Updates to the Higher Education Emergency Relief Grants

The Higher Education Emergency Relief Fund (HEERF) was implemented under the CARES Act by the federal government earlier this year. The fund allocations became available to institutions based on a formula determined in the CARES Act. Essentially, it weighs the number of full-time students that are Pell-eligible with the total population of the school and the number of students that were not enrolled online full-time before the COVID-19 pandemic.

In the August 31, 2020 Federal Register Announcement, the Department of Education published revised information regarding HEERF—maintaining the same seven reporting requirements for all institutions that receive HEERF grants. Institutions are expected to publish this information for the public; however, this announcement includes a clarification that decreases the frequency of reporting after the initial 30-day period to a quarterly reporting system. It also clarifies reporting for item four:

“(4) The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act.

Footnote: For the purposes of this report, institutions may determine the number of eligible students based on the number of students for whom the institution has received an Institutional Student Information Record (ISIR) plus the number of students who completed an alternative application form developed by the institution for this purpose. The institution may then apply this number to its own methodological framework for disbursal of funds to produce a final total of eligible students at the institution. The institution is not asked to make assumptions about the potential eligibility of students for whom the institution has not received an ISIR or an alternative application.”

Overview of Reporting Requirement Updates

Further guidance regarding quarterly and annual reporting for both the Student Portion and Institutional Portion is required to be publicly posted on an institution’s website by October 30, 2020 and will be required until September 30, 2022 or until all funds have been expended.

Additionally, the Quarterly Budget and Expenditure Reporting forms have been finalized and are available. When reporting expenses, institutions need to include these in the period they are incurred. These reporting forms should be treated as “live” documents and updated as more expenses are deemed eligible and/or discovered.

Quarterly reporting: All HEERF grant awards first received and through September 30, 2020 must be posted no later than 10 days after the end of each calendar quarter. The next report is due January 10, 2021, then each quarter thereafter (April 10, July 10 and October 10). If an institution has expended all their HEERF Student Portion grant funds, they must indicate that quarterly posting is the final report. Then, no more quarterly reporting is required to be published. If all Institutional Portion grants have been expended, the “final report” box must be checked. After that quarterly report is posted, no further public reporting is needed as well.

Annual Reporting: This will be submitted to the Department of Education on a portal system. The portal is currently in development, and the first annual report will likely be due in early 2021. All institutions that received any HEERF funds will need to submit.

We recommend once the quarterly reports are posted to the institution’s website, the link should be emailed to HEERFreporting@ed.gov. In addition to the reporting requirements updates, there are a few other changes that are still in draft form. These include a few tweaks to the spending categories, reorganized instructions and clarification regarding the number of years (three) records need to be retained after the grants end.

Additionally, a third round of FAQs was released on October 2, 2020. The CARES Act HEERF Rollup includes all previously released FAQ documentation.

To speak with our expert Title IV team, please contact us.

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