The Latest in Additional HEERF Regulatory Guidance

The Department of Education (DE) has released additional regulatory guidance and an allocation table in an FAQ document about the latest round of Higher Education Relief Fund (HEERF) aid passed as part of the American Rescue Plan Act (ARPA). This guidance provides clarity as to which portion of the allocation must be spent on additional emergency grants to students and which is available for institutional purposes.

We previously covered the basics of HEERF and HEERFII. However, this guidance provides details on both the allocation and reporting that were not available at that time. Major elements of this most recent guidance center around the usage of the institutional portion of the allocation, emergency grants to students, and a few new required uses of the funds.

Below we’ve outlined some of the most significant and relevant points of this new guidance.

Institutional Portion

  • Guidance is consistent with earlier guidance with regards to allowable and unallowable uses.
  • Funds cannot be used for the purchase or construction of real property.
  • Funds can be used to discharge student debt.
  • Funds can be used to offset costs associated with the transition to remote learning.
  • The guidance reiterates that funds must be spent within one year from the date when the DE processed them.

Emergency Grants to Students

  • Addresses questions concerning whether international or Deferred Action for Childhood Arrival (DACA) students are eligible to receive emergency financial aid under the HEERF programs
  • Prioritizes emergency grants to students with exceptional need
  • Reiterates that emergency grants to students are not taxable income to them

New Required Uses of Funds

  • Requires funds to be used for “the implementation of evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines”
  • Requires funds to be used for “direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances”


  • DE has also provided an updated quarterly reporting form for HEERF institutional aid.
  • Quarterly reports are still required for both the institutional and student portions of an allocation. Each report is separate for the calendar quarter reporting period and not cumulative.
  • Annual reporting requirements have not yet been announced.

NACUBO has summarized much of the new guidance in their recent article. Your higher education CPA can help you navigate these latest developments and see how they apply to your institution. Please contact us with any questions.

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