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In a recently published information collection request for the Coronavirus Aid, Relief, and Economic Security (CARES) Act Higher Education Emergency Relief Fund (HEERF), the Department of Education provided a reporting form that will be used to collect information on the following HEERF programs: emergency student aid; institution funds; funds for Historically Black Colleges and Universities, Tribally Controlled Colleges and Universities, and Minority Serving Institutions; and the Fund for the Improvement of Postsecondary Education. ED is accepting comments through September 28.

The notice indicates that the information submission deadlines are as follows:

  • January 29, 2021, for the reporting period from March 13–June 30, 2020
  • September 30, 2021, for the reporting period from July 1, 2020–June 30, 2021
  • September 30, 2022 for the reporting period from July 1, 2021–June 30, 2022

A downloadable sample report from the Federal Register provides insight into documentation and fund use details that ED would like to collect. The sample report covers all HEERF programs for all types of institutions and consequently all program attributes are listed on the illustrative form. ED will use skip logic to drive institutions toward their applicable HEERF program attributes based on an institution’s OPEID number. Consequently, institutions receiving student aid (CFDA 84.425 F) and institutional funds (CFDA 84.425F) should not assume that reduced tuition revenue caused by lower fall enrollments or reduced tuition prices are an allowable use of institutional portion HEERF.

The comment request relates to burden. ED is seeking input on data that would be difficult to report, additional data that would be important to collect, suggestions for reducing reporting burden, recommendations for improving information accuracy, and feedback on completion time estimates. This is an opportunity for institutions to evaluate this reporting request and provide feedback.

Comments must be submitted through the Federal Register portal for docket no. ED-2020-SCC-0122. NACUBO will comment on estimated burden and reasonableness of data requests and will ask for clarification on several allowable use lines presented in the illustrative form. 


Sue Menditto

Senior Director, Accounting Policy


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