The Coronavirus Aid, Relief and Economic Security (CARES) Act was signed into law (Pub. L. 116-136, 134 Stat. 281 (March 27, 2020) and established the Higher Education Emergency Relief Fund (HEERF) for colleges to distribute emergency financial aid grants to students and institutions of higher education. These funds are separate from those awarded under the American Rescue Plan and Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA).
The U.S. Department of Education (“USDOE”) has allocated $935,054.00 to South Georgia Technical College (“the college”) for these emergency financial aid grants to students. The college has signed and returned the Certification and Agreement to the U.S. Department of Education on April 22, 2020 for the CARES Act Grant in the amount of $935,054 to be distributed to eligible students.
Student Portion Distribution Plan and ReportingPursuant to Section 18004(c) of the CARES Act (“Institutional Aid Portion”), the USDOE allocated $1,870,108.00 to the college. This award is separate from the funding made available for Emergency Financial Aid Grants to Students described above and the Strengthening Institutions Program portion described in the next section below.
The college has signed and returned to the USDOE the Certification and Agreement and the assurance that the College intends to use the award for any costs associated with significant changes to the college’s delivery of instruction due to the COVID-19 pandemic. Such costs do not include payment to contractors for the provision of pre-enrollment recruitment activities, including marketing and advertising; endowments; or capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship.
Pursuant to the CARES Act, the college retains discretion in determining how to allocate and use the award provided, as long as the funds are spent only on those costs for which the college has a reasoned basis for concluding such costs have a clear nexus to significant changes to the delivery of instruction due to the coronavirus. Allowable costs include the college’s Institutional Costs first incurred on or after March 13, 2020 (the date of the Proclamation of National Emergency (Federal Register Vol. 85, No. 53 at 15337-38)), such as reimbursing itself for costs related to refunds made to students for housing, food, or other services that the college could no longer provide; for hardware, software, or internet connectivity that the college may have purchased on behalf of students or provided to students; the college’s technology costs associated with a transition to distance education; the college’s costs to build its IT capacity to support such programs; or to train faculty and staff to operate effectively in a remote teaching and learning environment.
Consistent with Section 18006 of the CARES Act and to the greatest extent practicable, the college will pay all of its full-time employees and contractors during the period of any disruptions or closures related to the coronavirus. The following expenditures are disallowed: senior administrator and/or executive salaries, benefits, bonuses, contracts, incentives; stock buybacks, shareholder dividends, capital distributions, and stock options; and any other cash or other benefit for a senior administrator or executive.
The college will comply with all reporting requirements (including those in Section 1501 l(b)(2) of Division B of the CARES Act) and submit required quarterly reports to the USDOE, at such time and in such manner and containing such information as the USDOE may reasonably require.
The expanded use of funds authority under the CRRSAA (Coronavirus Response and Relief Supplemental Appropriations Act, 2021) also applies to unexpended CARES Act funds. For its Institutional Portion CARES Act grants (CFDA 84.425F), the college is able to use its remaining funds in the same way they are allowed to use their supplemental Institutional Portion funds under the CRRSAA. The college has this expanded flexibility to use unliquidated (unspent) funds effective.
Quarterly Budget and Expenditure Reporting under CARES Act Sections 18004(a)(1) Institutional Portion, 18004(a)(2)