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CARES Act - HEERF Report

Graduate Theological Union
Higher Education Emergency Relief Fund (HEERF) REPORT
Emergency Federal Financial Aid Grants to Students

The Coronavirus Aid, Relief, and Economic Security Act (CARES), which establishes and funds the Higher Education Relief Fund (HEERF), directs institutions of higher education to provide emergency financial aid grants to students for expenses related to the disruption of campus operations due to coronavirus. Section 18004(c) of the CARES Act directs institutions to use no less than 50 percent of the funds received under Section 18004(a)(1) of the act to provide emergency grants to students.

The purpose of this funding is to provide emergency relief to students who have additional expenses related to the disruption of campus operations due to the coronavirus pandemic (including eligible expenses under a student’s cost of attendance such as food, housing, course materials, technology, healthcare, and childcare). Expenses must have occurred after March 13, 2020, the date the U.S. President declared a national emergency. The funds must be distributed directly to the student and cannot be applied towards tuition or fees that a student may owe to the institution or to replace loss of income.

On April 9, 2020, the Department of Education (ED) published a letter from the Secretary of Education announcing the HEERF student funding allocation which was distributed using a formula based on the institution’s enrollment. In order to access the grant, the institution must sign and return the Certification of Funding and Agreement acknowledging the terms and conditions. The HEERF Recipient’s Funding Certification and Agreement for Emergency Financial Aid Grants to Students states that school’s must “promptly and to the greatest extent practicable” distribute HEERF emergency grants within one year from the date they signed the certification.

The Graduate Theological Union (GTU) applied for the CARES Act Emergency Student Funds opportunity number ED-GRANTS-041020-003 using the prescribed website. The Senior Director for Financial Aid and Enrollment completed the SF-424 form and uploaded and submitted the signed Certification and Agreement for approval.

The GTU received notification of approval on April 28, 2020 and was awarded an allocation of $29,534 pursuant to the Certification and Agreement.

By signing the Agreement, the GTU agreed to comply with the Department of Education’s May 6, 2020 Electronic Announcement. The announcement stipulates that an institution that has applied and has been approved to receive its allocation, is required to submit a report to the Secretary describing the use of funds and how they were distributed, as defined in section 18004(e) of the CARES Act. The GTU must make accessible to the public a report within 30 days from the date the institution received its allocation and must be updated every 45 days thereafter.

The regulation states that only students who are or could be eligible to participate in programs under Section 484 in Title IV (TIV) of the Higher Education Act of 1965, as amended (HEA) may receive emergency financial aid grants. The only practicable way for the GTU to determine that a student is eligible to participate in a TIV program is by requiring the completion of the Free Application for Federal Student Aid (FAFSA). Federal eligibility (34 CFR 668.32) requirements include:

  • Must be a U.S. citizen or eligible non-citizen
  • Have a valid SSN number
  • Be registered for selective service (if born male)
  • Be enrolled or accepted as a regular student in an eligible degree program
  • Be enrolled at least half-time
  • Must maintain Satisfactory Academic Progress (SAP)
  • Must not be in default on a Title IV loan
  • Must not owe an overpayment on Title IV grants or loans

The Associate Dean of Students, the Director of Student Life and Liaison for International Students and Scholars, the Senior Director for Financial Aid and Enrollment, and the Assistant Director of Financial Aid were tasked to establish distribution criteria.

The Financial Aid Office first identified all doctoral and master’s degree students actively enrolled for the spring 2020 term using the GTU’s Student Information System (SIS). The next step was to review the active student list to identify Title IV eligibility by determining which students successfully completed the 19-20 FAFSA and those who did not file but are eligible. It was determined that there are 116 students that are or could be eligible to participate.

Due the level of funding of the HEERF student share, it was not feasible to equally distribute funds to every eligible student. Therefore, of the 116 students that are or could be Title IV eligible, the Financial Aid Office identified only those who successfully completed their 2019-20 FAFSA, which pared the list down to 88 students.

The priority was to provide the most HEERF emergency financial aid grants to students who exhibited the highest financial need as determined using federal methodology. To that end, this group of students were categorized by highest need, those enrolled full-time versus part-time and their year in program.

The Director of Student Life and Liaison for International Students and Scholars created an online Emergency Request that asked students to document their expenses related to the disruption of campus operations due to coronavirus and the amount needed. Students were given the option to upload any supporting documentation and share additional information in support of their circumstances. Once the online request was finalized, an email (see Appendix A) was sent to the group of 88 students inviting them to apply, which included an informational list of Frequently Asked Questions (see Appendix B).

Of the eighty-eight students who were sent the email, 12 students submitted their request.

The Associate Dean of Students, the Director of Student Life and Liaison for International Students and Scholars, the Senior Director for Financial Aid and Enrollment, and the Assistant Director of Financial Aid met to review, discuss and deliberate these requests on a case-by-case basis. Each request was first reviewed to ensure that all claimed expenses were eligible as a result of the disruption of campus operations due to the COVID-19 pandemic.

In order to distribute the funds in a fair and equitable manner, the group worked collaboratively to determine the amount of grant each student would receive by carefully taking into consideration their level of need, the amounts of their claimed expenses, and other factors such as the number of family members in their household, if the student is employed, and if the student is the sole or primary provider.

