Higher Ed: Extend the HEERF III Deadline to Spend Down Funds

Institutions that received Higher Education Emergency Relief Fund III (HEERF) funding and have yet to spend down all allocated funds may be eligible to request a one-time no-cost extension (NCE). 

The HEERF III program was authorized by the American Rescue Plan (ARP) in 2021, providing $39.6 billion to higher education institutions to support students and learning through the COVID-19 pandemic. This third phase of the HEERF funding program added to the $14 billion under HEERF I, authorized by the Coronavirus Aid, Relief and Economic Security (CARES) Act, and $21.2 billion under HEERF II, authorized by the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA).

The U.S. Department of Education (DOE) strongly encourages grantees to spend their remaining emergency dollars before June 30, but for those that may not be able to, there is this one-time opportunity to submit an NCE request. The deadline is June 20 and, if approved, will allow institutions an additional six months, through Dec. 31, 2023, to spend down funds for student awards, and twelve months, through June 2024, to spend down funds for institutional awards. 

Guidelines for Requesting the NCE

Institutions must submit requests for an extension to their assigned program specialists and include the name of the institution, the PR Award number, and the following “focus on four” items, per the 2023 HEERF Updates PowerPoint presented by the HEERF program director in March. These four items include: 

1. Project scope – Submit a detailed narrative clearly explaining the need for the NCE
2. Cost – Provide award balance details and how IHE will spend remaining funds
3. Time – Offer a realistic timeline for completion
4. COVID-19 – Explain how the expenses connect to, prepare, prevent, and respond to COVID-19

HEERF program specialists will confirm receipt of requests via email and will review and render a determination on NCE requests within 30 days. 

Requirements and Reminders for Those Considering an NCE

• For higher education institutions considering an NCE, there are parameters to keep in mind with regard to the program and its deadlines, including:
• The deadline for making purchases with HEERF III funds can be extended to June 2024, but only for those that have developed a plan for spending the money (in accordance with the “focus on four” above) and have submitted it to their program specialists by June 20.
• A one-time NCE for HEERF III must also be in compliance with the NCE requirements detailed in 2 CFR 200.308I(2) and 34 CFR 75.261.
• In addition, grantees (i.e., HEERF III recipients) must comply with the cost principles contained in the 2 CFR part 200 subpart E of the Uniform Guidance. Examples of costs specifically prohibited under the Uniform Guidance include using grant funds for lobbying, bad debts, or purchasing goods or services for personal use. 
• Under the American Rescue Plan, allowable uses under the HEERF III (a)(1) Institutional Portion awards include: 
  • Defraying expenses associated with COVID-19 (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, indirect costs, and payroll)
  • Making additional emergency financial aid grants to students

Further, there are numerous purposes for which HEERF III grant funds may not be used, including: 

• Funding contractors for the provision of pre-enrollment recruitment activities
• Marketing or recruitment
• Endowments
• Capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship
• Senior administrator or executive salaries, benefits, bonuses, contracts, incentives, stock buybacks, shareholder dividends, capital distributions, and stock options, or any other cash or other benefit for a senior administrator or executive
• Religious worship, instruction, or proselytization or equipment or supplies to be used for religious worship, instruction, or proselytization
• Construction or purchase of real property

Finally, HEERF reporting requirements will still apply to NCEs that receive grants, so institutions should keep abreast of these requirements, including:

• Deadlines: HEERF reports are due quarterly and must be posted to each institution’s primary website no later than 10 days after the calendar quarter (i.e., Jan. 10, April 10, July 10, and Oct. 10). The combined institutional and student report form should be used for this. 
• Performance: All institutions are required to submit HEERF annual performance reports via the Annual Report Data Collection System. The exact period for reporting will be forthcoming. 

The Mechanics of Closing Out HEERF Grants

If an institution is instead winding down its HEERF grants and is looking to close out the grants, requirements described in 2 CFR § 200.344 need to be followed, including:

1. Contacting the DOE program contact listed in Box 3 of the Grant Award Notification
2. Ensuring that remaining funds for expenditures incurred during the grant period of performance have been liquidated
   1. Per recent changes to the Uniform Guidance, institutions now have 120 calendar days to liquidate all financial obligations incurred under the award after the period of performance.
3. Ensuring that all quarterly reporting is properly posted online publicly and submitted to the DOE as required by the HEERF Quarterly Reporting requirements
   1. Please note that public quarterly reports should remain online for a period of at least three years after the submission of the last quarterly or annual performance report. 
4. Submitting the annual performance report for the last period of grant performance when the DOE opens the system for annual performance reporting
   1. Please note that in the 2024 HEERF annual report (calendar year 2023), the DOE intends to remove the “Students not categorized in IPEDS” as a category in questions 8e and 8f. Accordingly, institutions must begin tracking race/ethnicity, gender, and age for all students—including noncredit students—at the beginning of 2023 so they can appropriately report disaggregated data in the 2024 annual report.
5. Maintaining all grant financial records, supporting documents, statistical records, and all other entity records pertinent to the HEERF grant award for a period of three years from the date of submission of the last quarterly or annual performance report per 2 CFR § 200.334

As with any federal funds program, there can be lengthy reporting and compliance guidelines to follow. Higher education institutions looking to maximize their chances of getting approval will need to provide a compelling reason for the request, backed up by a narrative that explains how the rest of the monies will be disbursed. Once an extension is granted, institutions will need to make sure they stay in compliance with the requirements of the program as outlined above.  

Sources:

1. 2023 HEERF Updates
2. Fact Sheet: New Data Show the American Rescue Plan and Other Pandemic Relief Funds Have Helped 18 Million College Students
3. Higher Education Emergency Relief Fund 2021 Annual Performance Report
4. NASFAA HEERF Reporting Guidelines
5. HEERF 2023 Annual Reporting Opens in March