CARES Act Information

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Final Report by Houston Graduate School of Theology Regarding Administration of Section 18004(a)(1) CARES Act Grant Program Related to Student Aid Portion Funds

Section 18004(e) of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act” or the “Act”)), Pub. L. No. 116-136, 134 Stat. 281 (March 27, 2020), directs institutions receiving funds under Section 18004 of the Act to submit (in a time and manner required by the Secretary) a report to the Secretary describing the use of funds distributed from the Higher Education Emergency Relief Fund (“HEERF”). Section 18004(c) of the CARES Act requires institutions to use no less than 50 percent of the funds received from Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students for expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student’s cost of attendance such as food, housing, course materials, technology, health care, and child care). On April 9, 2020, the Department published documents related to the Emergency Financial Aid Grants, including a letter from Secretary Betsy DeVos, a form Certification and Agreement for signing and returning by institutions to access the funds, and a list of institutional allocations under 18004(a)(1).

HGST was pleased to receive and administer these aid funds to HGST students from the Federal CARES Act grant program. Please note the following itemized aspects of the report.

  • HGST signed and returned to the Department of Certification and Agreement an application stating that the school would use no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to Students.

  • HGST received $10,621 from the Department pursuant to the institution’s Certification and Agreement for Emergency Financial Aid Grants to Students.

  • A total of $10,621 was subsequently distributed to HGST students.

  • A total of 136 HGST students were eligible to receive the funds, and 21 submitted some portion of the application although 3 were not qualified due to the required enrollment dates.

  • A total of 10 HGST students sufficiently completed the application process by the stated deadline and received grants from this source.

  • The following method was used by the school to determine which students would receive grants: a Student HEERF Grant Committee was appointed by the HGST President comprised of the President, Academic Dean, COO/CFO, Director of Admissions/Communications, and Director of Financial Aid/Student Services; an online application form was developed along with a cover letter inviting students to submit applications; the letter and application form were made available to all qualified HGST students; fully completed applications received by the stated deadline were assessed by the Grant Committee in terms the students’ descriptions of the affects of the pandemic on them in view of the criteria stated in application form and letter; 10 students completely submitted the application form as directed and by the deadline. The Committee awarded those students the funds in equal portions or $1,062.10 per student, dispersed by check on Oct. 8, 2020

  • The following instructions, directions, and guidance for students were included in the application cover letter.

  • The application form contained the following content.

Quarterly Budget and Expenditure Reporting under CARES Act Sections 18004(a)(1) Institutional Portion, 18004(a)(2), and 18004(a)(3), if applicable

Institution Name: Houston Graduate School of Theology
Date of Report
: 2/2/21
Covering Quarter Ending: 9/30/20
Total Amount of Funds Awarded:
Section (a)(1) Institutional Portion: $ 0
Section (a)(2): $ 0
Section (a)(3): $82,320
Final Report? ☒


[1] To support any element of the cost of attendance (as defined under Section 472 of the Higher Education Act of 1965, as amended (HEA)) per Section 18004(c) of the CARES Act and the Interim Final Rule published in the Federal Register on June 17, 2020 (85 FR 36494). Community Colleges in California, all public institutions in Washington State, and all institutions in Massachusetts have different requirements due to recent U.S. District Court actions. Please discuss with legal counsel. HEERF litigation updates can be found here.
[2] Including costs or expenses related to the disinfecting and cleaning of dorms and other campus facilities, purchases of personal protective equipment (PPE), purchases of cleaning supplies, adding personnel to increase the frequency of cleaning, the reconfiguration of facilities to promote social distancing, etc.
[3] Including continuance of pay (salary and benefits) to workers who would otherwise support the work or activities of ancillary enterprises (e.g., bookstore workers, foodservice workers, venue staff, etc.).
[4] Please post additional documentation as appropriate and briefly explain in the “Explanatory Notes” section. Please note that costs for Section 18004(a)(1) Institutional Portion funds may only be used “to cover any costs associated with significant changes to the delivery of instruction due to the coronavirus, so long as such costs do not include payment to contractors for the provision of pre-enrollment recruitment activities; endowments; or capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship.”