Moneyman's College Financial Aid Blog

IMPORTANT NOTE: The guidance in this post was contradicted by later guidance from the Department of Education. See here for the most recent guidance. This post is left as it was originally published for historical purposes.

…Sometimes it seems like it might be a hurricane.

One day this week in moneyman’s hometown it rained. More than rain, it felt like a torrential downpour. Thunderstorms, tornado watch, lightning flashes and even some small hail. And that was just from some of the phone calls I was part of on Tuesday! The bad weather came through later in the week!

On Tuesday, the Department of Education released more information on the CARES Act emergency funding for students and institution (they have also started to refer to this funding by the name Higher Education Emergency Relief Fund – or HEERF – so we will be too). The information that was released contradicted some of the guidance that had been issued before (including the guidance I shared on the blog). So here is the latest update. Keep in mind this guidance is our best understanding at this time and could be contradicted by later issued guidance.

• Although previous announcements indicated no limitation on which students could receive HEERF funds (“Recipient retains discretion to determine the amount of each individual emergency financial aid grant…” from the agreement), new guidance in the FAQs shows that the Department does not want international students or DACA / Dreamers to qualify for this funding.
• To qualify for HEERF funding, students must have completed or been eligible to complete the FAFSA (and also meet all conditions for financial aid eligibility under section 484 of the Higher Education Act [HEA]). We’ll talk below about what that means, but for now it is important to know that if you want to qualify for this money you will need to complete the FAFSA.
• Students who qualify for HEERF funding will receive this money as a cash grant from their school; the school cannot use the money to pay for tuition or school charges, although once you receive the funding, you can do what you want to do with it (including sending it back to the school to pay for your charges if you so desire).
• Students who were exclusively enrolled in online programs will not qualify for HEERF funding. This does not eliminate students in online courses, just those for whom their entire program is online.

So you may be asking: moneyman, why do I care about any of this? Here’s why: if you have been impacted by the fact that your school’s campus(es) had to close and your classes have had to move exclusively online (and who hasn’t been impacted), you could qualify for a grant to help with your living expenses during this time. Remember from the CARES Act, the point of this $12B program (half of which was to go directly to students) was “to provide 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).”

So how do you qualify? Wit the guidance provided on Tuesday, many schools are going to require that you file your FAFSA (or have already done so) and (as I said before) meet the requirements under section 484 of the HEA. What are those requirements? According to NASFAA’s COVID-19 HEERF page, these include:

• Be enrolled or accepted for enrollment in a degree or certificate program. 
• Not be enrolled in elementary or secondary school.
• For currently enrolled students, be making satisfactory academic progress.
• Not owe an overpayment on Title IV grants or loans.
• Not be in default on a Title IV loan.
• File “as part of the original financial aid application process” a certification that includes
  • A statement of educational purpose.
  • Student’s SSN.
• Be a U.S. citizen or national, permanent resident, or other eligible noncitizen.
• Have returned fraudulently obtained Title IV funds if convicted of or pled guilty or no contest to charges. 
• Not have fraudulently received Title IV loans in excess of annual or aggregate limits.
• Have repaid Title IV loan amounts in excess of annual or aggregate limits if obtained inadvertently.
• Have Selective Service registration verified.
• Have Social Security Number verified.
• Not have a federal or state conviction for drug possession or sale, with certain time limitations.

Most of these items are covered by just filing a FAFSA and being an enrolled student, so if you are eligible to file a FAFSA and haven’t yet done so, you should now! Notice it says nowhere above that you have to have “financial need” for the funds. The HEERF funding is meant for “everyone” – as long as you aren’t an international or DACA / Dreamer student.

If you get the sense that moneyman is disappointed in this, you would be correct. It is very frustrating that the government added this limitation more than a week after the initial release of guidance which said none of this. I imagine many schools already had made plans on how to share this funding with all students regardless of citizenship status, and now they have to rework their plans (and come up with ways to support the students who don’t qualify under the new rules but still have significant needs.

So how do you ask for this money? This is going to depend by school. At some schools, you won’t have to ask; a small number of schools may just provide money to students who qualify. Most colleges are likely to have an application you will need to complete in order to request funding. FIU’s application is already live (although you must be able to log into their portal to see it). UWF already has their application live as well, although unlike FIU you will need to provide back-up documentation to support your request for funding.

From moneymman’s research, while some schools may ask for back=up documentation, many will just accept your application and your certification as your indication of your need for funds. These will likely be “small” grants (somewhere in the range of $500 to $1000) so many schools may not want to make it too difficult for students to apply. (And I know how ridiculous it is to say that $500 is “small” but when the Pell Grant is over $6000 at its maximum, this is much smaller in comparison)

So be kind to your schools if they haven’t placed their application online yet. We all just got final guidance on Tuesday. It’s been raining ever since.