NACUBO Recommends Improvements to HEERF Quarterly Reporting
4/25/2022
In February, the Department of Education requested comments on proposed Higher Education Emergency Relief Fund (HEERF) quarterly budget and expenditure reporting. The request sought emergency clearance for immediate first quarter 2022 reporting—which ED did not receive—and also asked for comments by April 18 to finalize the future quarterly reporting form.
In our April 18 comments, NACUBO asked ED to explicitly indicate on the form that the quarterly report includes both institutional portion use of HEERF funds as well as student aid information. Citing administrative burden reduction, the letter encouraged ED not to bifurcate reporting student head count and aid totals by HEERF (a)(1) institutional and student funding sources. NACUBO also asked ED to reduce confusion by clearly differentiating between lost revenue expenditure funds drawn and related fund use from expenditures claimed for allowable cost defrayment.
NACUBO’s comments included a redlined version of the proposed form to illustrate points made in the letter about student aid reporting. We also suggested wording in the “institutional expenditure” section to explain that questions about strategic planning or current use of funds should only apply to funds received for lost revenue claims.
