CARES Act HEERF Student Share Grant Policy

Loyola University of Chicago

CARES Act HEERF Student Share Grant Policy
for the Award and Administration of Funds

Adopted May 11, 2020

I. Background

On Friday, March 27, 2020, the federal government enacted the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”). Section 18004 of the CARES Act establishes the Higher Education Emergency Relief Fund (“HEERF”). The HEERF provides emergency funding to institutions of higher education, including funds that must go directly to students in the form of emergency financial aid grants (the “HEERF Student Share Grant Funds”) for “expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student’s cost of attendance, such as food, housing, course materials, technology, health care, and child-care)” (the “HEERF Eligible Expenses”).

Following are some key dates and decisions taken by Loyola University of Chicago (the “University”) which may have contributed to expenses incurred by students related to the disruption of campus operations due to the COVID-19 pandemic (“Disruption of Campus Operations”):

• On February 29, 2020, the University announced its decision to repatriate all students studying in Italy at the John Felice Rome Center (“JFRC").
  
  
• On March 12, 2020, the University announced a number of actions in response to the COVID-19 pandemic, with two primary objectives: 1) to de-densify the University’s on-campus population by transitioning from face-to-face education to online/distance learning; and 2) to ensure that there was no disruption in the academic progress of our students.
  
  
  • Effective March 13, 2020, all in-person, face-to-face classes were suspended and moved to online/virtual instruction effective Monday, March 23, 2020.
    
    
  • All residential students were instructed to leave campus for the semester. Residence halls were subsequently closed at the end of the day on March 19, 2020.
    
    
  • The University required all remaining study-abroad students to repatriate to their homes by March 20, 2020. All international summer programs were suspended.
    
    
  • On March 19, 2020, substantially all on-campus food service operations were suspended.
    
    
  • On March 20, 2020, campus buildings were closed to all except essential personnel.

II. Purpose and Scope

Loyola University of Chicago is eligible to receive up to $5,021,974 in HEERF Student Share Grant Funds. Under Section 18004(c) of the CARES Act, these funds must be used for HEERF Eligible Expenses.

III. Policy

The CARES Act requires that institutions disburse the HEERF Student Share Grant Funds to eligible students for HEERF Eligible Expenses. Students in associate’s, bachelor’s, graduate, professional and certificate programs may apply for the HEERF Student Share Grant Funds. This policy presents the University’s methodology for determining eligibility under the CARES Act, as well as the process and procedure for distributing and disbursing the HEERF Student Share Grant Funds. HEERF Student Share Grant Funds cannot be applied by the University toward a student’s account balance.

A. Eligibility

Under the CARES Act and subsequent administrative interpretation provided by the Department of Education (“ED”), students eligible to receive HEERF Student Share Grant Funds (“Eligible Students”) must meet all eligibility criteria listed below:

i. Students must have completed a Free Application for Federal Student Aid (“FASFA”) for the 2019-2020 Academic Year and be deemed eligible for Title IV aid.

According to Section 9 of the Department of Education FAQ guidance issued on April 21, 2020, only students who are or could be eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (“HEA”), may receive HEERF Student Share Grant Funds.

The University has concluded that the only practicable way to determine that a student is eligible to participate in the Title IV programs and meets all applicable student eligibility requirements is if the student has a completed FAFSA, has received an official Student Aid Report (“SAR”), has a valid Expected Family Contribution (“EFC”) on file for the 2019-2020 Academic Year, and meets all other Section 484 eligibility criteria.

Loyola students who had not previously submitted a FAFSA were notified via email on April 28, 2020 and advised to submit a FAFSA no later than Saturday, May 2, 2020, by going to studentaid.gov. Students who submit a 2019-2020 FAFSA after May 2, 2020, may be eligible, pending available funds.

Note: For the Spring 2020 academic term, the University’s enrollment totaled approximately 17,000 students including students enrolled primarily in associate’s, bachelor’s, graduate, and professional programs. Of the total enrollment, approximately two-thirds of students had filed a FAFSA. 

ii. Students must have been enrolled in a Title IV eligible degree-seeking or certificate program at the time of the Disruption of Campus Operations.

Students who have an effective withdrawal date prior to March 13, 2020 cannot receive HEERF Student Share Grant Funds. March 13, 2020 is the date on which on-campus instruction was suspended, disrupting the University’s normal campus operations, as described above, and giving rise to HEERF Eligible Expenses. 

iii. Students must have been enrolled for the Spring 2020 academic term in at least one ground-based class as of March 13, 2020, i.e., not enrolled in an exclusively online program.

iv. Students must submit a University HEERF Student Share Grant application.

