HEERF Quarterly Reporting Form Changes

By NASFAA Policy & Federal Relations Staff

The Department of Education (ED) on February 16 released planned revisions to the Higher Education Emergency Relief Fund (HEERF) quarterly reporting form for public comment in the Federal Register. The majority of the revisions to the form include adding data elements from the HEERF annual reporting form to the quarterly report. ED plans for implementation of the revised form prior to this year’s first quarter reporting deadline of April 10, 2022, using emergency clearance requested from the Office of Management and Budget (OMB.)

New Reporting Additions

While the current quarterly reporting form asks only for HEERF institutional portion expenditures by category of expense, the proposed quarterly form adds six questions from the annual report. The new questions are largely similar to the corresponding questions asked on the annual reporting form, including the table where institutions are asked to share the percentage of students who received emergency grants and how much students received in emergency grants by fund type and student type. A key difference between this new quarterly report question and the one on the annual report is that schools are asked to disaggregate only by credential level and not by enrollment or Pell Grant receipt status, as on the annual form.

The revised form also adds from the annual report to the quarterly report a question asking institutions if they designated HEERF program funds for a specific purpose or budget objective in future quarters. If they answer yes, institutions will need to complete a table broken down by HEERF funding tranche the amount they plan to spend in the 2022, 2023, and 2024 calendar years.

For institutions that used HEERF funding to replace lost revenue, the revised quarterly form adds a new table, again from the annual report, that requires institutions to break down those lost revenues by source and include the total amount used from each funding source for replacing lost revenue.

Time Burden Estimate

Notably, ED has increased the time burden estimate for institutions to complete the quarterly report from the original two estimated hours to complete the form per report, to five hours. The increase reflects the significant amount of additional reporting fields that ED has added to the form.

Public Comment

Public comments are due by March 14, 2022. 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: 2/24/2022

Jeanne S | 2/24/2022 6:34:47 PM

Fundamental. It would have been awesome if we knew when we received the funds, what reporting requirements would be. We then could have built our queries and data to capture this data and not have to back into it. As for 5 hours, maybe, if you have a robust and competent IR department. Many smaller schools and even larger ones are struggling with these resources. Honestly, I spent 2 hours just reading and interpreting these requirements, that does not include the data collection. Seems like the cart before the horse, yet again.

Peter G | 2/24/2022 2:0:26 PM

I'll stop ranting and move on, but the other issue I perceive here is OPE is essentially creating an April 10 data dump onto themselves, when many GANs expire between mid-April and mid-May.

OPE seems to lack the staff to do much with this data dump. They're certainly not going to be able to sort through thousands of reports in week or two and create resolutions for the schools that do need support. A simple 4868-style approach would almost certainly have been more beneficial for them, as well.

Peter G | 2/24/2022 1:54:53 PM

After reading ED's justification for seeking Emergency Approval, I think my criticism is they are choosing a very blunt solution to a problem that needed a more targeted approach.

The model they should have followed is IRS 4868 (request for extension) since their stated intent is to be able to intervene with institutions that are significantly off-trach. That's well and good, but the IRS doesn't make all filers submit a 4868, and the 4868 is also not 9 pages long.

The more tactical approach here would have been to add 3 questions to the existing report roughly in the vein of :
1) Has or will your institution request an extension of the GAN deadline for any HEERF funds?
2) What percent of Institutional funds remain unspent as of end of quarter?
3) What percent of Student funds remain unspent as of end of quarter?

Intervene where 1 is yes or 2/3 fall outside some defined threshold (albeit they should be able to calculate 2 & 3 with their own data, but that's probably too much to ask).

As is, they're basically proposing that all schools with Q1 expenditures, even those closing out, compile and report several pages of new data "just in case"? I mean, that's just both not particularly strategic but also pretty disrespectful imo.

They clearly don't value our time or the fact that time carries costs. 5 hours here, 6 hours there, 50 hours on the annual report and suddenly you're talking real cost and administrative burden.

Peter G | 2/24/2022 12:54:30 PM

Agree with Kyle. The justification for this seems questionable at all, but especially the use of "emergency clearance" to fast track it. Has the word "emergency" lost all meaning?

On top of the fact that for us this will be our final quarter of reporting, and I'd question the public/data value in pivoting at all at this stage of the life of HEERF, this just feels like one more cut when we're already bleeding fairly profusely.

Kyle R | 2/24/2022 11:51:18 AM

If I'm not mistaken, these reports are intended to provide transparency to the public for how the money is used. No better way than to make it more complicated for people to understand.

Rachel W | 2/24/2022 10:19:47 AM

Will this only apply to reports on or after April 2022 or will we have to go back and revise completed reports (My school has already submitted final reports for all HEERF funds).

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