ED Releases Updated Reporting Guidelines for Student Portion of CARES Act Emergency Relief
By Karen McCarthy, NASFAA Policy & Federal Relations Staff
The Department of Education (ED) has revised its May 6 Electronic Announcement (EA) outlining school requirements to publicly post certain student emergency grant information on the institution's primary website as part of the reporting requirements under the Coronavirus Aid, Relief, and Economic Security (CARES) Act.
The revised EA maintains the same seven reporting elements, but it adds a definition for "total number of eligible students" and decreases the frequency of reporting after the initial 30-day period from every 45 days thereafter to no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30) thereafter.
For purposes of this reporting, schools should calculate the number of eligible students by adding the number of students for whom the institution has received an Institutional Student Information Record (ISIR), plus the number of students who completed an alternative application form developed by the institution for this purpose, if any.
Of that total, the number of students who are eligible for an emergency grant per the institution's awarding criteria would be the final total of eligible students at the institution. The institution is not asked to make assumptions about the potential eligibility of students for whom the institution has not received an ISIR or an alternative application.
Publication Date: 8/31/2020
G. Michael J | 8/31/2020 5:39:37 PM
I also find the wording of the Footnote interesting. Does "may" mean that is was/is OK for schools to guess that students for whom they don't have ISIRs or other applications might be eligible for HEERF grants? How would they have done that?
Also, could "apply this number to its own methodological framework" refer to eligible students being admitted, registered, enrolled, and attending? Maybe I'm overthinking.
Peter G | 8/31/2020 2:11:39 PM
I read this a bit differently - the EA uses the word "may" twice in it's description.
For schools that defined it more specifically (e.g. valid ISIR + met the other Sec 484 criteria) you would seem free to not have to change your methodology/tabulation/reporting of this data item.
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