What Are the Reporting Requirements For HEERF Grants Before September 30, 2021?

The following HEERF I Reporting Requirements Table was available on the U.S. Department of Education's (ED's) HEERF Reporting and Data Collection website (1/5/2021 update) until sometime in Summer 2021:

CARES Act Section 18004(a)(1) Student Portion Public Reporting (Currently in Effect)
According to the May 6, 2020 Electronic Announcement, institutions that have awarded HEERF I grants to students from their allocation under Section 18004(a)(1) of the CARES Act are required to make the following information easily accessible to the public on the institution's primary website:

• An acknowledgement that the institution signed and returned the Recipient’s Funding Certification and Agreement for Emergency Financial Aid Grants to Students and that the institution has used, or intends to use, the funds to provide the mandated amount of at least 50 percent of the HEERF I grants to students.
• The total amount of Section 18004(a)(1) funds that the institution will receive, or has received, under the HEERF I student portion.
• Of those Section 18004(a)(1) funds, the total amount that has been distributed to students as of the date of reporting (i.e. the first 30-day deadline, and then the end of each calendar quarter thereafter).
• The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965, as amended (HEA), [20 USC 1091],and therefore eligible to receive an emergency grant.
• The total number of students who have received an emergency grant.
• The method the institution used to determine which students did or will receive emergency grants and how much funding they did or will receive.
• Any instructions, directions, or guidance provided by the institution to students concerning the emergency grants.

Separately, and not for publication on the school's website, the school also will need to document that it has continued to pay all of its employees and contractors during the period of any disruptions or closures to the greatest extent practicable, explaining in detail all specific actions and decisions related thereto, in compliance with Section 18006 of the CARES Act" See AskRegs Q&A, What Does "To the Greatest Extent Possible" Mean Under the CARES Act?

In the August 31, 2020 Federal Register, ED revised the May 6 announcement. The revised announcement maintains the same seven reporting elements, but it adds a definition for "total number of eligible students." For purposes of this reporting, institutions should calculate the number of eligible students by adding the number of students for whom the institution has received an Institutional Student Information Record (ISIR), plus the number of students who completed an alternative application form developed by the institution for this purpose, if any. Of that total, the number of students who are eligible for an emergency grant per the institution's awarding criteria would be the final total of eligible students at the institution. The institution is not asked to make assumptions about the potential eligibility of students for whom the institution has not received an ISIR or an alternative application.

Student Portion Reporting Deadlines: After multiple changes to the deadline, the original report was due to be posted on the institution's website 30 days from when the institution received its Grant Award Notification (GAN) informing the institution that the funds were available for drawdown. In the August 31, 2020 Federal Register, ED updated the frequency of reporting after the initial 30-day report. Subsequent reports must be posted to the institutions website no later than 10 days after the end of each calendar quarter (September 30, December 31, March 31, June 30) thereafter until HEERF I student funds are fully expended.

If the institution was previously required to post the report sometime in September due to now outdated deadlines, then the school should have waited to post its quarterly report by October 10 (and not post twice).

According to guidance NASFAA has received from ED, this student portion reporting can be done on a cumulative basis, meaning this information can be contained in one single report that is updated quarterly to show only cumulative information and not show information for each quarter separately. If there is no change, simply update the date and leave the information the same.

Reference the May 6, 2020 Electronic Announcement and the August 31, 2020 Federal Register, especially if you are looking for information on how these reporting requirements have changed since May 6, 2020.

Reference the January 15, 2021 Electronic Announcement for information about noncompliance with the above student portion reporting requirements.

Section 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) Public Reporting, Otherwise Known As the Quarterly Budget and Expenditure Reporting (QBER) (Currently in Effect)

The HEERF I reporting requirements are detailed in the Quarterly Budget and Expenditure Reporting form, which is located on ED's HEERF Reporting and Data Collection website. Institutions complete this form to satisfy the reporting requirements outlined in the QBER. Note that on September 23, 2020, ED emailed all grantees a copy of the draft QBER. ED has since made changes to the draft form and posted a final version of the QBER to the HEERF Reporting and Data Collection website on October 13, 2020. Institutions should be careful to report using the final form and not the previously emailed draft form.

The QBER must be posted to the institutions’ primary website, on the same page as they post their Student Portion Public Reporting (noted above), either as text or as a link to a PDF of the report. The QBER is distinct from both the Student Portion Public Reporting (noted above) and from the proposed Annual Reporting (noted below).

QBER Deadlines: The institution's first QBER was required to be submitted by October 30, 2020 and should have included cumulative expenditures over the period from when the funds were first awarded through September 30, 2020, according to ED.

