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Revised Student HEERF Grant Reporting Guidance

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Notice of Public Posting Requirement of (Student) Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees

Released As Predicted Last Friday

Institutional Grant Guidance Expected to be Published Prior to the Labor Day Holiday

“Be On the Lookout for Long-awaited Answers to Institutional Grant Questions and Reporting Guidance!”




Last Friday Aug. 28, 2020, ED posted a soft release providing revised guidance regarding how institutions of higher education who applied for and received  HEERF – Emergency Financial Aid Grants to Students must report, and make easily accessible for public review, seven key data elements regarding an institution’s acceptance, administration and disbursement of the funds.  As explained in the  revised Electronic Announcement (EA) published in the Federal Register Aug. 31, 2020.

“This revised EA maintains the same seven reporting elements (originally published in the Department’s May 6, 2020 guidance), but it adds a clarifying footnote for reporting item four and decreases the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter.

 Grantees posting a 45-day report on or after August 31, 2020 should instead post a report every calendar quarter, with the next calendar quarter report due by October 10, 2020 and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020.”


General Reporting Requirements

As previously stated in prior Department guidance, all institutions who received HEERF – Emergency Financial Aid Grants to Students are required to share specific information with the public which must appear in a format and location that is easily accessible.  The seven data items that must be reported to the Department and shared with the public are:

  1. An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to Students.
  2. The total amount of funds that the institution will receive or has received from the Department pursuant to the institution’s Certification and Agreement for Emergency Financial Aid Grants to Students.
  3. The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (e.,as of the initial report and every calendar quarter thereafter).
  4. The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act.[1]
  5. The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act.
  6. The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act.
  7. Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants.

(Reminder: This information must also be updated no later than 10 days after the end of each calendar quarter (September 30, and December 31, March 31, June 30) thereafter, unless the Secretary specifies an alternative method of reporting.)


Item 4 and the New Footnote

In addition to the revisions to the reporting timelines, the ED also provided a clarifying footnote that will likely come as favorable news for institutions as they attempt to comply with the reporting requirements and public sharing of information related to the allocation and disbursement of the HEERF Student Grant aid.  Simply put, ED clarifies how to determine the estimated number of eligible recipients for the Student Grants based upon ISIR data and other forms of alternative verification of eligibility established by the institution under the individual processes developed by the institution.  The data requirement and footnote read as follows:

“(4) The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to Students under Section 18004(a)(1) of the CARES Act.

 Footnote: For the purposes of this report, institutions may determine the number of eligible students based on the number of students for whom the institution has received an Institutional Student Information Record (ISIR) plus the number of students who completed an alternative application form developed by the institution for this purpose. The institution may then apply this number to its own methodological framework for disbursal of funds to produce a final total of eligible students at the institution. The institution is not asked to make assumptions about the potential eligibility of students for whom the institution has not received an ISIR or an alternative application.”



In a recent presentation by Deputy Assistant Secretary Christopher McCaghren, we remain confident that long-awaited guidance regarding answers to many questions posed by the higher education community at large, as well as specifically requested by our community, will be addressed in guidance from ED published this week.

Our belief is that this guidance is likely to include greater clarity on the permissible uses of the funds our community was eligible to receive (CARES Act, Section 18004(a)(1) grant funds).  We believe this guidance will include greater discussion and interpretive guidance on:

  • Acceptable forms of payroll allocations beyond those already provided;
  • Clear directives on the significant limitations in the use of Section 18004(a)(1) funds for reimbursement of lost revenue;
  • Clarifications on the scope of reporting required under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR part 200, as adopted and amended as regulations of the Department in 2 CFR part 3474; and
  • Much, much more!


FAME will constantly be hitting refresh on the Department’s HEERF Institutional Grants webpage and the specific links to the previously provided Frequently Asked Questions (FAQ) documents as well.

And we will of course notify you and summarize the information as soon as it comes out from ED.


Ineligibility to Compete for Institutional Resilience and Expanded Postsecondary Opportunity (IREPO) Grant Program 

One of the questions that was provided from our community was clarification on whether or not our sector was eligible to participate in the IREPO competitive grant program.  Neither the Deputy Assistant Secretary, nor FAME were completely certain as to whether or not we were eligible to participate, and committed to going back and reviewing the CARES Act requirements and provide an answer.  Unfortunately, the answer is a clear and unambiguous NO.  As prescribed in law:

Section 18004(a)(3) of the CARES Act directs the Secretary to allocate 2.5 percent of the $14.2 billion Higher Education Emergency Relief Fund (HEERF) funds appropriated by the Act to provide grants to institutions under part B of title VII of the Higher Education Act of 1965, as amended (HEA), for institutions that the Department has determined have the greatest unmet needs related to coronavirus. Part B of title VII of the HEA establishes the FIPSE. FIPSE grants, including grants under this program, are limited to institutions of higher education, as defined in section 101 of the HEA.


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