ED Seeks Public Comments on Another New HEERF Reporting Requirement

By Jill Desjean, Policy and Federal Relations Staff

On Monday, the Department of Education (ED) published in the Federal Register (FR) a comment solicitation for a new Coronavirus Aid, Relief, and Economic Security (CARES) Act Higher Education Emergency Relief Fund (HEERF) data collection for which it is seeking emergency processing and Office of Management and Budget (OMB) approval by Sept. 30, 2020. This comment request is for yet another new HEERF data collection, to be called the Quarterly Budget and Expenditure Reporting (QBER), and is distinct from the 30-day Fund Report and from the proposed annual data collection that ED published on July 29, 2020.

This data collection would presumably satisfy the CARES Act Section 15011 quarterly reporting requirements, which apply to recipients of more than $150,000 of any type of CARES Act funding. Earlier this summer, ED published an Electronic Announcement indicating that it had determined, in consultation with OMB, that these quarterly reporting requirements were considered to be met under the monthly reporting requirements prescribed under an existing law, the Federal Funding Accountability and Transparency Act of 2006 (FFATA). However, ED later confirmed to NASFAA that FFATA reporting is limited to grant recipients with subawardees, and that it would be rare for institutions to have a sub-awardee for spending CARES Act formula grant funds. So, while it is true that institutions that were required to report under FFATA would be considered compliant with CARES Act Section 15011 by nature of their FFATA reporting, most institutions are likely exempt from FFATA reporting, which left them without a reporting mechanism by which to comply with that provision of the CARES Act. This data collection seems to provide such a mechanism.

The QBER would apply to recipients of CARES Act funds under Sections 18004(a)(1), (2), & (3) and section 18004(c). Reports would be posted to institutions’ primary websites, on the same page as they post their 30-day Fund Reports, either as text or as a link to a .pdf of the report. Reports would be due no later than 10 days following the end of the calendar quarter, with the exception that the first report would be due on Oct. 30, 2020 as opposed to Oct. 10. The initial report would include cumulative expenditures through Sept. 30, 2020. Subsequent reports would include data only for the quarter being reported, and each quarterly report would need to be separately maintained on the institution’s website.

Quarterly submission of the QBER would be required until Sept. 30, 2022.

ED acknowledged in this FR notice that “this public reporting instrument may appear to be duplicative to the annual report form that is in preliminary development and will be submitted to the Department in 2021 (Federal Register /Vol. 85, No. 146 /Wednesday, July 29, 2020). As such, the Department specifically welcomes comment on the relationship between the two instruments and how it might reduce any possible duplication.”

Indeed both the proposed annual report and this new QBER request slightly different data about the school’s use of the institutional portion of its HEERF allocation for student emergency grants and tuition reimbursements.

ED requests public comments by Oct. 5 due to the emergency processing request, but is also initiating a regular clearance process for which public comments would be due by Nov. 27, 2020.


Publication Date: 9/29/2020

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