By Jill Desjean, NASFAA Policy and Federal Relations Team

On Wednesday, the Department of Education (ED) posted in the Federal Register an information collection request on a data collection form to satisfy Higher Education Emergency Relief Fund (HEERF) reporting requirements specified in section 18004(e) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which states that an institution "receiving funds under this section shall submit a report to the Secretary, at such time and in such manner as the Secretary may require, that describes the use of funds provided under this section." 

The first submission of this new data collection would be due on Jan. 29, 2021; the second on Sept. 30, 2021; and the third on Sept. 30, 2022. 

Institutions that received HEERF funds under any part of section 18004 of the CARES Act — which includes emergency grants for student expenses related to COVID-19; funds for institutional costs associated with significant changes to the delivery of instruction due to the coronavirus; funding for HBCUs, MSIs, and TCUs; and FISPE funding — would be subject to this additional reporting requirement. ED estimates it would take institutions 1.5 hours to complete the survey, and data elements to be collected would include:

• How institutions determined which students were eligible for emergency grants and how amounts were determined

• How institutions established that students met the Title IV eligibility requirements

• The payment method used for emergency grants to students

• Withdrawal rates for students who received emergency grants

• A categorized list of how the institutional share was spent

The purpose of this new data collection would be to provide ED with the information necessary for department staff to monitor that institutions spent HEERF funds in accordance with the allowable uses of funds. Descriptive statistics from the data collection would be made publicly available by ED.

While this new reporting requirement satisfies the reporting requirement specified in section 18004(e) of the CARES Act, it does not replace the 30-day Fund Report detailed in ED's May 6 Electronic Announcement, which requires institutions to post certain information about their distribution of the HEERF student emergency grants on their websites, which continue to require updates every 45 days. Those website URLs would be a required data element on the new information collection announced this week.

This new reporting requirement is also unrelated to, and does not substitute for, the quarterly reporting requirements specified in section 15011, which apply to all entities receiving funds under any provision of the CARES Act in excess of $150,000. NASFAA is still seeking clarity on this reporting requirement after ED announced on July 10 that existing federal grantee reporting requirements under the Federal Funding Accountability and Transparency Act of 2006 (FFATA) satisfy the CARES Act quarterly reporting requirements. It still remains unclear as to whether all institutions of higher education are subject to the FFATA reporting requirements and, for those that are exempt, how they will otherwise satisfy the CARES Act quarterly reporting requirements since no alternative path to compliance has been offered. ED has indicated that guidance is forthcoming on this topic and NASFAA will share that information as soon as it becomes available.

Comments are due on Sept. 28, 2020.

Publication Date: 7/30/2020

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