The subsequent quarterly reports must be posted no later than 10 days after the end of each calendar quarter, meaning January 10, April 10, July 10, and October 10. Subsequent reports must include data only for the quarter being reported; it cannot be cumulative covering mulitple quarters in one report. Each quarterly report must be separately maintained on the institution’s website. Quarterly submission of the QBER would be required until September 30, 2022. However, institutions do not need to continue quarterly reporting once they have exhausted all their funds, ED said. In such a case, the institution would only need to post its final expenditure report.

Additionally, ED is encouraging institutions to email [email protected] with their webpage where they post their quarterly reports. ED said it is asking institutions to both email them and post their reporting requirements publicly on their primary website in an effort to make the entire process accessible and accountable to the public. ED has posted a spreadsheet of institutions’ reporting web pages.

Reference the January 15, 2021 Electronic Announcement for information about noncompliance with the above institutional portion reporting requirements.

Annual Reporting (Currently in Effect, 2021)
In the July 29, 2020 Federal Register, ED posted an information collection request on a data collection form to satisfy HEERF I reporting requirements specified in Section 18004(e) of the CARES Act, which states that an institution "receiving funds under this section shall submit a report to the Secretary, at such time and in such manner as the Secretary may require, that describes the use of funds provided under this section."

The first submission of this new data collection is done through the HEERF Annual Report Data Collection System and is now due on February 8, 2021. The second is due on February 1, 2022, and the third is due on February 1, 2023.

HEERF Annual Report Data Collection System: ED began sending emails to campus officials on January 5, 2021 announcing the availability of the data collection system, along with login credentials to access the system. Institutions were required to provide ED with contact information for the individuals who should receive this information in early December. If you have not yet provided contact information to ED or have not received login information, contact [email protected].

Institutions that received HEERF I funds under any part of Section 18004 of the CARES Act—which includes emergency grants for student expenses related to COVID-19; funds for institutional costs associated with significant changes to the delivery of instruction due to the coronavirus; funding for HBCUs, MSIs, and TCUs; and FISPE funding—are subject to this additional reporting requirement. Data elements to be collected include:

• How institutions determined which students were eligible for emergency grants and how amounts were determined;
• How institutions established that students met the Title IV eligibility requirements;
• The payment method used for emergency grants to students;
• Withdrawal rates for students who received emergency grants; and
• A categorized list of how the institutional share was spent.

The purpose of this new data collection would be to provide ED with the information necessary for department staff to monitor that institutions spent HEERF funds in accordance with the allowable uses of funds. Descriptive statistics from the data collection would be made publicly available by ED.

While this new reporting requirement satisfies the reporting requirement specified in Section 18004(e) of the CARES Act, it does not replace the Student Portion Public Reporting or QBER noted above. Those website URLs noted above would be a required data element on this new information collection.

This new reporting requirement is also unrelated to, and does not substitute for, the Section 15011 CARES Act Quarterly Reporting requirements noted below.

Reference the January 15, 2021 Electronic Announcement for information about noncompliance with the above student portion reporting requirements.

CARES Act Section 15011 Reporting (Currently in Effect But Not Applicable to Most Schools)
Section 15011 of Division B of the CARES Act requires a grantee receiving more than $150,000 to report to ED on a quarterly basis. These CARES Act Quarterly Reporting requirements are detailed in the July 10, 2020 Electronic Announcement. According to ED, Section 15011 quarterly reporting requirements would be satisfied by the school's compliance with the Federal Funding Accountability and Transparency Act (FFATA) of 2006. FFATA reporting is for federal grantees who make subawards from those federal grants, which is not the case for the majority of institutional CARES Act grant recipients. In conversations with ED, the department acknowledged widespread confusion on reporting requirements and confirmed that it would be rare for institutional CARES Act recipients to have sub-awardees and, as such, most institutions would not be subject to FFATA reporting for their CARES Act funding.

See AskRegs Q&As, Which Schools Must Complete Federal Funding Accountability and Transparency Act (FFATA) Reporting For CARES Act Grants? and Where Can We Find Guidance For CARES Act Quarterly Reporting Under Section 15011?

NASFAA does not yet know if the QBER or Annual Reporting requirements noted in the above chart would satisfy the Section 15011 reporting requirements, or if the Section 15011 Quarterly Reporting would satisfy QBER. If/When we receive further guidance from ED, we will update this AskRegs Q&A and post it in Today's News.

HEERF II and HEERF III Reporting Requirements

According to Q&A #36, #37, and footnote #11 in the HEERF III Frequently Asked Questions, as well as the May 13, 2021 Federal Register: 

Quarterly Reports: ED confirms that institutions will be required to post the Quarterly Institutional Public Reporting Form (which was updated on May 11, 2021) and the Quarterly Student Public Reporting Form (updated May 13, 2021) for HEERF II and HEERF III funds to their websites by the tenth day following the end of each calendar quarter, as has been that case for HEERF I funds (detailed above).

