Higher Education Emergency Relief Fund (HEERF) – CARES ACT
Meharry Medical College’s Policy & Procedure on the Higher Education Emergency Relief Fund (HEERF) Emergency Financial Aid Grants to Students
Coronavirus Aid, Relief, and Economic Security (CARES Act) (HEERF I)
Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) (HEERF II)
American Rescue Plan (ARP) (HEERF III)
Section 18004(c) of the Cares Act requires Meharry Medical College to use at least fifty (50%) percent of the funds received to provide emergency financial aid grants to students for expenses related to the disruption of campus operations due to COVID 19 (including eligible expenses under a student’s cost of attendance such as food, housing, course materials, technology, health care, and child care).
Upon receipt of the Grant Award Notification (GANS) from the U.S. Department of Education, Meharry Medical College promptly made available emergency financial aid grants as funded by the Coronavirus Aid, Relief, and Economic Security (CARES) Act directly to students enrolled in the spring 2020 semester for their expenses related to the disruption of campus operations due to COVID 19, (including eligible expenses under a student’s cost of attendance such as food, housing, course materials, technology, health care, and child care) as required by Section 18004(c) of the CARES Act. Meharry Medical College did not use the funds to reimburse itself for any costs or expenses, including but not limited to, any costs associated with significant changes to the delivery of instruction due to the coronavirus and/or any refunds or other benefit previously issued to students.
Meharry Medical College acknowledged it has signed and returned to the U.S. Department of Education the Certification and Agreement for funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students.
The total amount of funds Meharry Medical College received from the Department pursuant to the institution’s Certification and Agreement [for] Emergency Financial Aid Grants to Students was $109,988.
The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day Report and every 45 days thereafter) was $109,988.
The estimated total number of students at Meharry Medical College eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act was 750.
Eligibility requirement as of April 24, 2020
Students must be eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (HEA). For purposes of disbursal of these funds, the College will base determination of eligibility on the existence of the student’s 2019-20 Free Application for Federal Student Aid (FAFSA).
Student must be enrolled at least half time.
Students must be United States citizens.
Student must be meeting Satisfactory Academic Progress.
Consistent with Section 18004(c), Meharry Medical College retained discretion to:
Determine the amount of each individual Emergency Financial Aid Grant consistent with all applicable laws, including non-discrimination laws.
Prescribe the methodology for distribution of funds across the student population.
The CARES Act student emergency funding was managed by the Director of Financial Aid. As encouraged by the Secretary of Education in the Recipient’s Funding Certification and Agreement for CARES Act Funding, “the Director of Financial Aid will exercise the use of professional judgment available under Section 479A of the Higher Education Act of 1965 (HEA), 20 U.S.C § 1087tt, to determine need and eligibility for receipt of CARES Act student emergency grants.”
The College awarded student emergency grants on the basis of need and upon certification (by each grantee/student) of allowable use as defined by Section 18004(c) of the CARES Act and consistent with this policy.
The Secretary of Education, Betsy DeVos, does not consider these individual Emergency Financial Aid Grants to constitute Federal Financial Aid under Title IV of the Higher Education Act of 1965 (HEA). The emergency financial aid funds were not used for any purpose other than the direct payments of grants to students for their expenses related to the disruption of campus operations due to coronavirus. Meharry Medical College promptly complied with Section 18004(e) of the CARES Act and report to the Secretary, when required, in accordance with 2 CFR 200.333 through 2 CFR 200.337, or in other additional form as the Secretary may specify.
