Emergency Assistance to Institutions of Higher Education

Program Description

Types of Projects

Frequently Asked Questions

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1. What is the purpose of the Emergency Assistance to Institutions of Higher Education Program?
2. How will the U.S. Department of Education (ED) award Program funds?
3. For what purposes may an IHE use Program funds?
4. What is an IHE, and which IHEs are eligible?
5. May proprietary institutions of higher education receive Program funds?
6. May students apply directly to ED for Program funds?
7. What is "extensive damage"?
8. May an IHE use Program funds to defray the costs of administering its grant?
9. What kinds of activities may be supported with Program funds?
10. What records must an IHE maintain after receiving Program funds?
11. What is cash management?
12. Who is responsible for cash management?
13. Who is responsible for monitoring drawdowns to ensure compliance with cash management policies?

1. What is the purpose of the Emergency Assistance to Institutions of Higher Education Program?

This program (Program) is designed to provide emergency assistance to institutions of higher education (IHEs) and students attending IHEs in areas directly affected by a covered disaster or emergency including Hurricanes Harvey, Irma, and Maria and the wildfires in calendar year 2017 for which the President declared a major disaster or emergency.

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2. How will the U.S. Department of Education (ED) award Program funds?

1. As we did in 2009 after the disasters in 2008, ED will accept and evaluate pre-applications. ED is required to prioritize, to the extent possible, (1) services to students who are homeless or at risk of becoming homeless as a result of displacement and (2) institutions that have sustained extensive damage, by a covered disaster or emergency.

2. After receiving pre-applications, ED will enter the data described in parts (a) — (d) below into a formula to determine each applicant’s equitable share of an initial overall amount. (Please note: since not all costs will be known at the time of pre-application, ED may reserve funds to be allocated later.) The Secretary has established the following factors as criteria that will be used in allocating these funds:

(a) Expenses. The expenses incurred by the IHE to remedy the effects of the covered disaster or emergency, including the costs of construction and reconstruction associated with physical damage to the IHE caused by the covered disaster or emergency, and the expenses associated with supporting students who are homeless or at risk of becoming homeless.

Note: Expenses associated with supporting students who are homeless or at risk of becoming homeless may include work to identify and serve such students, as well as food, employment, housing, counseling, emergency grants, transportation, and other services, so long as all such expenses are authorized under the Higher Education Act of 1965, as amended (HEA). Applicants should include only those expenses directed to students who are homeless or at risk of becoming homeless, and applicants should not include a portion of expenses directed to a larger population of students even if some of those expenses have aided some students who were homeless or at risk of becoming homeless. Applicants should, however, include expenses directed toward individual students who are homeless or at risk of becoming homeless, even if similar aid or services have been made available to other students.

(b) Funds received. Any amount of any insurance settlement or other funds received by the IHE, from any source including a Federal or other relief agency, related to remedying the effects of the covered disaster or emergency.

Additional factors we will consider in making an award include the following.

(c) Priorities. We will prioritize, to the extent possible, projects that support institutions serving students who are homeless or at risk of becoming homeless as a result of displacement, and institutions that have sustained extensive damage as a result of a covered disaster or emergency.

(d) Need for Project. The Secretary will consider the need for the proposed project. In determining the need for the proposed project, the Secretary will consider the magnitude or severity of the problem to be addressed by the proposed project.

Note: To consider the magnitude or severity of the problem to be addressed, the Secretary will consider the estimated percentage of operations, as a proportion of the IHE’s operations prior to the occurrence of the covered disaster or emergency, that remain impaired as a result of the covered disaster or emergency. This percentage should be estimated on the basis of year-over-year spending or budget, using spring 2017 as the baseline. For example, if the IHE’s spring 2017 spending was $100 million and the IHE’s spring 2018 budget is $75 million, the applicant should report that the IHE is operating at 75 percent.

When using the spring 2018 budget for the purpose of calculating the magnitude or severity of the problem to be addressed, do not include new activities being undertaken because of the covered disaster or emergency, such as reconstruction.

