The Coronavirus Response and Relief Supplemental Appropriations Act 2021 (CRRSAA) was signed into law (Pub. L. 116-260 (Dec. 27, 2020)) which provides additional funds for the Higher Education Emergency Relief Fund (HEERF) to assist public and private nonprofit colleges and universities in preparing for, preventing and responding to the COVID-19 global pandemic. These funds are separate from those awarded under the American Rescue Plan and Coronavirus Aid, Relief and Economic Security (CARES) Act.
Pursuant to Section 314(a)(1) of CRRSAA the USDOE allocated an additional $3,531,956[FN1] .00 to the college. This award is separate from the funding made available for the CRRSAA Emergency Financial Aid Grants to Students described above and the CRRSAA Strengthening Institutions Programs funds described below.
The college may use the award to defray expenses associated with coronavirus (including lost revenue, reimbursement for expenses already incurred, technology costs associated with a transition to distance education, faculty and staff trainings, and payroll); carry out student support activities authorized by the Higher Education Act of 1965, as amended (HEA) that address needs related to coronavirus; and make additional financial grants to students, which may be used for any component of the student’s cost of attendance or for emergency costs that arise due to coronavirus, such as tuition, food, housing, health care (including mental health care), or child care.
No grant funds may be used to fund contractors for the provision of pre-enrollment recruitment activities; marketing or recruitment; endowments; capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship; senior administrator or executive salaries, benefits, bonuses, contracts, incentives; stock buybacks, shareholder dividends, capital distributions, and stock options; or any other cash or other benefit for a senior administrator or executive.
The college may, but is not required to, use this Institutional portion to provide additional financial aid grants to students. If the college chooses to use this Institutional portion to provide additional financial aid grants to students, then these funds are subject to the requirements in the Public and Nonprofit Institution Grant Funds for Students Certification and Agreement.
The college may charge indirect costs to funds made available under this CRRSAA award. As the college does not have a current negotiated indirect cost rate with its cognizant agency for indirect costs, it will appropriately charge the de minimis rate of ten percent of Modified Total Direct Costs (MTDC). The college may also charge reasonable direct administrative costs to funds made available under this CRRSAA award.
The college acknowledges that any obligation under this CRRSAA grant (pre-award costs pursuant to 2 CFR § 200.458) must have been incurred on or after March 13, 2020, the date of Proclamation of the National Emergency.
Consistent with Section 315 of the CRRSAA 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 notify the USDOE within 30 days of making a determination that it is required to remit payment to the Internal Revenue Service for the excise tax paid on investment income of private colleges and universities under section 4968 of the Internal Revenue Code of 1986 for tax year 2019 via the Required Notification of Endowment Excise Tax Paid form, pursuant to section 314(d)(6) of the CRRSAA.
The college will comply with all reporting requirements (including those in Section 314(e)of the CRRSAA and submit required reports to the USDOE, at such time and in such manner and containing such information as the USDOE may reasonably require.
The Georgia Department of Audits and Accounts is the state agency that reviews the combined financial statements of the Technical College System of Georgia and its units, which includes this college. The college complies with GDAA’s requirements.
The college will comply with the provisions of all applicable acts, regulations and assurances; the following provisions of Education Department General Administrative Regulations (EDGAR) 34 CFR parts 75, 77, 81, 82, 84, 86, 97, 98, and 99; the OMB Guidelines to Agencies on Government wide Debarment and Suspension (Non-procurement) in 2 CFR part 180, as adopted and amended as regulations of the Department in 2 CFR part 3485; and the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR part 200, as adopted and amended as regulations of the Department in 2 CFR part 3474.
The college acknowledges it is under a continuing affirmative duty to inform the USDOE if the college is to close or terminate operations as an institution or merge with another institution.