Meharry Medical College reported:
how grants were distributed to students,
the amount of each grant awarded to each student,
how the amount of each grant was calculated, and
any instructions or directions given to students about the grants
Meharry Medical College distributed all the funds in the form of emergency financial aid grants to students within twelve (12) months from the date of the signed Certificate and Agreement. Students interested in applying for the emergency grant funds had to complete an application form prior to the release of their Emergency Financial Aid Grant Funds. A committee was developed to assist in reviewing the applications. The committee reviewed the application, along with the submitted documentation to determine eligibility. Due to the small allocation, guidelines were put in place to award students on a first-come, first-served basis. Priority consideration will be given to currently enrolled students whose future enrollment may be affected by COVID-19 pandemic. Funds were disbursed to students who submitted completed forms indicating and certifying that funds were to be used for allowable expenses as outlined by Section 18004(c) of the CARES Act. Students not submitting required supporting documentation with their application were not considered for the emergency financial grants. The Office of Financial Aid and the committee reviewed and approved all submitted certification forms prior to disbursal of funds. The Financial Services and Accounts Payable Offices processed the payments of the Emergency Financial Aid Grants to each student in the same manner in which credit balances are processed for Title IV aid. At no time were any emergency grant funds used by the College to offset existing student account balances, nor future student account charges. Funds were disbursed directly to individual students, in the form of a check or electronic fund transfer payment.
An application was created via Wofoo (https://mmcstudentlife.wufoo.com/forms/w1j6tfxo10db3zz/) and disseminated, via the Meharry e-mail system on April 27, 2020, to the entire student body at Meharry. All students were instructed to apply, attach documentation and submit by May 6, 2020. Due to the small allocation, it was decided to award said grant funds on a first-come, first-served basis based on the student’s request. It was determined, based on the allocation and to assist as many students as possible, the grant funds would be capped at $1,500 and the reasons would be narrowed down, i.e. 4th year students requesting moving expenses would not be funded; students who did not attach documentation for the request, would not considered; credit card bills, car payments, car insurance payments, etc. would not be included. It was a difficult decision to narrow down the application approval, due to all students had already received federal funds to cover their requests.
After the applications were received, following USDE’s guidelines, the Committee reviewed each application and assigned an amount, based on the student’s request.
The total number of students who have received an Emergency Financial Aid Grant under Section 18004(a)(1) of the CARES Act, during the first round of funding was 121.
The total allocation, for the first round of the CARES Act funds have been awarded and disbursed to all eligible recipients. There are no remaining grant funds available.
January 2022 – Additional funds for HEERF I
]The Department of Education granted additional HEERF I funds for the student portion to Meharry Medical College’s GAN award, P425E201458, totaling $491,158, to be used as emergency financial aid grants.
To begin the application process, an application was created in Google using forms – Meharry Medical College Additional CARES Act (HEERF I) funds was emailed to students on January 28, 2022, via Meharry’s email system, Outlook. Students were instructed to complete the application in its entirety and submit by Friday, February 4, 2022.
Eligibility requirements for the second round of HEERF I funds, as of January 28, 2022
Students must be eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (HEA). For purposes of disbursal of these funds, the College will base determination of eligibility on the existence of the student’s 2021-22 Free Application for Federal Student Aid (FAFSA).
Student must be enrolled at least half time.
Students must be United States citizens.
Student must be meeting Satisfactory Academic Progress.
These funds were awarded based on an application process. All students were considered for funding if all criteria were met and application was completed, without errors. Using the same analogy to determine the maximum amount of the grant funds to be awarded as used with the HEERF III funds, up to $2,000 per student was the award amount. The emergency financial aid grant amount was derived by using the cost of attendance components:
Rent – average in Nashville is $1,678
Utilities – $167.37
Food – $200
Students were advised to use these emergency financial aid grants to help meet urgent, basic needs such as:
Health care (including mental health care)
Child care expenses
After the application process closed on February 4, 2022, staff in the Financial Aid Office reviewed all submitted applications. 536 students submitted the HEERF I second round of funding application. The applications were numbered in the Google form based on the time and date the application was submitted. After reviewing each form, those students that did not meet the criteria was excluded from the final selection process. Fifty-three (53) students with the following criteria were excluded:
Non- U. S. citizens
Students who did not complete a 2021-22 FAFSA
Students not making SAP (i.e. gpa below the school’s required gpa)
Students who completed the application incorrectly, i.e. did not sign the application in the appropriate field, etc.
