NAICU Washington Update

Department of Education Considering Additional HEERF Reporting Requirements

July 30, 2021

As the Department of Education seeks to fully account for and justify to Congress and the public that the $77 billion provided to students and institutions in coronavirus relief was well spent, it is considering expanded reporting requirements for colleges and universities.  However, the unexpected detail of the reporting expansion proposed could be a hefty compliance burden for institutions. 

As a first step, the Department is requesting comments via Agency Information Collection Activities on the new and expanded reporting requirements on the Higher Education Emergency Relief Funds (HEERF).  Comments are due August 23, 2021. 

The proposed changes to the annual report apply to the uses of all HEERF funds (CARES, CRRSAA and ARP), and include institutional, student, FIPSE, and proprietary grants.  The changes would also apply to specific grants for Historically Black Colleges and Universities and Minority-Serving Institutions. 

The proposed expanded reporting form asks for new details at a level of complexity that will require institutions to review and research records in order to be in compliance. For example, the current emergency student grant reporting asks for the total amount received, total amount disbursed, total number of students who received grants, and the method the institution used to determine awards. The proposed form asks for detailed demographic background and enrollment status of student recipients, and details on how institutions determined which students needed grants and for what purposes.  

The current institutional grant reporting asks for the total amounts spent on the categories reflected in the guidance, with a space for short explanatory notes. The proposed form asks for the same information, but then also asks that it be organized by FASB category and whether lost revenue was due to reduced enrollment or from non-tuition sources. The form also asks about the employment status of faculty and staff before and after the pandemic. 

The higher education community will submit comments raising these concerns. Individual institutions may also want to comment on the information collection. College business officers and financial aid administrators also may want to review the proposal to determine the impact the additional information request would have on institutions. 

After the 60-day comment period, the Department will consider the feedback it receives and issue a draft form with another 30-day comment period before implementing its use. 

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