US Department of Education – Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), Higher Education Emergency Relief Fund (“HEERF”)
On Friday, March 27, 2020, the federal government enacted the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). Section 18004 of the CARES Act establishes the Higher Education Emergency Relief Fund (“HEERF”). The HEERF provides emergency funding to institutions of higher education, including funds that must go directly to students in the form of emergency financial aid grants (the “HEERF 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)” (the “HEERF Eligible Expenses”).
- Purpose and Scope
Atlantis University is eligible to receive up to $40,442.50, in HEERF Emergency Student Grant Funds. Under Section 18004(c) of the CARES Act, these funds must be used for HEERF Eligible Expenses
The CARES Act requires that institutions disburse the HEERF Emergency Student Grant Funds to eligible students for HEERF Eligible Expenses. Students in associate’s, bachelor’s, graduate, programs may apply for the HEERF Emergency Student Grant Funds. This policy presents the University’s methodology for determining eligibility under the CARES Act, as well as the process and procedure for distributing and disbursing the HEERF Emergency Student Grant Funds. HEERF Emergency Student Grant Funds cannot be applied by the University toward a student’s account balance.
Under the CARES Act and subsequent administrative interpretation provided by the Department of Education (“ED”), students eligible to receive HEERF Emergency Student Grant Funds (“Eligible Students”) must meet all eligibility criteria listed below:
- Students must have completed a Free Application for Federal Student Aid (“FASFA”) for the 2019-2020 Academic Year and be deemed eligible for Title IV aid.
According to Section 9 of the Department of Education FAQ guidance issued on April 21, 2020, only students who are or could be eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (“HEA”), may receive HEERF Emergency Student Grant Funds.
The University has concluded that the only practicable way to determine that a student is eligible to participate in the Title IV programs and meets all applicable student eligibility requirements is if the student has a completed FAFSA, has received an official Student Aid Report (“SAR”), has a valid Expected Family Contribution (“EFC”) on file for the 2019-2020 Academic Year, and meets all other Section 484 eligibility criteria.
AU students who had not previously submitted a FAFSA are advised to submit a FAFSA no later than 06/15/2020 by contacting FA. Students who submit a 2019-2020 FAFSA after 06/15/2020, may be eligible, pending available funds.
- Students must have been enrolled in a Title IV eligible degree-seeking or certificate program at the time of the Disruption of Campus Operations.
Students who have an effective withdrawal date prior to March 13, 2020 cannot receive HEERF Emergency Student Grant Funds. March 13, 2020 is the date on which on-campus instruction was suspended, disrupting the University’s normal campus operations, as described above, and giving rise to HEERF Eligible Expenses.
- Students must have been enrolled for the Winter 2020 academic term in at least one ground-based class as of March 13, 2020, i.e., not enrolled in an exclusively online program.
- Students must submit a University HEERF Emergency Student Grant Funds application.
- Students NOT eligible for HEERF Emergency Student Grant Funds
Examples of students who are not eligible for HEERF Student Share Grants include: dual-credit high school students; international, undocumented, and DACA students; students enrolled exclusively in an online academic program as of March 13, 2020; and any student who is not eligible to receive Title IV funds.
B. HEERF Eligible Expenses
Eligible Students who have incurred HEERF Eligible Expenses are eligible to receive HEERF Student Share Grant Funds, provided such expenses have not been previously reimbursed by the University.
HEERF Eligible Expenses must have been incurred no earlier than March 13, 2020.
C. HEERF Emergency Student Grant Amounts
Consistent with the ED’s April 9, 2020 letter, the University has decided to prioritize students with the greatest need, but at the same time establish a maximum funding threshold for each student to ensure that these funds are distributed as widely as possible.
For purposes of this policy, the University has determined that EFC is an appropriate proxy for student financial need. The University has also determined that distributing the HEERF Student Share Grant Funds as follows is consistent with the CARES Act and the ED’s guidance:
The funds awarded the student will be distributed over two payments, with the first payment being 50% of the awarded amount and the second payment being the remaining 50%.
Given the number of University students who may be eligible, and depending on the actual number of applications received and the grant funds requested in the applications, and consistent with the goal of prioritizing students with the greatest need, individual award amounts will be vary.
- Applying for a HEERF Student Share Grant
Eligible Students may apply for a HEERF Emergency Student Grant by completing an application that can be found on the University’s website (the “Application”). Once the Application is made available to students, the University will accept such online Applications for an initial period of three weeks, or until June 30th, 2020.
- Documentation to Accompany the Application
As part of their Application, Eligible Students are encouraged to submit receipts, other expense documentation, or an explanation and self-certification as to the HEERF Eligible Expenses listed in the Application.
- Review and Decision
Eligible students will be notified by FA that they need to complete the HEERF Emergency Student Grant Application with supporting documentation no later than June 30th 2020.
The submitted applications with supporting documentation on a rolling basis will be reviewed by the Executive Director, Compliance, Operations Director and FA. The submitted applications will be reviewed as they are received to verify student eligibility and review expense documentation and certifications.
Priority will be given to student requests that directly relate to their academic success with particular emphasis placed on technological needs for online course completion and basic daily necessities such as food and medical needs.
The applications will be ranked ordered based on the amount requested as well as ranking the applications based on lowest to highest EFC until the cumulative grants totals AU awarded amount to disburse.
The University will track each award until the University’s award amount has been attained.
- Disbursing HEERF Emergency Student Grants
The University will make every effort to disburse the HEERF Emergency Student Share Grants as soon as practicable after receiving and reviewing the eligible applications.
The University will disburse the HEERF Emergency Student Grants to students via check. Students will receive an e-mail notification once any disbursement is made.
The payments will be split over two equal payments. The second payment will be provided to the students within 60 days of the initial payments.
Note: In no event shall the Atlantis University apply any portion of such funds to pay down any balance owed by the student to the University. The CARES Act and ED guidance prohibits any such use.