ED Releases Revised Annual Data Collection Form for Public Comment

By Jill Desjean, Policy and Federal Relations Staff

On Thursday, June 24, the Department of Education (ED) published a revised draft annual data collection form for Higher Education Emergency Relief Fund (HEERF) dollars in the Federal Register for public comment. The form is to be completed by institutions for HEERF dollars received from the institutional and student portions of all three rounds of HEERF authorized by Congress, as well as for funds designated for Historically Black Colleges and Universities (HBCUs), Minority-Serving Institutions (MSIs), Tribally Controlled Colleges and Universities (TCCUs), Strengthening Institutions Program (SIP), Fund for the Improvement of Postsecondary Education (FIPSE), and the Proprietary Institutions Grant Funds for Students. 

The form — which will be due in early 2022, will cover the reporting period from January 1 2021-December 31, 2021 — contains several notable changes from the form institutions completed in January, 2021 to report on their Coronavirus Aid, Relief, and Economic Security (CARES) Act HEERF expenditures for the reporting period of March 13, 2020 through December 31, 2021.

New questions added

The revised draft form adds several new questions to the annual data collection form. It asks how HEERF has helped the reporting institution and its students, with a series of seven sub-questions that institutions will be asked to rate their agreement or disagreement, such as whether HEERF dollars helped their institution avoid closure, retain staff and at-risk students, and keep tuition increases to a minimum.

Also added is a question about what amount of HEERF amounts disbursed was used to cover outstanding account balances with the student’s affirmative written consent, reflecting new approved uses of funds and guidance that lifted the prohibition on CARES Act HEERF dollars being used to satisfy outstanding student account balances.

In addition to asking for average HEERF student grant award amounts, the revised form adds maximum and minimum award amounts as well.

Title IV eligibility questions removed

Several questions that were part of the January, 2021 data collection that related to how institutions determined whether students met the Title IV eligibility criteria, as required by ED’s June 17, 2020 Interim Final Rule, are removed from this draft form, in accordance with May 14, 2021 guidance removing this eligibility restriction.

Existing questions expanded to add sub-questions and request disaggregated figures

In addition to new questions, ED also adds significant detail to existing questions by asking for further disaggregation of data. For instance, HEERF grant recipient counts, total award amounts, and average award amounts would now have to be disaggregated by race/ethnicity, gender, and age.

Additionally, the existing question that asks institutions to break down their HEERF recipients by enrollment category (withdrawn, continued enrollment, or graduated) now asks institutions to provide the same data for non-HEERF recipients for comparison purposes, and asks for each of these data points to be disaggregated by academic level, Pell receipt status, enrollment intensity, race/ethnicity, gender, and age. The same questions for HEERF and non-HEERF recipients would also be asked for calendar year 2020 and, lastly, for all students for calendar year 2019 (prior to the pandemic and the first round of HEERF dollars), all disaggregated by the same characteristics previously noted and all intended for comparison purposes in determining the impacts of HEERF dollars on student persistence and completion.

Institutions would continue to be asked how much of their institutional share they had spent during the reporting period, broken down by category, but would be asked an additional question about how much their institution has budgeted or earmarked to spend in the subsequent calendar year on those same categories.

Institutions who report using institutional share funds to replace lost revenue would now be presented with an additional question asking them to categorize that spending. All institutions would also be asked, in addition to their count of FTE staff as of certain dates, to break those numbers down by whether those staff were considered instructional or non-instructional staff.  


ED estimated the burden for the January, 2021 annual data collection at 6 hours. They double that figure — to 12 hours — for the revised draft data collection, citing the addition of new questions and the significant amount of disaggregation added to existing questions. Institutional responses from a survey conducted by NASFAA, NASPA, and MDRC — the full results of which will be published and shared in Today's News in mid-July — indicated that ED's previous annual data collection burden estimate was lower than the actual number of hours it took the majority of responding institutions to complete, so their new estimate may also fall short of actual time required to complete this data collection. 

Public comments are due by August 23, 2021, after which ED will revise the draft data collection based on feedback received and post a second draft for a subsequent 30-day comment period before finalizing the data collection for institutions to use next January. NASFAA encourages schools to submit their comments through the process explained in the Federal Register notice. In addition, please submit any comments to NASFAA for consideration as NASFAA develops its public comments on behalf of its members. Keep track of all HEERF reporting requirements and other updates in Today’s News.


Publication Date: 7/1/2021

Peter G | 7/2/2021 12:47:17 PM

As a minor nitpick, the prior annual report did also require min/max awards for both Pell and non-Pell groups.

I have a few concerns with the expanded reporting. I think the big one is "now asks institutions to provide the same data for non-HEERF recipients for comparison purposes, and asks for each of these data points to be disaggregated by academic level, Pell receipt status, enrollment intensity, race/ethnicity, gender, and age" is a big one.

While this might make some sense for a "traditional" institution where these categories are both well-defined and straightforward, from a community college POV this is going to result in incredibly messy numbers that I hesitate to describe as "data". Student academic level is not a simple notion since students are often program-fluid and/or changing programs in a way that will greatly complicate tracking/reporting. Likewise, our institution/state both support a range of gender options - is that going to be the case for this federal reporting?

I'd be surprised if we could complete this in under 50 hours given both the complexity and the number of departments who would have to be pulled in and coordinated.

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