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Defraying Costs of Enrolling Displaced Students

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Fequently Asked Questions

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  1. What is the purpose of the Defraying Costs of Enrolling Displaced Students Program?
  2. How will the U.S. Department of Education (ED) award Program funds?
  3. For what purposes and activities may an IHE use Program funds?
  4. What is an IHE?
  5. May proprietary IHEs receive Program funds?
  6. May students apply directly to ED for Program funds?
  7. If the operations of an IHE were not disrupted, but some of its students were displaced, is the IHE eligible to receive Program funds?
  8. If an IHE has enrolled students who were displaced for a reason other than that operations at their IHEs were disrupted, is the IHE eligible to receive Program funds?
  9. What does it mean that “operations have been disrupted”?
  10. May an IHE use Program funds to defray the costs of administering its grant?
  11. What records must a Receiving IHE maintain after receiving Program funds?
  12. What is cash management?
  13. Who is responsible for cash management?
  14. Who is responsible for monitoring drawdowns to ensure compliance with cash management policies?

1. What is the purpose of the Defraying Costs of Enrolling Displaced Students Program?

This program (Program) will provide funds to institutions of higher education (IHEs) to help defray the unexpected expenses associated with enrolling displaced students from those IHEs at which operations have been disrupted by a covered disaster or emergency (Affected IHEs), namely Hurricanes Harvey, Irma, and Maria and the California 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?

ED will accept and evaluate applications for initial funding from IHEs that have enrolled displaced students (Receiving IHEs). Most funds will be awarded to institutions that have enrolled displaced students during the 2017–2018 academic year in order to help defray the unexpected expenses of enrolling these students for the first time. Some funds will be reserved by ED for future grants to help defray the expenses of enrolling displaced students in later academic years, or for other authorized purposes.

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

A Receiving IHE may use Program funds only to defray the unexpected expenses associated with enrolling displaced students from Affected IHEs. Allowable expenses include the costs of waivers of tuition, fees, room (housing), and board (food). Other costs may be allowed later if funds are available.

Grantees may not use Program funds to supplant funds that would have been or have already been provided for the same purpose, such as a transfer of a displaced student’s tuition dollars from the Affected IHE to the Receiving IHE, or funds made available through the Federal Emergency Management Agency (FEMA), a State, or a nonprofit relief organization. Grantees may use Program funds to supplement funds from such sources up to the full amount needed to pay the unexpected enrollment expenses in full.

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4. What is an IHE?

An eligible IHE must meet the definition of “institution of higher education” in section 101 or section 102(a)(1) of the Higher Education Act of 1965, as amended (20 U.S.C. 1001 and 1002(a)(1)) and in ED’s regulations at 34 C.F.R. (volume 34 of the Code of Federal Regulations) part 600.

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5. May proprietary IHEs receive Program funds?

Yes. The authorizing legislation for the Program does not distinguish a proprietary IHE from other IHEs.

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

No. This Program assists IHEs with expenses incurred while serving displaced students.

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7. If the operations of an IHE were not disrupted, but some of its students were displaced, is the IHE eligible to receive Program funds?

An IHE is not eligible for funds for displaced students who are not from an Affected IHE, that is, an IHE at which operations have been disrupted by a covered disaster or emergency.

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8. If an IHE has enrolled students who were displaced for a reason other than that operations at their IHEs were disrupted, is the IHE eligible to receive Program funds?

An IHE is not eligible for funds for displaced students who are not from an Affected IHE, that is, an IHE at which operations have been disrupted by a covered disaster or emergency.

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9. What does it mean that “operations have been disrupted”?

There is no fully determinative and objective standard that can capture all possible scenarios. At a minimum, the Affected IHE must be in an area where IHEs are eligible for aid due to a covered disaster or emergency, but the Affected IHE’s operations also must have been disrupted by the covered disaster or emergency. One way of assessing whether operations have been disrupted is to examine whether academic classes or other core services, such as room and board, were significantly disrupted such that students have self-reported to the Receiving IHE that they were displaced because of the disruption, or such that the Affected IHE issued a call for assistance for its displaced students.

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10. 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 the determination of 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 and 75.560–76.564 regarding indirect costs).

An IHE that receives or has received the full amount for displaced students that it normally charges for tuition, fees, housing, or board will be considered to have already recovered all of its indirect costs for that tuition, fee, housing, or board, and may not “double dip” for indirect costs by seeking additional funds for indirect costs for such items.

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11. What records must a Receiving 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.

For each year of the Program, the grantee must submit a report to the Secretary, at such time and in such manner as the Secretary may require, that includes:

  • the activities performed under the Program;
  • how the Grantee distributed the funds it received, including the funds used for each authorized activity;
  • a list of the displaced students, by anonymous unique identifier, such as student identification number, for whom the Grantee engaged in enrollment activities funded under this program, as a result of each covered disaster or emergency, including, for each student, (1) the institution from which the student was displaced, and (2) the covered disaster or emergency that resulted in the student being displaced; and
  • a description of the internal controls the Grantee had in place to ensure that funds were used for allowable purposes and in accordance with cash management principles.

Grantees should not send ED any personally identifying information about individual students (other than student identification number) unless ED specifically asks for this information due to, for example, an audit to identify possible improper payments.

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12. 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 drawdowns and the use of the funds, while also ensuring that grantees have funds at the point of need.

The Department’s cash management policies are reflected in 34 C.F.R. parts 75–77 and 79, including 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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13. Who is responsible for cash management?

Grantees 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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14. 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 the timing and amount of advances.

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Last Modified: 05/03/2018