As the effects of COVID-19 continue to ring throughout the nation’s education system, the federal government has been rolling out about $30 billion in aid under the Education Stabilization Fund in the CARES Act. The fund consists of a $13 billion Elementary and Secondary School Emergency Relief Fund, a $14 billion Higher Education Emergency Relief Fund, and a $3 billion Governor’s Emergency Education Relief Fund (GEERF).

An analysis of state postsecondary plans in these applications reveals that most states have not identified specific uses for the funds—in particular, the portion and targets of funds they intend to use for higher education—and there is important follow-up work to ensure that students most impacted by COVID-19 receive support through these dollars.

GEERF awards governors flexible discretionary funds to support local educational agencies (LEAs), institutions of higher education (IHEs), and other education-related entities considered essential during the pandemic. The grants are distributed by the U.S. Department of Education as subgrants or contracts to the eligible entities who have been “most significantly impacted by coronavirus” and/or deemed essential in providing emergency education services. The Department of Education determined each states’ allotment through a specific formula, and states submitted applications in early June. An analysis of state postsecondary plans in these applications reveals that most states have not identified specific uses for the funds—in particular, the portion and targets of funds they intend to use for higher education—and there is important follow-up work to ensure that students most impacted by COVID-19 receive support through these dollars.


When Congress passed the CARES Act, it allocated approximately $3 billion in grants to be made available to governors in all fifty states, as well as to the District of Columbia and the Commonwealth of Puerto Rico. It distributed the grants based on the state, territory, or district’s population (ages 5–24) and the aggregate of students aged 5–17, as stated under section 1124(c) of the Elementary and Secondary Education Act (ESEA).1

To access the funds, governors submitted an application to the Department of Education; all states did so, and all have been approved. The application criteria included a statement on how the state determined which LEAs and/or IHEs were “most significantly impacted by coronavirus,” and/or which other education-related entities were “essential for carrying out emergency educational services.” Use of the funds is restricted to covering expenses incurred on or after March 13, 2020, and for the sole purpose of supporting “ongoing functionality” of LEAs, IHEs, and education-related entities in the continuation of providing emergency educational services; the funds cannot be used for directly awarding scholarships, microgrants, or financial aid to students/teachers, but can be used indirectly.2 States have one year to award the funds, and are expected to adhere to a maintenance of effort (MOE) requirement, under which they must maintain the same level of support for K–12 and higher education in fiscal years 2020 and 2021 that they maintained in the previous three fiscal years. If a state says it is unable to follow the MOE due to a decline in financial resources, they may submit a waiver to the secretary of education for consideration.

The Department of Education recently released guidance on the MOE regarding the types of data that the department would consider as state support for education, such as state need-based financial aid, and which it would not, such as any local government contributions. Importantly, the secretary of education will not consider waivers until the end of FY 2021, which presumably makes it less likely that they will enforce the MOE retroactively.

How States Plan to Use Funds for Higher Education

State applications for GEERF ranged considerably in the level of detail they provided, and even states that have not formulated a plan for the money received approval.3 Below is a summary of common themes found in state applications pertaining to their higher education plans.4

Split between Higher Education and K–12 Education

Of all of the applicants, at least five are using their funds only for K–12 education; thirty-six explicitly say they will use some of their funds for higher ed and K–12; and eleven are unclear. California, Delaware, New York,5 Puerto Rico, and Utah are the applicants who are using GEERF for K–12. California has specifically released a budget summary discussing its $355 million allotment as it considers the impact COVID-19 has had on its schools.

While the vast majority of states broadly expressed allocating funds to K–12 and higher education, only two states gave specifics on how the funds would be split; Kentucky is allocating one-third of GEERF ($13.8 million) toward its IHEs, and Alaska allotted $1.5 million to its IHEs, $200,000 to secondary and higher education—specifically, Alaska’s Native Science and Engineering Program—and $1 million in competitive grants.

Focus on Remote Learning

The GEERF applications reveal that almost all fifty states are primarily focusing on improving remote learning. Due to the shift to online coursework, many states are focused on students in rural areas and low-income families who often do not have access to computers or do not have a reliable internet connection. As a result, states are purchasing and distributing hardware and software for students who do not have access to technology, spending on such items as Chromebooks/laptops, Wifi hotspots, mobile hotspots, enhancing online platforms, and technological infrastructure, and so on. For example, Rhode Island secured Chromebooks/laptops and mobile hotspots for their low-income students, and may use GEERF to continue technological support and connectivity for both K–12 and higher education students. In another example, Texas is planning to address instructional designs that are a barrier to effective remote learning, such as developing and implementing online educational resources.

Alternatives and Supplements to Remote Learning

While most of the GEERF application focused its questions on remote learning, several states supplied alternative plans for higher education, such as providing professional development training for teachers and staff to improve quality of teaching during the pandemic, distributing state aid grants to low-income students or students impacted by COVID-19, covering the salary of faculty and staff, and/or supporting additional institutional operations:

