Mark, while retired, I am not yet dead, so I have been trying to keep track of HEERF funding. When I was director at Scranton, we used HEERF I funding trying to adhere to the spirit of the law and altering guidance provided by ED. We used an online application asking all eligible students, both UG and on campus Grad students, to identify additional expenses caused by the disruption of on campus learning. We honored all requests, with limitations set for each category of expenses: transportation, technology, books and supplies, etc…. without regard to demonstrated financial need. HEERF II and I suppose III appear to allow much more flexibility. Prior to my retirement, I did provide the administration some suggestions on how to award the II funds that had been legislated using a tiered need approach like what you are considering and reserving a smaller pool to address any specific needs that may be identified through an application— technology needs, additional costs that may occur due to COVID 19 restrictions, etc… I’m unsure when III funds need to be spent and share Greg’s concern on how much layering of funds to the same populations should be done.