Students NOT eligible for HEERF Student Share Grants
Examples of students who are not eligible for HEERF Student Share Grants include: dual-credit high school students; international, undocumented, and DACA students; students enrolled exclusively in an online academic program as of March 13, 2020; and any student who is not eligible to receive Title IV funds.

B. HEERF Eligible Expenses

Eligible Students who have incurred HEERF Eligible Expenses are eligible to receive HEERF Student Share Grant Funds, provided such expenses have not been previously reimbursed by the University.

HEERF Eligible Expenses must have been incurred no earlier than March 13, 2020.

Note: Students at the JFRC, or other University-approved study-abroad programs who were reimbursed by the University for travel-related expenses may apply for a HEERF Student Share Grant to cover HEERF Eligible Expenses other than such previously reimbursed travel-related costs.

C. HEERF Student Share Grant Amounts

Consistent with the ED’s April 9, 2020 letter, the University has decided to prioritize students with the greatest need, but at the same time establish a maximum funding threshold for each student to ensure that these funds are distributed as widely as possible. For purposes of this policy, the University has determined that EFC is an appropriate proxy for student financial need. The University has also determined that distributing the HEERF Student Share Grant Funds as follows is consistent with the CARES Act and the ED’s guidance:

i. A total of $4.5 million, or approximately 90%, of the HEERF Student Share Grant Funds, will be made available to Eligible Students based on the initial applications received (the “$4.5M”).

The maximum HEERF Student Share Grant to an Eligible Student is expected to be $1,500 (the “Maximum Award”). Given the number of University students who may be eligible, and depending on the actual number of applications received and the grant funds requested in the applications, and consistent with the goal of prioritizing students with the greatest need, individual grants may be more or less than such Maximum Award.

ii. Remaining HEERF Student Share Grant Funds (“The Remaining Funds”) will be made available to Eligible Students on a case-by-case basis, consistent with the above eligibility guidelines and taking into account individual student circumstances.

IV. Procedures

A. Applying for a HEERF Student Share Grant
Eligible Students may apply for a HEERF Student Share Grant by completing an online application on the University’s website (the “Application”). Once the Application is made available to students, the University will accept such online Applications for an initial period of two weeks (the “Priority Application Period”). See Appendix A of this Policy for a Sample Application.

B. Documentation to Accompany the Application
As part of their Application, Eligible Students must provide receipts, other expense documentation, or an explanation and self-certification as to the HEERF Eligible Expenses listed in the Application.

C. Review and Decision
The University will accept online Applications during the Priority Application Period, verify student eligibility, and review expense documentation and certifications in order to establish eligible applications (“Eligible Applications”).

If the total value of Eligible Applications received during the Priority Application Period exceeds the $4.5M (based on the lesser of the amount requested and supported or the Maximum Award), the University will distribute the $4.5M by ranking the Applications based on lowest to highest EFC until the cumulative grants total $4.5M.

If the total value of Eligible Applications received during the Priority Application Period is less than or equal to the $4.5M, the University will rank the Applications based on lowest to highest EFC and approve each Eligible Application for the lesser of the amount requested and supported or the Maximum Award. The University will use any remaining balance of the $4.5M and the Remaining Funds to make additional awards consistent with the CARES Act and this policy. For example, the University may increase the Maximum Award for Eligible Applications from students having the greatest financial need, or take such other allowable actions until such time as the remaining balance of the $4.5M, and all Remaining Funds, are fully awarded.

D. Disbursing HEERF Student Share Grants
The University will make every effort to disburse the HEERF Student Share Grants as soon as practicable following the close of the Priority Application Period. While not a guarantee, the University anticipates that funds will be distributed no later than two weeks from the close of the Priority Application Period. Distribution updates will be posted online.

The University will disburse the HEERF Student Share Grants to students via the LOCUS Student Account system, but in no event shall the University apply any portion of such funds to pay down any balance owed by the student to the University. The CARES Act and ED guidance prohibits any such use.

Payments will be made via electronic transfer to the student’s bank account indicated in LOCUS. Students who do not have bank account information in LOCUS will be paid via check mailed to the student’s permanent address in LOCUS. Students will receive an e-mail notification once any disbursement is made.

E. Reporting and Tax Compliance
The University will comply with ED status update reporting requirements as required by the CARES Act.

The University will issue the appropriate tax documents to students for these HEERF Student Share Grants, if any, as required by the Internal Revenue Service. The Internal Revenue Service has provided interim guidance stating that the HEERF Student Share Grants are not taxable income to the students who receive such funds.

V. Resources

• HEERF Student Share Grant Online Application
• Appendix A: Sample Application
• U.S. Department of Education (ED): CARES Act: Higher Education Emergency Relief Fund