Reporting Requirements for Higher Education Emergency Relief Fund Disbursements

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On April 9, 2020, the U.S. Department of Education (ED) issued guidance related to the Higher Education Emergency Relief Fund (HEERF), a provision of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). This guidance addressed the student share of HEERF grants and included the CARES Funding Certification and Agreement (Agreement), which higher education institutions must complete to receive funding provided by the HEERF. The Agreement includes various reporting requirements but doesn’t include guidance on how to report on these requirements. 

On May 6, 2020, ED published guidance stating ED will provide instructions “in the near future” on how to report the required information included in the Agreement to the Secretary of ED. In the meantime, institutions must comply with the following to meet the reporting requirements for the student share of HEERF grants:

When to start reporting: 30 days after you receive your allocation
How often: Update every 45 days after first reporting
How to report: As of May 6, 2020, post on “the institution’s primary website in a format and location that is easily accessible to the public”
What to report:

  1. An acknowledgment that the institution signed and returned the Agreement to ED and the assurance the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide emergency financial aid grants to students.
  2. The total amount of funds the institution will receive or has received from ED pursuant to the institution’s Agreement for emergency financial aid grants to students.
  3. The total amount of emergency financial aid grants distributed to students under §18004(a)(1) of the CARES Act as of the date of submission, i.e., as of the 30-day report and every 45 days thereafter.
  4. The estimated total number of students at the institution eligible to participate in programs under §484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive emergency financial aid grants under §18004(a)(1) of the CARES Act.
  5. The total number of students who have received an emergency financial aid grant under §18004(a)(1) of the CARES Act.
  6. The method(s) used by the institution to determine which students receive emergency financial aid grants and how much they would receive under §18004(a)(1) of the CARES Act.
  7. Any instructions, directions or guidance provided by the institution to students concerning the emergency financial aid grants.

Additional considerations: Institutions should use data suppression and other methodologies to comply with and protect the personally identifiable information from student education records. For example, ED doesn’t expect institutions to report information about a group of 10 or fewer students. Institutions that accurately report the information listed above will meet the initial reporting requirements.

View ED’s published guidance here. As with most topics related to COVID-19, changes are being made rapidly. Please note that this information is current as of the date of publication. For more information, contact your BKD Trusted Advisor™ or use the Contact Us form below.

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