In footnote #11, ED acknowledges that, because it never affirmatively established HEERF II reporting requirements, it is extending the deadline by which institutions must submit retroactive HEERF II reports for the first quarter of 2021 (January through March) to the end of the second calendar quarter, which is June 30, 2021. When asked if this June 30th date is correct or should be July 10, 2021, ED responded vaguely "And yes, quarterly reports are generally required to be publicly posted 10 days after the close of the quarterly reporting period."

Clarification on Cumulative Reporting: Refer to the following Questions and Answers:

"NASFAA Question 1: Can quarterly reports be cumulative across multiple HEERF funds? That is, can one quarterly report be posted that includes cumulative HEERF I, II, and III funds in the same report?

ED Answer 1: Quarterly reports are assumed to merge within a single report an institution's expenditures across the different strands of HEERF grant funds (HEERF I, II, and III) unless an institution's reporting explicitly designates a Quarterly report as only pertaining to a specific set of HEERF funds (e.g., posting a separate Quarterly report for ARP funds). However, each report should be distinct in that each report covers those expenditures under the specific quarterly timeframe.

NASFAA Question 2: Within HEERF funds, is the student quarterly report cumulative and the institutional quarterly not cumulative?

ED Answer 2: Reports should not be cumulative but cover the specific quarterly reporting timeframes. [Note: If institutions earlier reported their student quarterly reporting as cumulative and not specific to each quarter, the Department is not requiring institutions to “go back” and fix those reports.]"

Initial 30-Day Report: There is a separate initial 30-day reporting requirement per the May 13th Federal Register: "The Department encourages institutions to report as soon as possible, but no later than 30 days after the publication of this notice or 30 days after the date the Department first obligated funds under HEERF I, II, or III to the institution for Emergency Financial Aid Grants to Students, whichever comes later."

ED Clarification: According to ED, if the school already posted its first 30-day report for HEERF I, it is not required to post another 30-day report for HEERF II (or a HEERF III 30-day report if it already posted one for HEERF I or HEERF II).

Annual Reports: HEERF II and HEERF III funds will also be subject to the annual reporting requirement, which is next due in early 2022. At the time of this July 9, 2021 update, ED has not yet finalized what will be included in the next HEERF annual report. ED does provide preliminary guidance on what institutions should be documenting now, as they continue to award their remaining HEERF I and II funds and begin awarding their HEERF III funds, in order to be prepared for the next annual report.

First, with respect to the requirement that institutions prioritize the awarding of HEERF III grants to students with exceptional need, ED advises institutions to "carefully document how they prioritize students with exceptional need in distributing emergency financial aid grants to students, as the Department is exploring reporting requirements regarding the distribution of emergency financial aid grants to students."

ED also indicates that it is exploring collecting more information on the HEERF annual report on institutions' implementation of two new required activities Congress added to the American Rescue Plan: implementing evidence-based practices to monitor and suppress the coronavirus, and conducting direct professional judgment (PJ) outreach to financial aid applicants.

Specifically, ED advises institutions to document (1) the strategies used to monitor and suppress COVID-19, (2) the evidence to support those strategies, (3) how those strategies were in accordance with public health guidelines, (4) the manner and extent of the direct outreach the institution conducted to financial aid applicants, and (5) how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution.

Additional Questions? You have to do your best to apply this guidance and the May 13, 2021 Federal Register. All additional questions on reporting must be submitted to the contact in the Federal Register and/or [email protected].

Update Notes:

• This Q&A was updated on July 9, 2021 to include clarifications and outstanding questions we had with ED related to HEERF II and HEERF III reporting requirements.
• This Q&A was updated on May 14, 2021 to include guidance in the May 11, 2021 HEERF III Frequently Asked Questions.
• This Q&A was updated on January 29, 2021 to indicate that, in a letter sent to the schools' designated Grants.gov contacts, ED extended the deadline for schools to complete their first annual report on the use of HEERF I student and institutional funds. The new deadline was February 8, 2021.
• This Q&A was updated on January 6, 2021 to reflect the opening of the HEERF I Annual Report Data Collection System, which at the time gave schools until February 1, 2021 to complete the first annual report on the use of HEERF I student and institutional grants.
• This Q&A was previously updated on December 3, 2020 to reflect the latest information available on the HEERF student and institutional grant reporting requirements under Section 18004(e) of the CARES Act.
• This Q&A was previously updated on September 1, 2020 to reflect an August 31, 2020 Federal Register change in the HEERF student grants reporting requirements, and it includes ED clarification on reporting for September/October 2020.
• This Q&A was previously updated to reflect three sets of reporting requirements for HEERF grants to students.
• Reporting is the responsibility of the school. Nothing requires that this be done by the financial aid office because these are not Title IV funds. Also, students who receive HEERF student grants from their institutions are not required to record or track how it is spent.