If using "spring 2017" as a baseline is an undue burden because of the IHE's budget practices, an IHE may compare a three-month period from spring 2017 to the same period in spring 2018, or an IHE may compare a set of six consecutive two-week pay periods from spring 2017 to the same pay periods in spring 2018.

3. ED will email notice of each institution’s allotment to the contact person named on the data information form.

4. Applicant institutions will then prepare and submit a full application for no more than the exact amount of their allotments, with form and content as described in the notice inviting applications and the application package for this program.

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3. For what purposes may an IHE use Program funds?

Any purpose authorized under the HEA is allowed. Note, however, that all activities funded under the Program must be in the context of emergency assistance. That is, the funding must be used for activities directly related to mitigating the effects of a covered disaster or emergency on students and institutions. We will prioritize, to the extent possible, projects that support students who are homeless or at risk of becoming homeless as a result of displacement, and IHEs that have sustained extensive damage, by a covered disaster or emergency.

Information about Office of Postsecondary Education programs is available at www2.ed.gov/about/offices/list/ope/index.html. Information about Federal Student Aid programs is available at studentaid.ed.gov/sa/. The U.S. Code version of the HEA is available at uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title20-chapter28&edition=prelim.

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4. What is an IHE, and which IHEs are eligible?

Eligible applicants are institutions that (1) meet the definition of “institution of higher education” in section 101 or section 102(a)(1) of the HEA (20 U.S.C. 1001 and 1002(a)(1)), and (2) are located in areas directly affected by a covered disaster or emergency. These areas include:

• Alabama: All counties.
• California: Butte, Lake, Mendocino, Napa, Nevada, Orange, Solano, Sonoma and Yuba counties.
• Florida: All counties.
• Georgia: All counties.
• Louisiana (parishes): Acadia, Allen, Assumption, Beauregard, Calcasieu, Cameron, De Soto, Iberia, Jefferson Davis, Lafayette, Lafourche, Natchitoches, Plaquemines, Rapides, Red River, Sabine, St. Charles, St. Mary, Vermilion, and Vernon.
• Puerto Rico: All municipalities.
• South Carolina: All counties.
• Texas: Aransas, Austin, Bastrop, Bee, Bexar, Brazoria, Burleson, Caldwell, Calhoun, Chambers, Colorado, Comal, Dallas, DeWitt, Fayette, Fort Bend, Galveston, Goliad, Gonzales, Grimes, Guadalupe, Hardin, Harris, Jackson, Jasper, Jefferson, Jim Wells, Karnes, Kleberg, Lavaca, Lee, Liberty, Madison, Matagorda, Milam, Montgomery, Newton, Nueces, Orange, Polk, Refugio, Sabine, San Augustine, San Jacinto, San Patricio, Tarrant, Travis, Tyler, Victoria, Walker, Waller, Washington, and Wharton.
• U.S. Virgin Islands: All islands (county equivalent).

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5. May proprietary institutions of higher education receive Program funds?

Yes; the definition in section 102(a)(1) of the HEA (20 U.S.C. 1001 and 1002(a)(1)) includes proprietary IHEs. A proprietary IHE may receive funds for activities and students to the full extent that it is eligible under the HEA.

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6. May students apply directly to ED for Program funds?

No. IHEs may receive funds for student financial assistance or other projects that serve students. IHEs should prioritize, to the extent possible, students who are homeless or at risk of becoming homeless as a result of displacement by a covered disaster or emergency.

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7. What is "extensive damage"?

ED will use the criteria listed above to make a determination regarding the extent of damage to each applicant IHE.

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8. May an IHE use Program funds to defray the costs of administering its grant?

Yes, provided that the amount is reasonable and necessary to effectively administer the grant. Administrative costs include direct and indirect costs involved in the proper and efficient performance and administration of the grant.

