NASFAA Policy and Federal Relations Team

Jill Desjean

July 30, 2020

On Wednesday, the Department of Education (ED) posted in the Federal Register an information collection request on a data collection form to satisfy Higher Education Emergency Relief Fund (HEERF) reporting requirements specified in section 18004(e) of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, which states that an institution “receiving funds under this section shall submit a report to the Secretary, at such time and in such manner as the Secretary may require, that describes the use of funds provided under this section.”

The first submission of this new data collection would be due on Jan. 29, 2021; the second on Sept. 30, 2021; and the third on Sept. 30, 2022.

Institutions that received HEERF funds under any part of section 18004 of the CARES Act — which includes emergency grants for student expenses related to COVID-19; funds for institutional costs associated with significant changes to the delivery of instruction due to the coronavirus; funding for HBCUs, MSIs, and TCUs; and FISPE funding — would be subject to this additional reporting requirement. ED estimates it would take institutions 1.5 hours to complete the survey, and data elements to be collected would include:

• How institutions determined which students were eligible for emergency grants and how amounts were determined

• How institutions established that students met the Title IV eligibility requirements

• The payment method used for emergency grants to students

• Withdrawal rates for students who received emergency grants

• A categorized list of how the institutional share was spent

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