In anticipation of a return to in-person classes in the future, institutes of higher education (IHEs) are offering incentives to students, faculty, and staff to get vaccinated against COVID-19 – and using Higher Education Emergency Relief Funds (HEERF) to do so. But is the use of HEERF funds for these incentives allowable under the guidelines?
In a recent FAQ released by the Department of Education, the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSA Act) section 314(c)(1) allows IHEs to use HEERF institutional grant funds to “defray expenses associated with coronavirus.” The Department of Education has stated that incentivizing students, faculty, and staff to get vaccinated is both a direct expense associated with COVID-19 and a risk mitigation strategy.
You can ensure that any incentive programs implemented are in compliance with the cost principles of the Uniform Guidance in 2 CFR part 200, subpart E.
In consultation with legal counsel at several colleges, we are advising clients that the use of HEERF funds for vaccine incentive programs is allowable. For more information, visit the Department of Education FAQ, or contact us directly at [email protected].