Unpacking the New Federal Guidance for HEERF III

Under HEERF III, higher ed institutions are receiving a total of $36 billion to provide students with emergency relief. The good news is that this round of funding is designed to be both more flexible and more equitable—helping institutions provide immediate support for the students who need it most.

But here’s the catch: the third round of funding comes with different guidance than HEERF I or HEERF II. And that means that the strategies used by institutions to distribute the last two rounds of emergency aid may not work.

Here are some key differences in the HEERF III guidance relative to the last two rounds of relief that institutions should bear in mind:

• It includes non-Title IV students. Unlike the last two rounds of COVID relief funding, the new guidance enables institutions to provide funding for students who are not eligible to receive Title IV federal aid, including DACA recipients and undocumented students. 
  

• It has an equity mandate. HEERF III also mandates that institutions cannot discriminate against any student on the basis of race or nationality in their methodology for prioritizing need and administering aid. This means that EFC alone cannot be the only determinant of aid eligibility, since it omits non-Title IV students and thus would be discriminatory if the sole basis of consideration.
  

• There is flexibility in timing to allow for optimized deployment in conjunction with HEERF II. According to recent ED guidance, drawing down both student and institutional HEERF II funds from G5 constitutes drawing down HEERF III funds — which means that institutions can be more strategic around timing and need not rush to draw down HEERF III. Additionally, the Department is allowing a no-cost extension for HEERF III beyond the September 30, 2022 spend date. The flexibility in timing suggests the Department wants institutions to deploy these funds quickly, but also as strategically as possible.

Last month, the U.S. Department of Education released new guidance to help colleges and universities understand how to distribute the third round of funds from the American Rescue Plan’s Higher Education Emergency Relief Fund (HEERF III).