Late last week, the Department of Education (ED) published its second round of changes to the annual data collection form for Higher Education Emergency Relief Fund (HEERF) dollars in the Federal Register for public comment. This will be the final comment period on the form. NASFAA and the National Association of College and University Business Officers (NACUBO) submitted joint comments on the first round earlier this summer. After this 30-day public comment period, ED will finalize the data collection form for institutions to use this coming January.
The form — which will be due in early 2022 and will cover the reporting period from Jan. 1, 2021 through Dec. 31, 2021 — contains several changes from the annual reporting 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 Dec. 31, 2020. The most recent changes to the proposed form address many of the issues raised in the NASFAA/NACUBO letter.
NASFAA and NACUBO, along with many other commenters, brought up the burden that disaggregation by student subgroups, retrospective-looking data elements, and reporting for students who did not receive HEERF funds would create for institutions, especially with the limited time frame. While ED ultimately decided to retain these data elements, it did allow for additional time for institutions to gather this data. For the newly proposed disaggregation data that was originally requested to be submitted in early 2022 (which covers 2021 implementation), institutions will now be allowed to submit most of this requested data in early 2023, at the same time that they will be submitting their annual report on 2022 implementation.
ED also increased the burden estimates for this reporting, which NASFAA and NACUBO argued were too low. ED originally estimated the burden to be around 12 hours for an institution to complete the report, but has increased that burden estimate to 40 hours.
Another issue brought up and addressed by ED was that of reporting HEERF dollars used to replace lost revenue. In their comments, NASFAA and NACUBO pointed out to ED that institutions were not tracking lost revenue based on prior guidance by ED and that lost revenue funds may not necessarily be expended in the same reporting period as the revenue loss occurred. In response, ED reframed the question on the form to focus on how lost revenue expenditures were derived, and aligned the categories for lost revenue with ED's own FAQ published last March, as recommended by those who submitted comments.
Additionally, ED addressed concerns raised in the NASFAA/NACUBO letter related to challenges institutions might face in disaggregating student enrollment, retention, and completion data by HEERF recipient status, and the difficulty of correctly interpreting such data assuming institutions could provide it at all. In response, ED updated the data collection instrument so that it no longer disaggregates by students who received HEERF grants; instead, it will look at overall retention rates for student populations, which ED posited could still provide insight into changes in retention during the pandemic.
If your institution did not send comments for the first comment period and would like to during this comment period, or still have outstanding issues, NASFAA encourages schools to submit their comments through the process explained in the Federal Register notice and to please make NASFAA aware of your comments by emailing them to our policy team. Comments are due by Nov. 8, 2021.
Publication Date: 10/15/2021