American Rescue Plan Act: Implications and Aid for Higher Education Institutions

This article was updated June 4, 2021.

The American Rescue Plan Act of 2021 (ARPA) allocates nearly $40 billion in additional aid to the Higher Education Emergency Relief Fund (HEERF), which is available through September 30, 2023. This is the third stream of funding appropriated for HEERF (HEERF III) to prevent, prepare for, and respond to the COVID-19 pandemic (coronavirus).

This increase in funds accompanies the US Department of Education’s expanded HEERF application, flexibility, and guidance for recipients.

Below, learn how ARPA funds will be allocated, steps to receive aid, and how your higher education institution can more easily apply HEERF grants.

How ARPA Funds Will Be Allocated

The ARPA’s allocation methodology, terms, and conditions closely follow those provided in the second stimulus legislation, Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA).

Congress appropriated the funding as follows:

  • Approximately $36 billion for public and private not-for-profit institutions
  • Approximately $3 billion for Historically Black Colleges and Universities, Tribally Controlled Colleges and Universities, Minority Serving Institutions, and Strengthening Institutions Program institutions
  • Approximately $198 million for institutions that the Department of Education, after allocating other funds available under HEERF III, determines have the greatest unmet needs related to the coronavirus
  • Approximately $396 million for proprietary institutions

How ARPA Funds Must Be Used

Student Portion of Received Funds

A new formula was provided for the amount of received funds that must be used to provide emergency financial aid grants to students. View the Department of Education’s allocation table for more information. The funds received may be applied toward:

  • Any component of the student’s cost of attendance 
  • Emergency costs that arise due to COVID-19, such as tuition, food, housing, child care, or health care—including mental health care

Institutional Portion of Received Funds

The remaining funds can be used for the same items as listed under the CRRSAA:

  • Defray expenses associated with the coronavirus, including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff training, and payroll—which includes benefits
  • Make additional financial aid grants to students, with priority given to students with exceptional need. Student is defined as, “any individual who is or was enrolled (as defined in 34 CFR 668.2) at an eligible institution (as defined in 34 CFR 600.2) on or after March 13, 2020.”

Students are no longer required to be eligible for Title IV student financial aid to receive HEERF grants. In addition, undocumented students, international students, and students studying abroad may receive HEERF grants.

Coronavirus Safety Measures and Outreach

In a departure from CRRSAA guidance, the ARPA adds a requirement that if an institution doesn’t use all of the institutional portion for emergency financial grants to students, a portion of the institutional funds received must be used for both of the following:

  • Implement evidence-based practices to monitor and suppress the coronavirus under public health guidelines
  • Conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to recent unemployment of a family member or independent student, or other circumstances
Reporting Requirements

HEERF grantees must continue to adhere to the two quarterly reporting requirements originally implemented through the CARES Act for HEERF I funding.

Quarterly institutional public reporting forms and responses to the quarterly student public reporting requirement must be conspicuously posted on institutions’ websites no later than 10 days after the calendar quarter end.


Students are no longer required to be eligible for Title IV student financial aid to receive HEERF grants. In addition, undocumented students, international students, and students studying abroad may receive HEERF grants.

The Department of Education will collect an annual report for HEERF III ARP grantees in early 2022, and it will share more information in advance of the annual reporting deadline.

Retroactively Charge HEERF Costs

Grantees will now have the flexibility to charge HEERF costs back to March 13, 2020, the date that the coronavirus pandemic was declared a national emergency.

These updates reflect a change in the Department of Education’s prior position, which only allowed funds received under the CRRSAA to be used for costs incurred on or after December 27, 2020—the date of the CRRSAA’s enactment.

Guidance for Calculating Lost Revenue

The US Department of Education supplemented this change of interpretation with additional guidance addressing:

Taxability of Emergency Financial Aid Grants

Emergency financial aid grants made by a federal agency, state, Tribe, higher education institution, or scholarship-granting organization to a student because of an event related to the COVID-19 national emergency aren’t included in the student’s gross income.

To learn more about HEERF regulations and availability, visit FAQs related to HEERF II funding.

We’re Here to Help

For more information about coronavirus relief available to higher education instructions, ways to apply ARPA funds, or changes to HEERF grants, contact your Moss Adams professional.

Additional Resources

For regulatory updates, strategies to help cope with subsequent risk, and possible steps to bolster your workforce and organization, please see the following resources: