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FAME REGULATORY UPDATE: U.S. Department of Education (ED) Releases Two Important Pieces of Guidance

(Note: FAME is aware the institutions are having problems locating the appropriate area to submit your completed Fund Certification and Agreement.  ED is aware of this problem and are working to address it.  FAME is closely monitoring the situation and will provide updates as soon as new information is available.)

Over the past twenty-four hours, ED has published and posted two important pieces of new guidance.

Midday yesterday, Secretary of Education Betsy DeVos announced the release of over $6 billion in funds to assist students enrolled at institutions of higher education that have been displaced as a result of the COVID-19 pandemic.

Around the same time, ED also released a new Frequently Asked Questions (FAQ) providing long awaited guidance regarding questions our community and other portions of the higher education community submitted in response to the Financial Responsibility Final Rules.

Below FAME has attempted to provide you with links to this new guidance and information.  We are in the process of reviewing it ourselves and plan to provide summaries and updates early next week and discuss all of this information on the next FAME Webinar on Wednesday, April 14, 2020.

Please review the brief summaries and information below.

CARES Act: Education Stabilization Funds—Higher Education Emergency Relief Funds

Throughout the day yesterday, ED shared an array of information providing the higher education community with the first real guidance on the distribution of a portion of the higher education emergency funds under the CARES Act.

All of the guidance and information focuses upon the release of student funds which are expressly stated to be used to cover 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).

As we believe you are aware, this is only half of the funds that will ultimately be released to your institution, with another separate process yet to be defined, that will provide access to an equal amount of funds for institutional relief.  Information on this process will come from ED in the weeks ahead.

For now, FAME encourages our clients to take some time to review and complete the Funding Certification and Agreement, hold internal discussions on how your institutions plans to distribute the funds, including appropriate polices and procedures you will undertake to monitor the allocation and disbursement of the funds in order to fulfill the reporting requirements, and then submit your documents using the website.

Your institution has a year to disburse the funds, and while we understand that you are hoping to provide these funds to your students as soon as possible, we respectfully suggest that you proceed slowly and with caution in the disbursement of these funds.


Student Portion of Higher Education Emergency Relief Funding under CARES Act:

Department’s April 9th Press Release

Department’s Allocation of Higher Education Emergency Relief Funds to Institutions

Department’s April 9th Letter to Institutions of Higher Education

Student Funding Certification and Agreement Education Submission Site

Financial Responsibility and Administrative Capability Guidance

The following FAQ provides additional guidance related to the Final Rule on Financial Responsibility published by ED last year. FAME encourages institutions to review the document and will be sharing our own summary and analysis of updates contained within next week.

Financial Responsibility Q&A


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