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Updated 8/31/2020: On August 21, the Department of Education announced that it will extend most of the regulatory flexibilities related to the COVID-19 emergency through the end of the payment period that includes December 31, 2020, or the end of the payment period that includes the end date for the federally-declared emergency, whichever occurs later. The agency also announced that it is decreasing the reporting requirements for HEERF emergency grants to students to only quarterly updates.

The Electronic Announcement (EA) focused on regulatory flexibilities notes several exceptions, however, which are summarized below. Business officers are encouraged to read the EA in its entirety.

Reporting and Audit Requirements

Until further notice, financial statement and compliance audit deadlines are extended by six months. Deadline extensions applicable to Equity and Athletics disclosures (EADA), the Fiscal Operations Report and Application to Participate (FISAP), and Campus and Fire Safety remain as outlined in a July 10 announcement.

Campus-based Matching Requirements

The Coronavirus Aid, Relief, and Economic Security (CARES) Act waives the institutional share requirement associated with the Federal Work-Study and Federal Supplemental Educational Opportunity Grant programs for the 2019-20 and 2020-21 award years. Irrespective of when the national emergency declaration is lifted, no institutional match is required for either of these award years.

Return to Title IV

An institution is not required to return Title IV funds for any student who begins attendance in a payment period or period of enrollment that includes March 13, 2020, or begins between March 13 and the later of December 31 or the last date that the national emergency is in effect, and subsequently withdraws from the period as a result of COVID-19-related circumstances. Standard term programs must use the payment period to calculate returns.

Where an institution has opted to use the period of enrollment to calculate its returns for a non-term or non-standard term program, the waiver may apply to a student who begins attendance in a payment period that includes December 31, 2020, or the last date that the national emergency is in effect and withdraws after the conclusion of that payment period but within the applicable period of enrollment.

Other exclusions address the following topics:

  • Leave of absence
  • Foreign institutions
  • Academic calendars

The extensions had been announced in a series of EAs in 2020.

HEERF Emergency Grants to Students

In a separate August 31 Federal Register notice, ED announced that it was decreasing the frequency with which schools will have to report on emergency grants provided to students under Section 18004(a)(1) of the CARES Act Higher Education Emergency Relief Fund (HEERF). Institutions  still have to post information to their websites within 30 days of initially submitting their Certification and Agreement forms for the funds, which most schools have already done; however, subsequent student disbursement reports will now only need to be updated quarterly, rather than every 45 days as was previously required.

As reported earlier, ED is still seeking comments on additional reporting mechanisms for all HEERF aid. NACUBO will be submitting comments by the September 28, 2020 deadline.


Bryan Dickson

Director, Student Financial Services and Educational Programs


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