Grant amounts ranged between $600 and $3,500 and the GTU has distributed $29,534 of HEERF to students as of July 1, 2020.

The Director of Student Life and Liaison for International Students and Scholars notified the students of the emergency financial aid funds that were awarded to them via email (see Appendix C).

In accordance with the National Association of College and University Business Officers (NACUBO), the 26 CFR 1.6050S-1 reporting requirements for the 1098-T are still in effect and requires schools to report all “grant aid processed and administered by the institution.” In order to accurately report the emergency financial aid funds, the GTU’s Financial Aid and Business Offices made the unilateral decision to disburse HEERF grants to students using their Student Information and Financial Aid Management Systems (FAMS). Note: the IRS collects the 1098-T not to determine whether the student has taxable scholarships or grants, but to provide documentation allowing the IRS to ensure that students claiming the American Opportunity and Lifetime Learning Credit(s) have not paid all of their tuition and fees costs with grants and scholarships. Questions on this topic should be directed to the IRS as tax rules and regulations are not within the GTU Financial Aid or Business Office's area of Title IV expertise.

The Financial Aid Office created a federal fund code for the purpose of auditing and tracking and so that the award could be disbursed through the FAMS. Additionally, a “COVID-19” budget expense item was created so that it could be added to a student’s spring 2020 cost of attendance in order to prevent an over-award as these funds should not count against a student’s estimated financial aid.

Once an identically matching award code was created in the SIS, the Vice President for Administration and Finance and Chief Financial Officer linked the award with the T-code that was created specifically for this federal emergency fund to facilitate ease for tracking purposes. The CFO opened a new bank account in order to keep these funds separate from Title IV funds. She also set up a separate HEERF specific refund T-code to facilitate the ability to quickly post the aid to a student’s billing account and run immediate refunds. Grant funds were drawn down from ED’s G5 system by the Business Office.

The full amount of the grants awarded were disbursed directly to the student regardless of whether they owe a balance to the GTU. Emergency grant funds were issued to students either by direct deposit or in the form of a paper check and mailed through the U.S. Postal Services to student billing addresses.

Appendix A

As COVID-19 continues to evolve and impact various communities, the United States Congress has created the Higher Education Emergency Relief Fund (HEERF) to provide institutions of higher education with emergency federal funding to assist students whose lives were disrupted by the COVID-19 pandemic.  To help cover some of our students' unexpected expenses due to COVID-19 such as housing, food, transportation, medical expenses, childcare, etc., GTU has applied and procured some of that funding. Now, here's an invitation for you to apply for those emergency funds.

You can find the application here. The application is due by Thursday, May 14th, but funds are limited. Please apply as soon as possible.

Appendix B

CARES Act Higher Education Emergency Relief Funds
Frequently Asked Questions (FAQs)

What is the CARES Act/HEERF and how is it funded?
The Coronavirus Aid, Relief, and Economic Security (CARES) Act was passed by Congress and signed into law by the President. One component of the law reserves funds for the purpose of providing institutions of higher education with emergency federal funding to assist students whose lives were disrupted by the COVID-19 pandemic. This is called the Higher Education Emergency Relief Fund (HEERF).

Who is eligible to apply for HEERF?
GTU doctoral and Master of Arts students who have completed a FAFSA, are determined to be Title IV eligible, and are making Satisfactory Academic Progress (SAP) are eligible. International, undocumented, non-degree and non-aid filers are not eligible.

Do I need to be enrolled during spring 2020 to be eligible?
Yes. Students who are enrolled at least half-time for the spring term are eligible.

How do I apply and what expenses does the grant cover?
Complete the online application, which available from the Director of Student Life.  The funds can be used to cover expenses incurred due to COVID-19 such as housing, food, transportation, medical expenses, childcare.

Do I need to submit receipts to apply?
No. However, we require applicants to attest, under penalty of the law, that the expenses detailed in their respective applications are true and accurate. Students must be able to produce documentation of expenses incurred, if requested.

How much will I receive?
Amounts will be determined on a case-by-case basis taking into consideration your unique circumstances, the amount of funding available and how many students apply.

Will I receive the emergency grant even if I owe the school money?
Yes. If you are eligible for these emergency grants, you will receive the money even if you have current financial holds or owe the campus fees or fines.

When will HEERF applicants be notified?
HEERF award notifications will be issued within 7-10 business days after the application period has closed.

How will I receive my money?
If you have not already done so, we recommend that you sign up for direct deposit with the Business Office to ensure that your funds reach you as quickly as possible. Otherwise, a paper check will be mailed to your student billing address.

I did not complete a FAFSA.  Is it too late to apply?
No. However, priority consideration will be given students who have already completed their 2019-20 Free Application for Federal Student Aid (FAFSA).  Due to limited funding, decisions will occur on a first come, first served basis, therefore it is critical that you apply as soon as possible.

Who do I contact with questions?
Email the GTU Financial Aid Office at

Appendix C

Thank you for applying for the Higher Education Emergency Relief Fund (HEERF). This fund was created by the federal government to help students with unexpected expenses related to the COVID 19 pandemic.

Upon considering the circumstances surrounding the need for assistance mentioned in your application and the availability of funds, the HEERF Disbursement Committee decided to award you the following sum of money via direct deposit or check: $ _______.

We hope that this government assistance can help you during this difficult time. We will let you know if more funds become available.