To address the unprecedented challenges of the COVID-19 pandemic, Congress authorized the Higher Education Emergency Relief Fund (HEERF I) in March 2020 with over $6 billion allocated for emergency financial aid. In this paper, we utilize the administrative burden framework to analyze HEERF I implementation for a stratified random sample of colleges, focusing on the implications for equity. We find that disbursement policies varied along two dimensions: (1) whether they imposed burdens on students by requiring applications and proof of hardship and (2) whether they targeted needy students and varied the amount of aid according to need. When we examine sectoral differences, we find that private for-profit colleges were more likely to place higher burden on students, whereas public and minority-serving institutions were more likely to reduce burden.