HEERF II

Amount of HEERF II Funds Spent: $8,967,765.00

Number of students awarded: 8,433

Eligible students:  44,472

Overview

The Consolidated Appropriations Act, 2021 (pdf) included additional COVID-19 relief through the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act. This new COVID stimulus bill included $23 billion for higher education institutions and students, using the same Higher Education Emergency Relief Fund (HEERF) model established in the Coronavirus Aid, Relief and Economic Security (CARES) Act.

The University of Oklahoma was awarded $27,880,322 in total HEERF II funds.

Allowable Uses

Institutions must spend at least the same dollar amount on student grants as they were required to spend under the CARES Act. Total HEERF II funds that must be spent on student grants must be at least $8,967,765. In addition, the allowable uses of funds are more flexible than in the CARES Act. 

Student Eligibility

Similar to CARES, the CRRSAA includes no student eligibility requirements, however, institutions are required to prioritize grants to students with exceptional financial need, such as those who receive Pell Grants. The HEERF II funds can be awarded to online students, as well as qualified aliens, including refugees and persons granted asylum. It is believed that the Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) of 1996, which prohibits certain noncitizens from receiving federal benefits, applies to HEERF II funds, making DACA, undocumented, and international students ineligible.

Student Fund Uses

Students may use the grants toward any component of their cost of attendance.  Funds can also be used for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care (including mental) and childcare.  In the CRSSAA, there was an expansion of the grant provision permitting institutions to apply the emergency grants to a student’s account – only after receiving written (or electronic) affirmative consent from the student.  This could potentially be payments received for qualified tuition and related expenses that will have 1098-T reporting requirements, yet to be determined by the IRS.

HEERF II Emergency Grant Student Eligibility: 

Because US citizenship status must be confirmed for HEERF II eligibility, students enrolled in Norman campus programs or Health Sciences Center programs for the Spring 2021 term must have an official FAFSA on file for Aid Year 2020-2021 with no US citizenship issues that require resolution.  The university will set aside funds from the institutional portion of the HEERF II grant monies to award in the event that any qualified aliens are documented after the initial awards to students.

The University defines “exceptional need” as students with an Expected Family Contribution (EFC) of less than 5712.  While the EFC maximum threshold is in line with Pell Grant eligibility, Pell grant eligibility is not a criterion of HEERF II funds and an EFC of 5711 or less will be used to determine eligibility for undergraduate students and for graduate/professional students.  

We are proposing that the university spend the entire student portion of the HEERF II funds via block grants.  The number of eligible students meeting the criteria with an EFC of 5711 or less for both campus programs as of “specific date” (ex:  03/31/2021) will result in an award amount per student equal to what it takes to spend the entire student portion of the HEERF II funds allocation.  Our current estimate is that grants will be around $1,063.67 per student.     

HEERF II funds are not treated as Estimated Financial Assistance (EFA) when awarding. Additionally, the funds are not be treated as taxable income or untaxed income for Title IV federal student aid purposes.

We recommend these emergency grants be provided directly to the students using the previous process of refunding the credit balance without applying the grant directly to the student’s account balance.  Affirmative consent is required to have the emergency financial aid grants applied directly to the existing account balance.  Requiring student permission adds extra steps in the refund process, including tracking each grant payment to determine if consent was received from the student to apply the grant to the student account (with a possible 1098-T reporting impact for 2021) versus no consent required and the refund is sent directly to the student (not reportable on 2021 1098-T). 

Our recommendation is to email the students who are determined eligible to receive the HEERF II emergency grants and provide them with the exact guidance on the costs the grant is eligible to pay: “any component of the student’s cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care (including mental health care) or child care,” and proceed with the process to award the block grant amount and refund it directly to the students via their Bursar’s accounts without applying the funds to any outstanding balances they may have.

4/9/2021  Approved by CARES Committee, Legal and Internal Audit

Updated May 26, 2021

The Consolidated Appropriations Act, 2021 included additional COVID-19 relief through the Coronavirus Response and Relief Supplemental Appropriations (CRRSA) Act. University of Oklahoma students on all campuses who were enrolled for the Spring 2021 term, with a 2020 – 2021 FAFSA on file, whose eligible citizenship status has been confirmed, have been evaluated for eligibility. Students who are determined to show need, based upon the Expected Family Contribution (EFC), as calculated by the US Department of Education, are deemed eligible to receive a HEERF II Emergency Grant. Eligible students will receive the same amount; there is no application or appeals process.

Updated April 15, 2021