HEERF Reporting Requirement Updates

By NASFAA Policy & Federal Relations Staff

On Tuesday, the Department of Education (ED) released new guidance on the third round of Higher Education Emergency Relief Fund (HEERF) grants authorized by the American Rescue Plan

ED confirms that institutions will be required to post the Quarterly Institutional Public Reporting Form (which was updated on May 11) and the Quarterly Student Public Reporting Form for HEERF II and HEERF III funds to their websites by the tenth day following the end of each calendar quarter, as has been that case for HEERF I funds. 

Notably, ED acknowledges that because it never affirmatively established HEERF II reporting requirements, it is extending the deadline by which institutions must submit retroactive reports for HEERF II for the first quarter of 2021 (January through March) to the end of the second calendar quarter, which is June 30, 2021. 

HEERF II and HEERF III funds will also be subject to the annual reporting requirement, which is next due in early 2022. ED indicates that it will share more information regarding the annual report in advance of the annual reporting deadline.

While ED has not yet finalized what will be included in the next HEERF annual report, it does provide preliminary guidance on what institutions should be documenting now, as they continue to award their remaining HEERF I and II funds and begin awarding their HEERF III funds, in order to be prepared for next year's annual report. 

First, with respect to the requirement that institutions prioritize the awarding of HEERF III grants to students with exceptional need, ED advises institutions to "carefully document how they prioritize students with exceptional need in distributing emergency financial aid grants to students, as the Department is exploring reporting requirements regarding the distribution of emergency financial aid grants to students."

ED also indicates that it is exploring collecting more information on the HEERF annual report on institutions' implementation of two new required activities Congress added to the American Rescue Plan: implementing evidence-based practices to monitor and suppress the coronavirus, and conducting direct professional judgment (PJ) outreach to financial aid applicants.

Specifically, ED advises institutions to document (1) the strategies used to monitor and suppress COVID-19, (2) the evidence to support those strategies, (3) how those strategies were in accordance with public health guidelines, (4) the manner and extent of the direct outreach the institution conducted to financial aid applicants, and (5) how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution.

Watch Today's News for the latest updates on HEERF reporting requirements.


Publication Date: 5/12/2021

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