational Agency (CFDA 84.425A)
· Education Stabilization Fund Program Outlying Areas-Governors (CFDA 84.425H)
The entity that receives federal funds is ultimately responsible for completing FFATA reporting; prime grantees are responsible for following required processes and procedures to enter data into FSRS, which may include identifying the appropriate State, local, or institutional office or individual charged with meeting FFATA requirements. In meeting their reporting requirements under Section 15011 of the CARES Act, prime grantees should review their FFATA reporting to ensure the data they submit is complete, accurate, and of high quality.
For more information on FFATA, please visit https://www.fsrs.gov/.
In accordance with Recipient’s Funding Certification and Agreements executed by grantees for CARES Act funding, the Secretary of Education is planning to specify additional forms of reporting on a less-than-quarterly basis (such as on an annual or semi-annual basis) to ensure full CARES Act compliance and full implementation of the signed agreements. This reporting will likely include collecting recipient jobs data (e.g., number of jobs created or retained). Any additional reporting through this process will be announced in the Federal Register and the public will have the opportunity to comment on it
CARES ACT -- Return to title IV and Refund Waivers
President Donald Trump signed the third COVID-19 relief package Friday, which was passed by Congress last week after a series of long negotiations. The $2 trillion dollar bill — dubbed the Coronavirus Aid, Relief, and Economic Security (CARES) Act — allocates $14 billion to higher education, and includes multiple provisions related to student aid, such as ensuring students who had to leave school because of the coronavirus will not be penalized.
SEC. 3508. INSTITUTIONAL REFUNDS AND FEDERAL STUDENT LOAN FLEXIBILITY of the CARES Act also allows ED to waive the return of Title IV funds (R2T4) requirements for schools or students to return unearned grant or loan assistance for students who withdrew because of a qualifying emergency. The bill would provide loan cancelation for the portion of a Direct Loan associated with a payment period which the student did not complete due to a qualifying emergency. Each institution who uses a waiver under this section must report to ED the number of recipients who received waivers, the amount of grant or loan assistance associated with each recipient, and the total amount of grant or loan assistance that the institution has not returned under Title IV.
To assist our schools with this section of the Act, Campus Ivy has developed the attached process and form to allow our schools to notify us of any waivers they have granted their students. Please review the instructions on the form and contact email@example.com if you have any questions.
WASHINGTON — U.S. Secretary of Education Betsy DeVos announced yesterday that nearly $1.4 billion in additional funding will be directed to Minority Serving Institutions (MSIs), including Historically Black Colleges and Universities (HBCUs) and Tribally Controlled Colleges and Universities (TCCUs), as well as institutions serving low-income students to help ensure learning continues during the coronavirus national emergency. The HEER Fund also sets aside 2.5 percent of the HEER Fund ($349 million) to address the greatest unmet needs related to the coronavirus, giving priority to schools that have not been allocated at least $500,000 from the fund. The Department is deploying these funds to ensure that every eligible public and private nonprofit institution will receive at least $500,000 in CARES Act relief funding.
Key things to note:
Campus Ivy notes that several of our schools have been included on these lists for additional funds. Please review the attached allocation list to see if you have been allocated additional funds.
- The Excel Allocation list covers 18004(a)(2) – These funds are for HBCUs, TCCUs, and MSIs
- The PDF allocation list is specific to 18004(a)(3) and covers schools that previously received less than 500K. It shows the additional allocation you can apply for as well as any prior amounts you were allocated.
- Some schools are listed on both allocations lists, if you are then the PDF list gives you all your allocations listed in one place.
- Some schools are not listed on either lists, if so then you did not qualify for any additional funds and there is no action you need to take.
- Your institution must have entered into the Funding Certification and agreement for Emergency Financial Aid Grants to Students and Institutions before submitting the Certification and Agreement for these additional funds. A copy of the Institutional agreement can be viewed here.
- Institutions may use this funding to cover the cost of technology associated with a transition to distance education, grants to cover the costs of attendance for eligible students, and faculty and staff trainings. Additionally, funds may be used to cover operational costs, such as lost revenue, reimbursements for prior expenses, and payroll. The Secretary encouraged schools to use these funds if possible to give additional aid to your students. A copy of the Secretary’s letter can be viewed here.
- Institutions cannot use these funds for expenditures toward senior administrator and/or executive salaries, benefits, bonuses, contracts, incentives; stock buybacks, shareholder dividends, capital distributions, and stock options; and any other cash or other benefit for a senior administrator or executive.
- You must submit this new Certificate and Agreement to the grants.gov website [https://www.ed.gov/about/offices/list/ope/caresact.html] for each allocation separately. The Opportunity Grant Id number are as follows,
- ED-Grants-043020-001 for Historically Black Colleges and Universities (HBCU)
- ED-Grants-043020-002 for Tribally Controlled Colleges and Universities(TCCU)
- ED-Grants-043020-003 for Minority Serving Institutions (MSI)
- ED-Grants-043020-004 for Strengthening Institutions Program (SIP)
- ED-Grants-043020-005 for Fund for the Improvement of Postsecondary Education (FIPSE)
Here are key takeaways from the Higher Education Emergency Relief Fund authorized by the Coronavirus Aid, Relief, and Economic Security (CARES) Act
- In order to access these funds, all institutions must sign and return the Certificate of Funding and Agreement via: grants.gov (https://www.grants.gov/web/grants/applicants/registration.html), acknowledging the terms and conditions of the funding. You will need to register on the website, just follow the steps provided.
