HEERF – October 2020 Update on Reporting Requirements

The Higher Education Emergency Relief Fund (HEERF) program was created under the CARES Act to provide students and educational institutions with much-needed help during the COVID-19 pandemic. This program was recently updated by the Department of Education (ED) to address several critical matters.

Note: For background on the HEERF program, check out our previous articles:

https://www.jmco.com/articles/higher-education/cares-act-education-stabilization-fund/

https://www.jmco.com/articles/higher-education/cares-act-higher-education/

https://www.jmco.com/articles/higher-education/heerf-funding-faqs/

October 2020 Update

The following are the key takeaways from the ED’s recent updates to HEERF reporting requirements:

Section 18004(a)(1) – Student Portion Public Reporting:

• Reporting method: All information needs to be posted for public view on your institution’s primary website.
• First report due date: 30 days after the ED committed the funds to your institution.
• Reporting frequency: All reports are due quarterly and must be posted within 10 days after each calendar quarter (e.g., Jan. 10, April 10, July 10)
• Subsequent reporting dates: As of October 2020, the next reporting deadline falls on Jan. 10, 2021, for the period ending Dec. 31, 2020.
• If all HEERF funds have been expended: In your quarterly report, indicate that all funds have been utilized. You will no longer have to submit quarterly reports after that.

Section 18004(a)(1) – Institutional Portion, (a)(2), and (a)(3) Public Reporting

• Reporting method: All information needs to be posted in the same place as the student portion report.
• First report due date: 30, 2020, for the period from the first award through Sept. 30, 2020.
• Reporting frequency: Same as student portion reporting.
• Next reporting date: As of October 2020, the next reporting deadline falls on Oct. 30, 2020, for the period from the first award through September 30, 2020.
• If all HEERF funds have been expended: Check the box indicating that it is the final report. You will no longer have to submit quarterly reports after that.

Annual Reporting

• Reporting method: The report is to be submitted to the ED’s portal system (currently in development).
• First/next report due date: To be confirmed (preliminarily, early 2021).
• Reporting frequency:
• If all HEERF funds have been expended: All HEERF grantees will be required to submit the first annual report. This is regardless of whether all funds have been used up as of the reporting deadline.

Quarterly expenditure report templates are at the ED’s portal. Reports can be posted on your institution’s website in either HTML or PDF format. After uploading the reports, it is highly encouraged to notify the Department by email at HEERFreporting@ed.gov to ensure that the Department registers the reports on time. The ED has emphasized public accountability by requesting all information to be posted online and be available to anyone.

Unfortunately, as frequently the case with many government-sponsored initiatives, compliance requirements are not always clearly communicated (or are outright confusing). Realizing that and appreciating the program’s importance, we’ll continue to cover the HEERF program as it evolves.

If you still have questions, James Moore’s Higher Education team is ready to guide you further through the HEERF program’s complexities, benefits, and reporting requirements.

All content provided in this article is for informational purposes only. Matters discussed in this article are subject to change. For up-to-date information on this subject please contact a James Moore professional. James Moore will not be held responsible for any claim, loss, damage or inconvenience caused as a result of any information within these pages or any information accessed through this site.