In a recent email to institutions' primary IPEDS contacts, the Department of Education (ED) requested that grantee institutions submit contact information for campus officials who should receive an email from ED later in December with login information for the Higher Education Emergency Relief Fund (HEERF) Annual Report Data Collection System.
The email asks institutions to provide contact information for a Submitter and an Editor, no later than tomorrow, Dec. 4, 2020. The Submitter is the grant official with the authority to submit the report on behalf of the grant, while the Editor is a user who can answer the questions in the data collection form, but who will not have Submitter authority, according to ED's email. Institutions are asked to submit the first and last name and email address for the submitter, editor, and an optional second editor to firstname.lastname@example.org.
For background, the HEERF Annual Report Data Collection System was announced in the Federal Register in July to satisfy 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 60-day comment period for the Annual Report Data Collection System closed on Sept. 28, 2020. ED made several revisions to the most recent iteration of the form in its 30-day comment request which closed this week. NASFAA submitted its comments for this most recent version on December 2. ED will now review this latest round of stakeholder comments, make final revisions to the annual data collection, and release the final annual report form within the next two months.
The first submission of this new data collection would now be due on Feb. 1, 2021; the second on Feb. 1, 2022; and the third on Feb. 1, 2023. The form now features a question where institutions can indicate that the current submission is their final submission because they have fully expended their HEERF funds during the reporting period. ED also increased the reporting burden from 1.5 hours to six hours.
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 within 10 days of the end of each calendar quarter. Those website URLs would be a required data element on this annual report.
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.
Publication Date: 12/3/2020