It was decided to award the HEERF I funds to the remaining eligible 484 students. The funds were awarded based on their Expected Family Contribution (EFC) from their 2021-22 FAFSA. There were 338 students with an $0 EFC. These students received a $2,000 emergency financial aid grant. There were 5 students who had an EFC of $1 to $500. These students were given an extra $400, totaling $1,731 to $1,732 and the remaining 141 students, with EFCs ranging $501 or above, were awarded the remaining funds in equal disbursements, i.e. $1,331, each. After the process had closed and students had been selected, Request For Disbursement (RFD) forms was created and forwarded to Accounts Payable for processing on Thursday, February 17, 2022. Funds were direct deposited into the eligible students’ preferred bank accounts, beginning March 9, 2022.
The total amount of additional funds Meharry Medical College received from the Department of Education on the Grant Award Notification (GAN) P425E201458, was $381,170. An additional $109,988 was transferred from the Institutional portion of the HEERF I funds and $381,170 was transferred from the Institutional portion of the HEERF III funds to match the total allotment of grant funds received for emergency financial aid grants. Making the total allocation for awards for the second round of HEERF I funds $872,328.
The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act was $982,316.
The total number of students at Meharry Medical College eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act was 867.
The total number of students who received an Emergency Financial Aid Grant under Section 18004(a)(1) of the CARES Act, during the second round of funding was 484, making the total number of students receiving HEERF I emergency financial aid grants, 605.
Meharry Medical College (MMC) is committed to ensuring our students are able to make progress towards graduation. MMC was issued additional supplemental funding from the U.S. Department of Education, which requires the same assurance that the institution has used, or intends to use, no less than the amount awarded for HEERF I under the HEERF II award and at least fifty (50) percent of the HEERF III funds received under Section 314(a)(1) of the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) to provide Emergency Financial Aid Grants to students on are after March 13, 2020, the date of the declaration of the national emergency. The Higher Education Emergency Relief Fund II (HEERF II) is authorized by the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA), Public Law 116-260, signed into law on Dec. 27, 2020. On March 11, 2021, President Biden signed the American Rescue Plan Act of 2021 (ARP) (Pub. L. 117-2). The ARP appropriated 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. Taken together, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) (Pub. L. 116–136), the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA) (Pub. L. 116-260), and the ARP represent HEERF I, HEERF II, and HEERF III, respectively.
HEERF III is structured like the HEERF II programs under the CRRSAA, with certain important differences that will be discussed within these FAQs. These FAQs are intended to describe the features and allowable uses of grants received under the HEERF I, II and III programs and may be updated with additional information in the future.
Institutions have expanded flexibility in their use of supplemental Institutional Portion funds (CFDA 84.425F) that includes defraying expenses associated with coronavirus, carrying out student support activities authorized by the Higher Education Act of 1965, as amended (HEA), that address needs related to coronavirus, and making additional financial aid grants to students.
CRRSAA section 314(c)(2) allows an institution to spend its CRRSAA funds on student support activities authorized by the HEA, where student support activities address needs related to the coronavirus. The CRRSAA section 314(d)(2) allows institutions expanded use of funds authority for unexpended CARES Act funds. HEERF grants for students may be used for 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.
Eligibility Requirements For a Student To Receive HEERF Grant Funds
According to the HEERF funding and guidance from the Department of Education, the following factors played a pivotal role in MMC’s decision for awarding these funds:
HEERF II and III requires that institutions prioritize students with exceptional need, for example, but not limited to, such as students who receive or may have been eligible to receive Pell Grants. Based on the fact that MMC’s students are Independent students and not Pell grant eligible, MMC decided to select exceptionally financial needy students based on using their Expected Family Contribution (EFC) from their 2021-22 FAFSA results. To fall within this category, students must have received an $0 EFC on their FAFSA.
Unlike the CARES Act, the CRRSAA does not require that 50% of an institution’s funds be spent on student grants. It does, however, require that institutions spend at least the same dollar amount on student grants as they were required to spend under the CARES Act.
The ARP (HEERF III) funds require that 50% of an institution’s funds be spent on student grants, with the exception of for-profit institutions, which must spend 100% of their funds on student grants.
