Skip to content Menu

The Department of Education recently published two guidance documents: one addressing questions related to funds provided under the Coronavirus Aid, Relief, and Economic Security (CARES) Act, and the other announcing regulatory flexibility with regard to Return to Title IV funds during the COVID-19 pandemic.


The FAQ addresses deadlines for spending Higher Education Emergency Relief Fund (HEERF) dollars, emergency student aid in future academic terms, and assists with interpreting “any costs associated with the significant delivery of instruction due to the coronavirus.”  Many of those questions focus on the different requirements in the CARES Act.

  • Section 18004(a)(1) includes the emergency grants to students and the institutional share. This represents 90 percent of the HEERF.
  • Section 18004(a)(2) addresses funds provided to Historically Black Colleges and Universities (HBCUs), Tribally Controlled Colleges and Universities (TCCUs), and Minority Serving Institutions (MSIs), as well as other institutions eligible for the Strengthening Institutions Program (SIP).
  • Section 18004(a)(3) provides additional funds to institutions through the Fund for the Improvement of Postsecondary Education (FIPSE).

The FAQ generally groups sections 18004(a)(2) and (a)(3) together and clarifies the distinction between those and (a)(1). Several questions indicate that under Sections 18004 (a)(2) and (a)(3) there is greater leeway for granting scholarships and using funds to offset future lost revenues. Other questions address Section (a)(1) institutional funds and reinforce that institutions have the discretion to determine the types of costs associated with campus closures, with dining and residential staff expenses included as examples. A new NACUBO accounting tutorial delves deeper into allowable direct and indirect costs. 

R2T4 Timeline Extended

One June 16, ED also updated an Electronic Announcement, indicating the agency was extending the timeframe for relief from R2T4 requirements to periods that include March 13, 2020 and the later of December 31 or the last date the national emergency is in effect. ED also clarified that an institution cannot automatically apply CARES Act R2T4 relief to all students who withdrew unless a disruption to instruction occurred during that payment period.


Bryan Dickson

Director, Student Financial Services and Educational Programs



Sue Menditto

Senior Director, Accounting Policy


Related Content

NACUBO Pushes Back on GASB’s Coronavirus Accounting Proposal

In a letter to the Governmental Accounting Standards Board, NACUBO supported GASB’s accounting interpretation of CARES Act relief funds but disagreed with its assertion that a global pandemic is neither an unusual nor infrequent occurrence for financial reporting.

GASB Issues Defined Contribution Plan and Component Unit Guidance

GASB’s Statement 97 exempts defined contribution benefit plans from financial burden and accountability criteria that would lead to reporting in fiduciary fund financial statements.

GASB Releases CARES Act and Coronavirus Technical Bulletin

A Technical Bulletin released by GASB on July 2 clarifies the accounting, reporting, and recognition criteria for various program resources under the CARES Act.