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NACUBO’s HEERF Programs Grant Accounting Tutorial takes a reasoned approach to revenue recognition under both the Financial Accounting Standards Board (FASB) and the Governmental Accounting Standards Board (GASB) standards.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act, Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA), and the American Rescue Plan Act (ARPA) provide budgetary relief to higher education institutions through Higher Education Emergency Relief Fund (HEERF) allocations. HEERF I under CARES, HEERF II under CRRSAA, and HEERF III under ARPA are administered by the Department of Education and are combined and referred to as HEERF program grants.


All HEERF allocations have an institutional portion and a student aid portion, are subject to Office of Management and Budget Uniform Guidance rules, and contain minimal student aid spending requirements. The grants are considered non-exchange transactions with eligibility contingencies under GASB and conditional contributions with a right of return and barriers to entitlement under FASB. The HEERF II absolute dollar spending minimum on student aid results in less aid allocated to students and more aid to institutions when compared to the no-less-than-50-percent student spending rules under HEERF I and HEERF III. However, because all three HEERFs have been administratively combined and have minimal student aid spending requirements, NACUBO’s guidance uses student aid disbursements as the basis for a consistent pro-rata recognition approach across all three tranches of HEERF funds.


This new accounting tutorial supersedes NACUBO’s 2020 CARES Act accounting tutorial and is available only to NACUBO members.


Sue Menditto

Senior Director, Accounting Policy


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