NAICU Washington Update

Education Department Requests Feedback on Reporting Protocols for Emergency Relief Funds

July 30, 2020

The Department of Education issued a request for comments on the Higher Education Emergency Relief Fund (HEERF) data collection process that institutions are required to fulfill as part of their annual reporting requirement under the CARES Act.  Posted in the Federal Register on July 29, the Department is asking stakeholders to review the form and instructions and provide answers to specific questions and overall feedback on the process in general.  The 60-day comment period closes September 28, 2020. 

The HEERF reporting is in addition to the monthly reporting to the department on emergency student grants, and the quarterly reporting under Federal Funding Accountability and Transparency Act. 

According to the Department, the agency is seeking input from data submitters and stakeholders on the following directed questions: 
  1. What data in this form will be difficult to collect or report and why? Are there changes that could be made to improve the quality of the data or reduce the burden?
  2. The Department believes the data requested under this collection will be valuable for multiple purposes, such as measuring program performance and informing future program design. The Department is interested in learning the extent to which others, particularly stakeholders at the State and local level, agree that this data is valuable for their own purposes and whether there is additional data that would be valuable for the Department to collect from its grantees?
  3. The Department is interested in reducing the burden of data collection and making use of existing data when at all possible. For example, are there alternative methods to collect data or data that is already collected on institutional expenditures related to HEER funding under section 18004a of the CARES Act?
  4. Will the proposed method for collecting the number of FTE positions created or retained as a result of HEER funds awarded to IHEs yield accurate data? Is there an alternative methodology that would improve the accuracy of the data?
The Department anticipates that the first HEERF reports will be due on January 29, 2021, and will cover the reporting period from March 13, 2020 through June 30, 2020. The following annual reports are anticipated to be due in September of 2021 and 2022, covering the annual reporting periods from July 1 to June 30. 

While these questions are directed to institutions of higher education data submitters, comments from all stakeholders on these topics are welcome. To submit comments, stakeholders should go to and use the Docket ID: ED-2020-SCC-0122; Agency: Department of Education (ED) to submit a response. 

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