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A June 24 Department of Education information request proposes significant new annual Higher Education Emergency Relief Fund (HEERF) reporting requirements for both student and institutional funds. Comments are due August 23, 2021.

For institutional HEERF funds, the proposed reporting form would require allowable use reporting and would gather information about how funds applied to lost revenue were subsequently used. Institutions would be required to report such fund use by functional expense categories used in the Integrated Postsecondary Educational Data System (IPEDS) finance survey. Proposed emergency student aid reporting would require calendar year 2020 and 2021 student demographic information, based on IPEDS categories, for HEERF aid recipients and non-HEERF aid students by enrollment, degree or program completion, and retention. Pre-pandemic 2019 base year reporting would require demographic information for all enrolled students by degree or program completion, and retention status.

ED is requesting that comments address if:

  • The information is necessary
  • Burden estimates are accurate
  • The clarity, quality, and utility of collected information can be improved
  • There are ways ED can minimize collection burden, including through the use of information technology

The annual data collection applies to the following HEERF categories authorized under the CARES Act, CRRSAA, and ARPA:

  • Student Aid (CFDA 84.425E)
  • Institutional Portion (CFDA 84.425F)
  • Historically Black Colleges and Universities (CFDA 84.425J)
  • American Indian Tribally Controlled Colleges and Universities (CFDA 84.425K)
  • Minority Serving Institutions (CFDA 84.425L)
  • Strengthening Institutions Program (CFDA 84.425M)
  • Fund for the Improvement of Postsecondary Education (CFDA 84.425N)
  • Proprietary Institutions Grant Funds for Students (CFDA 84.425Q)

NACUBO encourages institutions to comment separately and also to contact us with feedback to inform our comments.


Sue Menditto

Senior Director, Accounting Policy


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