The Department of Education (ED) has issued reporting guidelines for higher education institutions to comply with Higher Education Emergency Relief Fund (HEERF). Below is a summary of the reporting guidelines:
We broke down what your higher education institution needs to know about the CARES Act.
Student Portion of HEERF Funding
The guidance states the following information must appear on the institution’s primary website 30 days after the date when the institution received its allocation under 18004(a)(1) of the CARES act. It must be updated every 45 days thereafter:
In an update on August 28, 2020, the 45-day requirement was changed to be no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, and June 30) thereafter, unless the Secretary specifies an alternative method of reporting:
On August 28, 2020, a revised notice for the Student Share Public Posting Requirement for HEERF Grantees was issued. In the revised notice, the following was added:
As institutions are working to prepare the 30-day Fund Report, they must remember to still comply with the Family Educational Rights and Privacy Act and protect personally identifiable information. The ED states that it does not expect institutions to report information about a group of 10 or fewer students on publicly available websites controlled by the institution.
Those institutions that accurately report the information listed above will meet the initial reporting requirements. For subsequent reports and reporting for other related HEERF programs, the ED will notify participating institutions of the preferred reporting method.
Institutional Portion HEERF Funding
The Department of Education also recently issued guidance regarding reporting requirements for the Institutional Portion (a)(2) and (a)(3), as well as the institutional portion of the school’s Section 18004(a)(1) funds. The first reports are due to be publicly posted on the institution’s website by October 30, 2020. The covered period on the first publicly posted report should cover the period from the date of the first HEERF grant award through September 30, 2020. Subsequent reports are due quarterly and must be posted no later than 10 days after the next calendar quarter begins (January 10, April 10, July 10, October 10).
Here is a link to the pdf version of the required quarterly report.
For the reporting requirements on the student portion of the HEERF funding, please refer to the following Insight.
Below is a summary of the HEERF Reporting Requirements:
|Who Reports||Method of Reporting||First report due to be posted||Frequency of Reporting||As of 9/28, when is the next report due?||Substance of Reporting||What do I do if I have expended all of my HEERF grant funds?|
|Section 18004(a)(1) Student Portion Public Reporting||All HEERF grantees that received a Section 18004(a)(1) Student Portion award.||Information is publicly posted on institution's primary website.||First report was generally due 30 days after the Department originally obligated funds to the institution for the Section 18004(a)(1) Student Portion. See our Federal Register notice published on August 31, 2020 for more information.||Subsequent reports are due quarterly and must be posted no later than 10 days after the calendar quarter (October 10, January 10, April 10, July 10).||By October 10 covering the period from the last 30 or 45 day report through September 30.||Information specified in our May 6, 2020 Electronic Announcement, which was updated in a Federal Register notice published on August 31, 2020.||Please indicate that the final quarterly posting is the final report that covers all remaining HEERF fund expenditures for Section 18004(a)(1) Student Portion funds. After posting that report, no more quarterly public reporting of Section 18004(a)(1) Student Portion funds is required.|
|Section 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) Public Reporting||All HEERF grantees that received a Section 18004(a)(1) Institutional Portion, (a)(2), or (a)(3) award.||Information is publicly posted on institution's primary website in the same place as the Student Portion Public Reporting described above.||First report due October 30, 2020 covering the period from first award through September 30, 2020.||Subsequent reports are then due quarterly and must be posted no later than 10 days after the calendar quarter (January 10, April 10, July 10, October 10).||By October 30 covering the period from the date of the first HEERF award through September 30.||October 13, 2020 Update: Reporting Forms Now available: Word Document (38 KB) | PDF Document (156 KB)||Please check the box on the form that it is the "final report" that covers all remaining HEERF fund expenditures for 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) funds. After posting that report, no more quarterly public reporting for 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) funds is required.|
|Annual Reporting||All HEERF grantees.||Report is submitted to the Department via a portal system currently in development.||Intended first annual report due in early 2021.||Yearly. Submission will be required of all HEERF grantees.||Intended first annual report due in early 2021.||Not yet finalized, but draft form is in public comment period. See our Federal Register Notice here and Form and Instructions and Supporting Statement here.||All institutions that received any HEERF award will still have to submit an annual report in early 2021 to the Department regardless if at that time they still have HEERF funds or not.|
For further information regarding HEERF Funds, the ED has provided the following FAQs:
Frequently Asked Questions Provide Additional Guidance
In October 2020, additional guidance was released via the third round of frequently asked questions related to HEERF. Highlights include:
Maintaining Compliance in Your Higher Education Institution
The CARES Act provided several benefits for industry specific entities, including higher education institutions. It’s important to know the requirements for these relief provisions and comply with them. Ensuring you have the proper documentation in place for this funding is the first step. It will also be critical to watch for updated guidance and best practices as your higher education institution navigates this new normal.
Here’s what higher education organizations need to do in the wake of COVID-19.