  • Broad strategic support to institutions. Alaska has created $1 million in competitive grants to support eligible education-related entities in their endeavors to innovate strategies that will provide emergency educational services to students, child care and early childhood education, social and emotional support, and protect education-related jobs. Kentucky intends to provide funds for strategic planning and direct resources to aid IHEs as they reopen in the fall to unknown enrollment numbers and student engagement; the funds will also be used to provide remote mentoring and advising for freshman and returning students as a result of distant learning. Kansas intends to use some of the funds to cover the salaries of faculty and staff, maintain institutional operations, and aid students experiencing homelessness, including wraparound services, such as food, health services, and social support. And Nevada intends to provide professional development and additional support services for their IHE educators for remote learning.
  • Community colleges, adult education, and CTE. Arkansas wants to broaden workforce education initiatives and provide IHEs with grants to enhance employability skills through career training programs. Wyoming is awarding funds to its community colleges and local Adult Education providers to serve its disadvantaged population, including potentially providing computer labs, professional development, and increased instructional hours for adult education.
  • Financial aid. Three states mention using funding for grant aid. Connecticut is using a portion of GEERF for need-based financial aid via an existing state scholarship for students facing financial barriers, and Kentucky also mentions helping IHEs with targeted financial aid. New Hampshire mentions scholarships for low-income students, but it is not clear if this will be for K–12 or postsecondary education.
  • Data infrastructure. Texas plans to use a portion of their funds to develop data infrastructure for students, institutions, employers, and policymakers for advising and efficiency as it pertains to students’ “progress-to-credential,” including a potential interactive advising tool that could help students choose an IHE, compare programs of interest, apply for financial aid, and more.

Retaining Students and Dual Enrollment

Some states, such as Alaska, Illinois, and Tennessee, plan to use a portion of their funds to retain students who may drop out of school as a result of COVID-19’s impact on their financial situations, or encourage students to attend college through dual enrollment:

  • In 2019, the University of Alaska Fairbanks began a pilot dual enrollment program, and a portion of GEERF will be used to expand it to provide opportunities for students to access college-level courses and receive dual credit for completion.
  • Illinois has formed a “funding methodology” that will prioritize the immediate needs of vulnerable students who may drop out of school due to COVID-19. This effort includes supporting technological capacity of vulnerable students who are low income, rural, and students of color to attract and retain vulnerable students as they graduate high school and transition to college during COVID-19, and graduating the most vulnerable students.
  • Tennessee has listed early dual enrollment as one of their initiatives to educate students and sustain academic progress.

Defining “Impacted Institutions”

Though it is not clear how states will determine which institutions are “most significantly impacted by coronavirus,” or how much funds should be awarded to them as a result, a few states gave some indication. For example, using data from the Department of Education’s IPEDS data system and the Tennessee Higher Education Commission’s student data system, Tenneesse created funding allocations for its IHEs based on the proportionate share of low-income students at each institution, who are defined as undergraduate students receiving Pell grants and institutions who award only graduate degrees as students whose household income is less than $36,000 annually.

Illinois, on the other hand, states that it has established a funding methodology to distribute dollars, and Indiana is developing a need-based criteria with their relevant state agencies using equity indicators and current tech access data.

Vague Applications

The U.S. Department of Education approved applications from states that had effectively left the entire use of funds section blank.6 Email correspondence7 with those states indicate that they do intend to use the funds, but are still finalizing how to do so. In addition, several other state applications are unclear regarding how funds will be used, whether it be the result of vague responses, missing text due to formatting issues, or the state still finalizing its decision.8

Supporting Students in Higher Education

While it is unclear how many states will focus the majority of their GEERF funds primarily on K–12 education, it is likely that many will, given the acute needs. Because few dollars may be available, states who do use some of the funds to support their institutions of higher education should prioritize sending these dollars to supporting the students who need it the most. For example, states can do the following:

  • Identify vulnerable student populations left out of the CARES Act emergency grant (HEERF) funding and fill these gaps with GEERF dollars.
  • Target dollars to support institutions that are underresourced but serve large populations of low-income students and students of color.
  • Consider using these funds to support their existing need-based financial aid programs.

Unfortunately, the short turnaround for applications has meant that states received approval while providing little information about their plans. The Department of Education should ensure that, as states report in on their actions over the next forty-five days, they are able to justify allocation choices that have truly supported students who are most significantly impacted.

As many IHEs continue to struggle financially to maintain and provide quality education to their students during COVID-19, further federal support for public higher education will be critical. Institutions with large populations of disadvantaged students such as those who are low-income and students of color are the ones most affected by COVID-19’s impact on the education system. As the federal government continues to consider additional aid and funding to institutions of higher education, and as states finalize plans to allocate CARES Act dollars available through GEERF, they should keep in mind the underresourced and marginalized groups of students who need their help the most.


  1. Each state has a specific allotment based on 60 percent of the state’s population aged 5-–4 and 40 percent of the relative number of children counted under section 1124(c) of ESEA, which takes into account poverty rates.
  2. Governors can provide subgrants to eligible entities who can then provide scholarships to students consistent with the CARES Act.
  3. More information may be forthcoming, as within forty-five days of receiving the grant, each state must report to the Department of Education an initial report describing the process it took to formulate a criteria for disbursing funds.
  4. The list below is not exhaustive, and further details are provided in the GEERF applications located on the Department of Education’s website. At the time of publication, the links to the application were down.
  5. New York’s application says its funds are for its school districts, and so was included in the list of states only using these dollars for K–12 education.
  6. In the relevant section of the application asking states if they intended to use funds for remote learning, to support technological capacity including access and “instructional expertise,” and/or developing informational and academic resources and making aware and providing access to “best practices and innovations in remote learning” for students, families, and educators, Vermont recorded its responses as “Not at this time,” and Utah with “The Governor does not intend to use GEER funding for this purpose at the state level.”
  7. Dominique Eaton, personal communication, June 11, 2020.
  8. Specifically Arizona, D.C., Florida, Michigan, Mississippi, Montana, Nebraska, New Mexico, North Carolina, Wisconsin, and Vermont.