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In June, the Department of Education shared an updated proposed annual reporting form for colleges and universities related to their use of Higher Education Emergency Relief Fund (HEERF) federal COVID-19 relief aid. The department requested public comments in response to the proposed form and NACUBO joined with the National Association of Student Financial Aid Administrators (NASFAA) to submit a letter raising several concerns with the form and offering suggestions for its improvement.

Areas of Concern

Related to reporting requirements concerning funds used for emergency grants to students, the letter expresses concern that ED’s request for significant student demographic data greatly exceeds what is required to ensure institutional compliance with the law, particularly as these funds are meant to address specific COVID-19-related needs within a finite period and will not be a recurring source of funding.

In addition, because schools tracked which students received emergency grants in varying systems—in some cases outside of existing student financial aid systems—we raised concerns that having to retroactively incorporate that tracking into other systems in order to collect the demographic data ED is seeking will represent significant time and expense burdens to institutions.

The letter also highlights several areas where student demographic data may be impossible to accurately report on ED’s proposed form, and that several of the proposed questions related to student-facing HEERF issues require subjective responses that will not result in reliable data reporting.

We also raised multiple concerns with proposed reporting requirements pertaining to institutional lost revenue expenses. Seemingly new requirements that would necessitate segregating HEERF institutional funds into separate programs or funds for budgeting, unclear footnote guidance, and lost revenue categories that do not match ED’s own existing lost revenue guidance need clarity. Additionally, there are several areas on the form, such as within the functional expense information request, where it would be functionally impossible for schools to produce all the data ED is proposing to request.

NACUBO and NASFAA’s comments provide suggestions for alternative reporting requirements where necessary but also recommend that some proposed items be removed from the form entirely, in order to obtain the most accurate reporting information for ED without being overly burdensome to colleges and universities.

NACUBO will continue to monitor the development of the proposed form and urges ED to adopt our suggestions.


Megan Schneider

Senior Director, Government Affairs



Sue Menditto

Senior Director, Accounting Policy


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