Grant Funds Can Be Used For The Following Types Of Needs
A portion of the HEERF grant funds were used to provide emergency financial grants to help students meet urgent, basic needs such as:
Health care (including mental health care)
Child care expenses
Meharry Medical College provided emergency financial aid grants to eligible students for expenses related to the increased cost of living in Nashville and any 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 childcare). Using DOE’s clarified “student” definition, Meharry considered any individual who was enrolled at the institution in the fall 2021 semester would qualify for assistance under the HEERF programs, which included citizens, permanent residents, refugees, asylum seekers, DACA recipients, DREAMers, and similar undocumented students, in the awarding of HEERF emergency financial aid grants.
Based on a transparent process of awarding the emergency financial aid grant funds, Meharry elected to award funds to all enrolled students due to the significant increase in living expenses in Nashville, TN and unexpected increased educational costs, during the pandemic, regardless of whether the student completed a FAFSA or was eligible for federal Title IV student aid.
Cost of attendance components considered in arriving at the $10,000 emergency financial aid grant:
Fall 2021 semester (5 months) – (July 2021 through December 2021)
Rent – average in Nashville is $1,678 (COA budget allows $1,250)
Utilities – $167.37
Food – $200
MMC had 957 enrolled, registered students who were deemed eligible to receive Emergency Financial Aid grants under the HEERF III allocation when the awards were made on November 22, 2021. Eligible students had to be enrolled at the time when the grants were awarded. This did not include those students who had taken a leave of absence or those that had withdrawn or had been administratively withdrawn, within the semester. All eligible students were considered when making awards and no application was required. Students received $10,000 each, with an additional $2,000 going to approximately 618 students who displayed exceptional financial need, based on $0 EFC from their most recently filed FAFSA. Total emergency financial aid grants awarded was $10,806,000.
An Argos report was used to pull all eligible students to be awarded the emergency financial aid grants
An Excel spreadsheet was used to capture all eligible students
Request for Disbursement (RFD) form was used to document each student and the amount of funds they received. Nine (9) to ten (10) students were included on each RFD
Once the RFDs had been completed, they were forwarded to Accounts Payable for processing
Each student was entered into Banner student system. Those who had set up direct deposit through Financial Aid had their emergency financial aid grant funds disbursed into their bank accounts as early as Wednesday, November 24, 2021. Those who elected to pick up paper checks, were instructed beginning Wednesday, November 24, 2021 to frequent the Cashier’s window, LRC Building, 5th floor for disbursement.
The additional $2,000 disbursements for $0 EFC recipients were completed in April 2022.
All funds have been disbursed and paper checks disseminated.
The Office of the President sent out an additional email blast to the students to remind them of how the emergency financial aid grant funds were to be used. Students was advised to use the grant funds for any component of their cost of attendance or for emergency costs that may arise or have arisen due to coronavirus, such as tuition, food, housing, health care (including mental health care), or childcare espenses.
Tuition-related Reduction Payments Initiatives for the HEERF II and III Funding Awarding Methodology
As it relates to the tuition-related reduction payments, Meharry decided to assist those currently enrolled students who had borrowed federal loans to pay tuition expenses, with a tuition reduction loan payment. No additional money will be released to students in hand. The financial aid grant will be used to make a loan reduction (reduce current year loan balance) on students’ outstanding loan debt. This decision was the result to assist in reducing the loan debt that Meharry students incur over the matriculation of their health professions education. Meharry Medical College elected to provide a tuition-related reduction payment toward outstanding debt to enrolled 2021-22 students who had borrowed financial aid, in the form of a federal student loan, to support their tuition educational activities while attending Meharry, during the fall 2021 through spring 2022 semesters. This payment will not be awarded to self-pay students, International Dental students, or those students who had their tuition paid through third-party agencies.