- It is critical that you fully read and understand all agreements on the document before you sign and submit it to the Department.
- After the Department has received the certificate, institutions may draw down their emergency assistance funds using the Department’s G5 system.
- For full service schools - Campus Ivy will draw the funds once they are available in your account. We will upload the confirmation with a copy of the grant agreement as supporting documentation for the draw.
- For Software only schools – You will have access to draw these funds as you do today.
- The CARES Act provides institutions with significant discretion on how to award this emergency assistance to students. This means that each institution may develop its own system and process for determining how to allocate these funds, which may include distributing the funds to all students or only to students who demonstrate significant need.
- Campus Ivy recommends following the regulatory standard of treating all similar type students the same, so develop a method where you identify your most neediest students and allocate an amount similar to the maximum Pell award for the year. Try to help as many students as possible.
- The only statutory requirement is that the funds be used to cover expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student’s cost of attendance, such as food, housing, course materials, technology, health care, and child care).
- Campus Ivy recommends that you review your Indirect costs for your students when setting the maximum amount per student.
- Campus Ivy recommends that you track the distribution of these funds to your students. Develop a new code so you can post the funds to the student’s ledgers and then issue credit balance checks. You should issue the credit balance checks for the full amount of the disbursement whether there is a balance on the student’s ledger or not. You will be required to report these funds starting 45 days after you receive them and then every 30 days after that.
- The Department has not yet defined how they will require you to report so ensure that you are accurately tracking these funds.
- If you determine that your institution’s students do not have significant financial need at this time, I would ask that you consider giving your allocation to those institutions within your state or region that might have significant need.
- The expectation is that all funds will be spent within one year from the date you receive the funds.
- This will be 50% of the total grant amount for your school, the Department will issue an update once they are ready to issue the 2nd 50% which will be distributed to you for your institution.
- A copy of the Secretary’s letter, the certificate and agreement form, and the allocations per school have been attached to this email for your reference.
- Campus Ivy will announce a webinar on this topic once the Department’s further issues guidance on the remaining 50% of the stimulus grant. We will continue to hold these webinars as more updates are forthcoming.
Great news, the Grant.gov website will now accept your Recipient’s Funding Certification and Agreement. Please see additional guidance below to help you successfully submit your documents.
- The person that completes your SAM.gov registrations will be the person with the right access to complete the process on Grant.gov. If that person cannot complete the process then they will need to give someone else the access by adding them to Sam.gov and then going to Grant.gov and updating the access there as well. See screenshot below with arrow showing the link to make updates to access, ‘Login as EBiz POC’.
- Once you login then navigate to the search for Grant page and search for ‘041020-003’ grant number. The grant will appear and then you can click on the grant to access the grant page.
- Once you are on the Grant page then click the APPLY button toward the top of the page. This will take you to a screen with 3 hyperlinks,
- Completing the Application for Federal Assistance (SF-424).
- Completing the Department of Education Supplemental Information Form for the SF-424.
- Link to Upload Attachments
Frequently Asked Questions
- Q: I don’t see my school on the allocation list, how do I know how much I will receive.
A: Only the schools on the list have been allocated funds from this Emergency Grant. If you have questions on why you did not receive an allocation, please contact your Federal Student Aid Regional Office.
- Q: Can I use some of these funds to reimburse my school for expenses related to COVID-19?
A: No, this first 50% of the grant must all go to your students. There will be a second 50% released for your school expenses. The Department has not yet released the date of when those funds will become available.
- Q: Can I only award these funds to our Pell students or only Title IV recipients?
A: No, you can award all Title IV eligible students at your school that have a need because of the COVID-19 pandemic. Even your cash paying students can receive these funds. The only requirement is that the student has completed the FAFSA or is eligible to complete the FAFSA.
- Q: How do I calculate how much each student is eligible for?
A: Schools have a lot of flexibility on how much to award each student. The goal is to assist the most neediest students but it is possible that all your students have a need. We are sharing the CARES ACT - Guide for the Distribution of Student Grants under the Higher Education Emergency Relief Fund developed by the policy makers at Career Education Colleges and Universities (CECU). Along with other helpful information, this document also gives you a few options to consider when developing your formula.
- Q: How should I record these in our system and what do I need to share with Campus Ivy.
A1: Campus Ivy recommends that you record each disbursement made to the student on their student ledger account. You would disburse the funds to the account as ‘COVID Emergency Grant Funds’ and then also record on the ledger the check issued to the student as ‘Student Check – COVID Emergency Grant’. None of this fund can be used to reduce a student’s balance owed to the school. This allows you to properly account for the funds when you need to report them to the Department.
A2: You do not need to send any of this information to Campus Ivy at this time. We will update you once the Department releases the reporting requirements. If you choose to have your students complete a form for these funds, then you should upload a copy to the Core system.
- Q: When will I receive the money? Has any school received their funds?
A1: You will receive an email directly from the Grants.gov website as your application gets updated and funds are disbursed. Please share this email with Campus Ivy once you receive it at firstname.lastname@example.org. Campus Ivy will also be checking all G5 accounts each day to see if any funds have been released. We will draw the funds and upload confirmation to Core. Additionally, we will email the school directly when these funds are received.
A2: We have not yet received any funds for our schools.
- Q: How do I log onto the Grants.gov website, I am having issues submitting my application.
A: We have attached to this email prior guidance on getting the proper access to the Grants site. Please note that you must be registered on SAM.GOV to have the right access to Grants.gov. Both sites have contact numbers that you can call to get additional guidance.