The U.S. Department of Education issued additional guidance to colleges and universities on May 11 regarding the appropriate use of funds allocated to institutions as part of the American Rescue Plan (“ARP”). The additional guidance was offered in the form of an FAQ identifying changes to requirements for higher education institutions regarding the use of federal COVID-related support.

The ARP includes $39.6 billion supporting higher education institutions under its Higher Education Emergency Relief Fund (“HEERF III”). This support follows two prior rounds of funding under the CARES Act in May 2020 (“HEERF I”), and CRRSAA in December (“HEERF II”). As with HEERF I and HEERF II, funding provided to higher education institutions under HEERF III is to be split between direct

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