NAICU Washington Update

Higher Education Community Comments on HEERF Reporting

August 26, 2021

NAICU and other higher education associations worked together to submit official comments regarding the Department of Education’s recent request for public comment on proposed changes to the reporting requirements for Higher Education Emergency Relief Funds (HEERF). 

The proposed changes to the HEERF funds reporting requirements would retroactively expand the amount of student demographic data and categorical spending detail colleges and universities must report. Much of this data may not have been collected due to requirements at the time the funds were made available. The Education Department is requesting the reporting changes apply retroactively to all three emergency relief bills -- the Coronavirus Aid, Relief, and Economic Security (CARES) Act, the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and the American Rescue Plan (ARP) Act.

The higher education community letter acknowledges that because of the historic amounts of funding provided so quickly to students and institutions, there is great public interest in knowing how institutions have managed and distributed funds, and how they have complied with departmental guidance to do so. The letter also outlines specific concerns with the proposed changes to reporting, including that funds were distributed according to rules in existence at the time and the new student demographic data information requested may be unavailable because institutions focused on collecting data required when the funds were distributed.

The letter also makes clear that institutions understand the importance of transparency with regard to the use and distribution of federal funds.

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