Learn more about the case Connelly v. United States. ...
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The following is a brief summary of some of the more significant questions that were answered by the U.S. Department of Education (Department) when they published new FAQs in conjunction with the institutional aid portion of the funds that are now available under the American Rescue Plan Act (ARP).
This article specifically discusses the requirements under ARP to “implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines.”
There are two main outcomes that are desired:
(a) implement evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines; and
(b) conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act (HEA).
The Department has outlined four buckets that would be permissible and demonstrate compliance of ARP requirements. The below are examples of allowable expenditures and activities include, but are not limited to, costs associated with the following:
Testing:
Prevention:
Reducing Barriers to Vaccination:
Supporting Students:
Additionally, the CDC has developed several COVID-19-focused resources tailored to institutions of higher education available at www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/index.html, including “Considerations for Institutions of Higher Education” at www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/considerations.html.
Also relevant are those activities found on the Department’s Best Practices Clearinghouse.
This requires institutions to provide notice to financial aid applicants and current financial aid recipients that they may be able to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances.
The Office of Postsecondary Education published guidance in January 2021 reminding financial aid administrators that they may use professional judgment to reduce or adjust to zero the income earned from work for a student and/or parent if the student or parent has received unemployment benefits. As such, institutions should work to disseminate this opportunity widely for their financial aid applicants and make use of the professional judgment authority as needed.
“Direct outreach” requires an institution to actively engage financial aid applicants and recipients regarding the opportunity to receive a financial aid adjustment. Such outreach should be more than a passive notification of the opportunity to receive a financial aid adjustment, such as posting this opportunity on the institution’s website. Direct outreach is not considered advertising or recruiting. Direct outreach could include, but is not limited to, any of the following:
Please note that direct outreach does not require in-person interaction to financial aid applicants. Additionally, grantees are reminded that marketing is an impermissible use of HEERF III funds.
Congress did not set a specific threshold or amount that institutions must use to implement these two required activities. As such, recognizing that each institution’s needs and circumstances are different, institutions should be guided by the Cost Principles in 200 CFR part 200 subpart E, which require that an institution spend a reasonable and necessary portion of its HEERF grant funds in order to successfully implement these two required grant activities.
Any institution that receives an ARP (a)(1) Institutional Portion award (both supplemental awards and new awards) or ARP (a)(2) or (a)(3) award must implement these two required activities as part of the implementation of its HEERF III grant, provided it has not allocated its entire institutional portion to emergency financial aid grants for students.
Institutions should document how they implemented these two required activities consistent with 2 CFR § 200.334. Specifically, institutions should document (1) the strategies used to monitor and suppress COVID-19, (2) the evidence to support those strategies, (3) how those strategies were in accordance with public health guidelines, (4) the manner and extent of the direct outreach the institution conducted to financial aid applicants, and (5) how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution. The Department is exploring following up by collecting more information on an institution’s implementation of these two required activities in the 2021 HEERF Annual Report to be submitted in early 2022.
Schneider Downs’ Higher Education Industry Group is a dedicated team of experienced professionals, specializing in serving colleges and universities. Our team consists of individuals who have devoted their professional careers to thinking big within the higher education sector and delivering personal focus to each institution, their management teams and governing bodies.
Learn more at www.schneiderdowns.com/education.
Learn more about the case Connelly v. United States. ...
Learn more about the case Connelly v. United States. ...
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