The tuition-related reduction payment will cover up to fifty percent (50%) of the total tuition costs for students in the School of Medicine (SOM), School of Applied Computational Sciences (SACS), School of Graduate Studies and Research (SGSR), which includes Masters of Health Sciences (MHS), Masters of Public Health (MPH/MSPH). It was decided since the School of Dentistry (SOD) students, excluding the International Dental students, have a higher cost of attendance and incur the highest loan debt, their tuition-related reduction payment will encompass up to seventy-five percent (75%) of their total tuition costs. The amount of the tuition-related reduction loan payment will be based on the amount of tuition the students were assessed in the fall 2021 through spring 2022 semesters. If students were assessed at a tuition rate less than the half amount of the tuition charge, the tuition-related reduction payment will cover the actual amount of the tuition charged, or the amount of loan they borrowed. If they did not borrow loans that total the amount of their tuition charge, the tuition-related grant will be reduced to the amount of the loan the student borrowed.
Outstanding student account and housing balances totals were received from the Office of Financial Services and dated back to cover balances for students enrolled as of March 2020. No account balances were included for balances that predated the March 2020 spring semester.
Seven hundred seventy-six (776) students were awarded tuition-related reduction loan payments, totaling $22,003,674. All funds have been posted to the students’ Banner accounts and the funds sent to their respective lenders.
Tuition-related Reduction Loan Payments (HEERF II and III)
Must have been enrolled in the fall 2021 through spring 2022 semesters, or in the fall 2021 semester, alone, in a degree-granting program; Those who have withdrawn, taken a ‘leave of absence,’ were ‘administratively withdrawn’, were enrolled in an away research experience, or were previously enrolled, etc. are not eligible;
Must have borrowed and received federal loans to pay their fall 2021 and spring 2022 tuition. (The amount of the tuition reduction payment will not exceed the amount of tuition the student was charged in the fall 2021);
Must not have received tuition payment through a third-party service grant*;
Cannot be self-pay student.
Cannot be enrolled in the International Dental Program;
Funds were awarded if students had federal loan debt, only, private loans were not considered
*If student is awarded a third-party service grant after the HEERF funds have been awarded, posted and returned to the lender, the HEERF funds grant will not be retracted.
As of May 31, 2022, the below chart shows the total amount of Higher Education Emergency Relief Funds (HEERF I, II and III) that the institution will receive or has received from the U.S. Department of Education pursuant to the institution’s Certifications and Agreements for Emergency Financial Aid Grants to Students (Student Portion), Institutional Portion and the HBCU-Emergency Relief Fund.
Is it a Taxable Event if the School uses HEERF Funds to pay off, write off, or discharge a Student’s Outstanding Balance?
This AskRegs Knowledgebase Q&A was updated on February 11, 2022 to include long-awaited IRS guidance related to Higher Education Emergency Relief Fund (HEERF I) student grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), HEERF II student grants under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021), and HEERF III grants under the American Rescue Plan Act of 2021 (ARP).
Scenario: Schools are using their institutional HEERF to write off students’ outstanding balances as encouraged by ED, but debt that is discharged is normally a taxable event per general IRS rules.
Answer: No. According to the February 11, 2022 IRS Higher Education Emergency Grants Frequently Asked Questions, HEERF I, HEERF II, or HEERF III student or institutional funds used to pay off or discharge a student’s outstanding (or overdue) balance are not taxable. Therefore, educational institutions do not have information reporting requirements under Internal Revenue Code, section 6041 when using HEERF funds to pay off or discharge a student’s overdue balance. These payments are not included in the student’s gross income. Because the payments are not income, section 6041 does not apply to them, and higher education institutions are not required to file or furnish students with IRS Form 1099-MISC, Miscellaneous Income.
This includes situations when the institution writes-off the outstanding balance and then pays it with HEERF institutional funds. See the IRS FAQs for more information.
Quarterly Budget and Expenditure Reporting Under CARES ACT Sections 18004(A)(1)
Institutional Portion, 18804(S)2, and 18804(A)(3)
Quarter 1 2021 Report
January 1, 2021 – March 30, 2021
Quarter 2 2021 Report
April 1, 2021 – June 30, 2021
Quarter 3 2021 Report
July 1, 2021 – September 30, 2021
Quarter 4 2021 Report
October 1, 2021 – December 31, 2021
Quarter 1 2022 Report
January 1, 2022 – March 30, 2022
Quarter 2 2022 Report
April 1, 2022 – June 30, 2022