This use of funds, as well as indirect costs and rates, must comply with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 C.F.R. part 200 and ED's administrative regulations (see 34 C.F.R. 75.560 — 75.564 regarding indirect costs). Activities performed under the authority of a particular program authorized under the HEA must follow all statutory and regulatory restrictions on the indirect cost rate for that program. Any requirements, however, relating to matching, Federal share, reservation of funds, or maintenance of effort that would otherwise be applicable under 20 U.S.C. 1087 — 51 et seq. or 1138 et seq. do not apply.

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9. What kinds of activities may be supported with Program funds?

Any purpose authorized under the HEA, is allowed. Note, however, that all activities funded under the Program must be in the context of emergency assistance. That is, the funding must be used for activities directly related to mitigating the effects of a covered disaster or emergency on students and institutions.

Information about Office of Postsecondary Education programs is available at www2.ed.gov/about/offices/list/ope/index.html. Information about Federal Student Aid programs is available at studentaid.ed.gov/sa/. The U.S. Code version of the HEA is available at uscode.house.gov/view.xhtml?req=granuleid%3AUSC-prelim-title20-chapter28&edition=prelim.

For instance, program funds may be used for student financial assistance, faculty and staff salaries, equipment, and student supplies and instruments. ED will prioritize, to the extent possible, students who are homeless or at risk of becoming homeless as a result of displacement, and institutions that have sustained extensive damage, by a covered disaster or emergency.

Grantees may not use Program funds to supplant funds that otherwise would have been used for the same purpose, such as funds made available through an insurance policy, the Federal Emergency Management Agency (FEMA), a State, or a nonprofit relief organization, or any other third party. Grantees may use Program funds to supplement funds from such sources up to the full amount needed for emergency assistance.

Use of funds for a purpose authorized under the HEA is subject to the regulations that pertain to that purpose. For example, if activities under a particular grant program or financial aid program were disrupted and require emergency aid to become fully operational, Program funds for this purpose are subject to the regulations for that grant or aid program, except that any requirements relating to matching, Federal share, reservation of funds, or maintenance of effort under 20 U.S.C. 1087 — 51 et seq. or 1138 et seq. that would otherwise be applicable do not apply.

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10. What records must an IHE maintain after receiving Program funds?

Grantees and contractors that administer portions of a grant award must maintain adequate written records to support how funds were received, disbursed, and spent under the program. The records must be made available to ED, if requested, for the purpose of examination or audit. The full requirements regarding recordkeeping for ED grants are in 2 C.F.R. 200.333 — 200.337.

In particular, the "Bipartisan Budget Act of 2018" designates this program to be "susceptible to significant improper payments" for purposes of the Improper Payments Information Act of 2002 (31 U.S.C. 3321 note). See P.L. 115-123, the "Bipartisan Budget Act of 2018," Division B, Subdivision 1, Title XII, §21208(a), Feb. 9, 2018; 132 Stat. 108. Grantees will be required to undertake significant additional reporting as we implement plans to identify and reduce improper payments. We will provide additional information after we make awards.

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11. What is cash management?

Cash management refers to the various financial activities that a grantee must fulfill in order to comply with the grant funding requirements. Cash management regulations ensure that grantees develop and maintain effective financial systems with appropriate internal controls. These regulations are structured to minimize the time between fund draw-downs and the use of the funds, yet to ensure grantees have funds at the point of need.

Cash management policy is governed by law and applicable regulations. ED administrative regulations are published in 34 C.F.R. parts 75 — 77, 79, 81, 82, 84, 86, and 97 — 99, and include the regulations for administering discretionary and formula grants. The regulations pertaining to ED's cash management policies as they apply to grants are in 2 C.F.R. part 200.

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12. Who is responsible for cash management?

Grantees and subgrantees are responsible for maintaining internal controls regarding the management of Federal program funds under the Uniform Guidance in 2 C.F.R. 200.302 and 200.303. Grantees are responsible for ensuring that subgrantees are aware of the cash management requirements in 2 C.F.R. part 200, subpart D.

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13. Who is responsible for monitoring drawdowns to ensure compliance with cash management policies?

Grantees must monitor their own drawdowns and those of their subrecipients to ensure substantial compliance with the standards regarding timing and amount of advances.

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