Rebecca Flake and Kate Lee Carey
October 22, 2020
The Department of Education’s webinar provided some helpful additional context and explanation regarding the October 30 HEERF institutional reporting requirements.
In our October 8, 2020 blog post, we provided a summary of the recent Higher Education Emergency Relief Fund (HEERF) guidance issued by the Department of Education regarding the uses of the HEERF institution funds and the related reporting requirements. ED hosted a webinar on October 14, which expanded and clarified several aspects of these requirements. Below are the key points of guidance provided in the webinar.
Uses of HEERF Institutional Funds
Principal Deputy Under Secretary, Diane Auer Jones led an insightful discussion on the acceptable use of the §18004(a)(1) HEERF institutional funds. (Recall that this is the category of HEERF institutional funds that most institutions received.) She emphasized that ED was providing flexibility in the interpretation of what constitutes an expense related to the disruption of instruction. She explained that the key underlying principles to identify an eligible expense include:
An actual expense documented with a bill or an invoice to be paid
The expense is above and beyond what would have normally been paid before the COVID-19 pandemic
The expense is a direct result of changes the institution made in response to the pandemic
To identify the eligible portion of the expense, identify the “delta” by calculating the difference between the original (pre-pandemic) expense and the new expense