BEST PRACTICES FOR ACCOUNTING AND DISBURSING ALLOCATIONS FROM THE HIGHER EDUCATION EMERGENCY RELIEF FUND

Hogan Marren Babbo & Rose, Ltd. | HMBR

April 16, 2020

Co-authored by Michael Wherry of McClintock & Associates and Audrey Kaplan of HMBR

Since the U.S. Department of Education’s April 9, 2020, announcement of the forthcoming release of the student emergency funds as noted in Section 18004(c) of the Coronavirus Aid, Relief and Economic Security Act (CARES Act), we have had numerous discussions with clients in regard to the awarding, disbursing, accounting and reporting of these funds. As the Secretary noted in her cover letter, the “CARES Act provides institutions with significant discretion on how to award this emergency assistance to students. ….The only statutory requirement is that the funds be used to cover expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student’s cost of attendance, such as food, housing, course materials, technology, health care, and child care).” Due to the generous discretion being provided by the Secretary, institutions have the ability to target the emergency relief as best suits its student base. However, with this generous discretion, the onus of documentation supporting these emergency grants lies with the institution. ~ CONTINUE READING