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Following months of limited reporting guidance from the Department of Education on college and university use of CARES Act Higher Education Emergency Relief Fund (HEERF) allocations, ED both announced and immediately implemented new quarterly reporting requirements for schools on September 28. 

The new requirements pertain to use of HEERF allocations under Section 18004(a)(2), Section 18004(a)(3), and the institutional portion of a school’s Section 18004(a)(1) funds. Schools are still obligated to comply with separate quarterly reporting requirements concerning their use of Section 18004(a)(1) funds earmarked for emergency grants to students.

Schools must provide their first quarterly reports by October 30 for the period between the date of their first HEERF award and September 30; subsequent reports are then 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).

ED received emergency clearance to immediately implement these new quarterly requirements due to the COVID-19 pandemic. The requirements were announced during an open comment process on separate HEERF annual reporting requirements. The timing created some confusion for schools, since similar flaws existed in both the quarterly proposed reporting form, which had a weeklong comment period, and the annual proposed reporting form, which is undergoing a full comment period.

NACUBO submitted comment letters on both proposed forms, highlighting that both created confusion as to what is, and is not, an allowable use of the Section 18004(a)(1) institutional share, and also stressed the need for ED to update its FAQ guidance to address this question as well. Both comment letters also suggested that housing refunds to students warranted a unique reporting line and posed questions about the permissibility of using funds for rental equipment, purchasing faculty and staff training for online instruction, and providing tuition discounts, among other items.

Learn more about these requirements and other updates at the next Telephone Town Hall, October 23 at 2 pm ET.


Megan Schneider

Senior Director, Government Affairs


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