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NACUBO Comments on HEERF Quarterly Reporting

3/18/2022

The Department of Education has requested emergency clearance from the Office of Management and Budget for first quarter 2022 Higher Education Relief Fund (HEERF) Institutional Portion reporting. In comments on the request, NACUBO asked ED to hold off on clearance for new reporting requirements in the first quarter of 2022 (due April 10).

Citing a lack of time for institutions to prepare for the information request as well as issues with the report itself—such as a lack of clarity over whether emergency student aid was distributed from institutional portion, student portion, or both types of HEERF grants—NACUBO asked ED to defer new reporting requirements at least until after the annual HEERF reporting is submitted, and no sooner than the second quarterly report due date of July 10. NACUBO also requested that all student emergency grant aid information by student be included with Student Portion Reporting.

The Quarterly Report

In its request, the Department of Education seeks to add student information to the current HEERF Institutional Portion quarterly reporting form. Specifically, the proposed quarterly reporting form adds the following information requests for undergraduate and graduate students for (a)(1), (a)(2), and (a)(3) Institutional Portion grants and appears to also ask for the same information about Student Portion grants:

  • The amount of student emergency grant aid provided
  • Total enrollees
  • Amounts used to pay down student balances with student permission
  • Amount used to discharge account balances

The report form then redundantly adds some of the above information to the “matrix” of all institutional portion uses of funds.

Emergency clearance comments were due March 14, but additional comments can be submitted through April 18 as part of a regular clearance process. For those comments, ED is interested in feedback on–

  1. Whether the collection is necessary to the proper functions of the department
  2. If the information will be processed and used in a timely manner
  3. Whether ED’s estimate of burden is reasonable
  4. If the information to be collected is clear
  5. How ED can minimize the burden of information collection

NACUBO asks institutions to review the proposed form and submit comments to ED directly or to NACUBO for inclusion in our April 18 letter to ED.

Contact

Sue Menditto

Senior Director, Accounting Policy

202.861.2542

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