Unlike the CARES Act, the CRRSAA requires that institutions prioritize students with exceptional need, such as students who receive Pell Grants, in awarding financial aid grants to students.  However, Pell eligibility or receipt is not required to receive CRRSAA funding.  In addition, CRRSAA explicitly provides that financial aid grants may be provided to students exclusively enrolled in distance education.

The June 17, 2020 Interim Final Rule (IFR) (85 FR 36494), which limited student eligibility for emergency funding under the CARES Act to students who are or could be eligible to participate in the Department's Title IV federal student financial aid programs under HEA Section 484, apply to HEERF programs under CARES and is not applicable to CRRSAA funds.  The IFR and its implementing regulation, 34 CFR § 668.2, apply only to funds made available under the CARES Act and not to funds made available under CRRSAA.

Regarding CRRSAA financial aid grants, institutions may not

1. condition the receipt of financial aid grants to students on continued or future enrollment in the institution,
2. use the financial aid grants to satisfy a student's outstanding account balance, unless it has obtained the student's written (or electronic) affirmative consent, or
3. require such consent as a condition of receipt of or eligibility for the financial aid grant.

Financial aid 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.

The funds will be applied directly to a student's account.  After obtaining the student's written (or electronic) affirmative consent, the student may leave the funds on the student account; otherwise, the student may elect to take the funds as a refund.  The Department believes that allowing students to consent to the application of a CRRSAA financial aid grant to their student accounts would facilitate use of funds, if desired by the student, while retaining the student's discretion to determine what costs should be covered with these financial aid grant funds.

Q:  Does the student's Free Application for Federal Student Aid (FAFSA) need to be completed in order to disburse HEERF student funds to the student?

A:  While ED's guidance does not require a FAFSA, the FAFSA is the quickest and easiest way to confirm a student is eligible to participate in Title IV programs and meets all applicable eligibility requirements.  As such, UD has limited CRRSAA funding to FAFSA filers.

Q:  What eligibility criteria are in section 484 of the Higher Education Act (HEA)?

A:  Section 484 of the HEA states that Title IV eligible students must

• be enrolled or accepted for enrollment in a degree or certificate program
• not be enrolled in elementary or secondary school
• if currently enrolled, be making satisfactotry academic progress
• not owe an overpayment on Title IV grants or loans
• not be in default on a Title IV loan
• file "as part of the original financial aid application process" a certification that includes
  • a statement of educational purpose
  • student's SSN
• be a U.S. citizen or national, permanent resident, or other eligible noncitizen
• have returned fraudulently obtained Title IV funds if convicted of or pled guilty or no contest to charges
• not have fraudulently received Title IV loans in excess of annual or aggregate limits
• have repaid Title IV loan amounts in excess of annual or aggregate limites if obtained inadvertently
• have Selective Service registration verified
• have social security number verified
• not have a federal or state conviction for drug possession or sale, with certain time limitations.

Q:  How will UD determine which students receive emergency grants and the amount of each grant?

A:  ED encourages institutions to prioritize awarding of emergency grants to students with the greatest need.  Information on UD's grant amounts by student population can be found in the table below.

CARES Act Reporting Information

30 Day Reporting Requirement

On April 22, 2020, the University of Delaware signed and returned the Certification and Agreement to the Department of Education (ED) to receive CARES funding and intends to use at least 50% of the CARES Act funds received for emergency grants to UD students.

The University of Delaware received $6,087,405 in CARES Act funding from ED for emergency grant distribution to eligible students.

The total amount of emergency grants distributed to students as of May 18, 2020, was $2,496,897, to 5,220 students.  All told, $5,940,300 was made accessible to 13,493 eligible students (the number of UD Title IV eligible students under Section 484 of the Higher Education Act).  For students who have not completed the process required to determine Title IV eligibility or have higher expenses than the amount of the official CARES emergency grant, SFS is working closely with the Office of the Dean of Students to provide additional assistance until funding has been depleted.

The method used to determine which students received the emergency grants and how much they received was based on the Expected Family Contribution (EFC) from the Free Application for Federal Student Aid (FAFSA) according to the following table.

Eligible students were notified via email to the student (on May 11, 2020) and to the parent/guardian on record (on May 13, 2020) of the emergency grant assistance available.  The communication advised students to refer to their student accounts for grant award amounts and to request the funds be sent to them either via direct deposit or check to their current address.

Students were informed these funds cannot remain on the student account to reduce balances due to the University.  The University also required students to certify their eligibility for the grant funds by listing the amount of eligible COVID-19-related expenses the grant would offset.  Examples provided to the students to assist in determining cost-of-attendance-related expenses resulting from COVID-19 included food, housing, course materials, technology, health care, child care, and transportation from campus to home.  Students were able to request grant refunds to the lesser of the amount of the grant on their student account or the amount of eligible expenses certified.

CARES Act Reporting Information

45 Day Reporting Requirement

As of June 17, 2020, UD had 10,318 students receive $4,631,667 of the $6,087,405 in CARES Grant Emergency funding awarded to them.

CARES Act Reporting Information

90 Day Reporting Requirement

As of July 23, 2020, UD had 10,633 students receive $4,722,006 of the $6,087,405 in CARES Grant Emergency funding awarded to them.  Students who have not yet requested an emergency grant may do so by submitting a request to askSFS, including the expenses and amount requested.  (Note:  Approved grant amounts may differ from the amount requested and will be based on funds available and the original grant eligibility, determined by EFC.)

Below is a list of eligible expenses. Documentation may be required for requested expenses.

• Food
  
• Housing (e.g., rent)
• Moving expenses (e.g., storage)

• Technology for online classes
• Transportation (e.g., unanticipated travel costs)
• Child care

• Student's COVID-related healthcare and medical expenses

CARES Act Reporting Information

120 Day Reporting Requirement

As of September 11, 2020, UD had awarded $5,875,920 of the $6,087,405 in CARES Grant Emergency Funds.  Of the amount awarded, 10,516 students have received funds totalling $5,465,025.  The latest round of CARES Grant awards included $500 CARES Grant funds for students eligible for the federal Pell Grant, or those with Expected Family Contributions (EFCs) from the FAFSA of $6,000 or less, who were enrolled in Spring 2020 and Fall 2020.  In addition, students who did not request their spring allocations of $150-$800 were offered their initial spring amounts.

Any remaining funds after October 1 will be reallocated based on levels from spring.

CARES Act Reporting Information

150 Day Reporting Requirement

As of October 13, 2020, a total of 10,558 students have received $5,645,424 in CARES funding.