ED’S LOST REVENUE GUIDANCE – MCCLINTOCK & ASSOCIATES INTERPRETATION
Michael T. Wherry
March 22, 2021
On March 19, 2021, the U.S. Department of Education (ED) released long awaited guidance on the uses of the Higher Education Emergency Relief Funding (HEERF) grants included in the various coronavirus relief legislation passed over the previous year: the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which created the first round of the grants, or HEERF I; the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) (HEERF II); and the American Rescue Plan (ARP) Act (HEERF III).
We were pleased to see this guidance from ED, as this is an area in which we fielded many questions over the last year, and the guidance is more expansive and lenient than we had anticipated. We applaud and thank ED for this new guidance.
As a reminder, for institutions that are proprietary, this guidance only applies to HEERF I grants, as HEERF II and HEERF III did not award them new institutional grants. Institutions should act quickly if they want to utilize lost revenue to claim any remaining institutional HEERF I grant as the one-year anniversary of this grant will occur in April, in many cases.
The guidance issued mainly addresses two items:
