Amount of HEERF III Funds Spent: $24,915,024
Number of students awarded: 14,023
Eligible students: 44,472
The American Rescue Plan Act of 2021 (ARP) was signed on March 11, 2021, and includes approximately $39.6 billion for the Higher Education Emergency Relief Fund (HEERF) and represents the third stream of funding appropriated for HEERF to prevent, prepare for, and respond to coronavirus. Together, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), the Coronavirus Response and Relief Supplemental Act, 2021 (CRRSAA), and the ARP represent HEERF I, HEERF II, and HEERF III, respectively. The University of Oklahoma was awarded $49,592,175 in total HEERF III funds.
The HEERF III program requires at least half of the institution’s allocation under ARP (a)(1) must be used to make emergency financial aid grants to students. The minimum amount that was calculated by the Department of Education that the University of Oklahoma must use for financial aid grants to students must be at least $24,915,024. The allowable uses of the ARP funds are similar to the CRRSAA requirements.
Under the ARP, a student is now defined as any individual who is or was enrolled at an eligible institution on or after March 13, 2020, the date of declaration of the national emergency due to the coronavirus, regardless of whether they completed a FAFSA or are eligible for Title IV aid. The HEERF III student aid grants are available to all students, which now includes international or Deferred Action for Childhood Arrival (DACA) students. As with CRRSAA, institutions are directed with the ARP funds to prioritize students with exceptional financial need, such as those who are eligible for Federal Pell Grant funds.
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 health care), and child care. As with CRSSAA, ARP does not allow emergency financial aid grants to satisfy a student’s outstanding account balance, unless the institution has obtained the student’s written (or electronic) affirmative consent.
We are proposing that the university spend the ARP funds in a phased approach identified as follows:
PHASE I: Identify students with:
Award a block financial aid grant of $1,500 per student. Disburse Phase I during the week of August 16, 2021.
PHASE II(a): Identify students with:
Award a block financial aid grant of $2,250 per student.
PHASE II(b): Identify students with:
Award a block financial aid grant of $1,800 per student.
Students that do not meet the criteria to be awarded during Phases I or II will be able to request HEERF III funds by submitting an online application. Applications for Phase III will be reviewed and awarded subsequent to the completion of Phase II. This population includes students enrolled in Fall 2021, that are non-FAFSA filers, DACA students, international students, and students who filed a FAFSA but have an EFC greater than 5846. These funds will be awarded on a first-come, first-served basis until the student allocation of HEERF III funds are fully exhausted.
PHASE III: Student submits an online application utilizing single sign-on credentials. The application simply contains statements that the student attests to in order to apply for HEERF III funds and record their request for the funds. With indicators for YES/NO responses, attestation statements include:
Verification of the above student attestations will be done by the Financial Aid Office staff to ensure enrollment and that the student has not previously received HEERF III funds. No student will be eligible to receive HEERF III funds in both Phase II and Phase III of the disbursement plan. Once Fall 2021 enrollment and no previous receipt of HEERF III funds is verified, the student will be awarded a block financial aid grant of $1,000 per student. Domestic students who can verify that they were not eligible to file a FAFSA (includes refugees, asylum seekers, Deferred Action for Childhood Arrival (DACA) recipients, other DREAMers, and similar undocumented students), are enrolled for Fall 2021 at the time of the award, and have not received previous HEERF III funds will be awarded a financial grant of $2,250. Disbursement of Phase III awards will continue during the remainder of the Fall 2021 term, until the student portion of the HEERF III funds are depleted.
HEERF III 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 and are not subject to reporting on the 1098-T Tuition Statement.
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 versus no consent required and the refund is sent directly to the student.
Our recommendation is to email the students who are determined eligible to receive the HEERF III emergency grants under Phase I and Phase II 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.
10/04/2021 Approved by CARES Committee, Legal and Internal Audit