NAICU Washington Update

Reporting Requirements for CARES Act Funds Updated

September 03, 2020

The Department of Education has made three changes to the reporting requirements colleges and universities must follow if they received student emergency grants under the Higher Education Emergency Relief Funds from the CARES Act.
First, the department has decreased the frequency of reporting after the initial 30-day reporting period from every 45 days thereafter to every calendar quarter.  Specifically, reports must be made no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30).
Second, to facilitate reporting on the number of eligible students, institutions can use the number of students for whom it has an Institutional Student Information Record (ISIR) plus the number of students who completed an alternative institutional application. This number can then apply to the institutional methodology for disbursal of funds. Institutions are not being asked to make assumptions about the potential eligibility of students for whom the institution has not received an ISIR or an alternative application.
And third, to be consistent with FERPA, institutions should report “less than 10” if the total number of students receiving grants is less than 10 but more than zero, to protect personally identifiable information.
Reports should still be made available publicly on institutional websites, and cover the following elements:
  1. An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that 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 that the institution will receive or has received from the Department pursuant to the institution's Certification and Agreement for Emergency Financial Aid Grants to Students.
  3. The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the initial report and every calendar quarter thereafter).
  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.
  5. The total number of students who have received an Emergency Financial Aid Grant to students under Section 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 Section 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.

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