Are Schools Required To Issue IRS 1099-MISC Forms To Higher Education Emergency Relief Fund Grant Recipients?

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This guidance is not award-year-specific and applies across award years.

This AskRegs Knowledgebase Q&A was updated on February 16, 2022 to note that the IRS guidance applies to all three programs--Higher Education Emergency Relief Fund (HEERF I) student grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), HEERF II student grants under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021), and HEERF III grants under the American Rescue Plan Act of 2021 (ARP).

No. According to the IRS, schools are not required to issue IRS 1099-MISC forms to students who receive HEERF I or HEERF II student grants. Per the IRS Higher Education Emergency Grants Frequently Asked Questions website:

"Q6. Q6. Do higher education institutions have any requirements under Internal Revenue Code section 6041 to report information on Form 1099-MISC for emergency financial aid grants awarded to students under section 3504, 18004, or 18008 of the CARES Act, or otherwise in response to the COVID-19 pandemic (including under other provisions of the CARES Act, section 314 of the COVID Relief Act, or section 2003 of the ARP)?

A6. No, higher education institutions do not have information reporting requirements under section 6041 with respect to the emergency financial aid grants. These grants are not included in students' gross income, as described in A1, A2, and A3 above. Because the grants are not income, section 6041 does not apply to them, and higher education institutions are not required to file or furnish Forms 1099-MISC, Miscellaneous Income, reporting the emergency financial aid grants."

Any additional questions about the taxability or IRS treatment of HEERF funds must be referred to the IRS or to the National Association of College and University Business Officers (NACUBO), as this is not within NASFAA's area of expertise.

Note: The IRS has not yet issued similar guidance related to HEERF III funds under the American Rescue Plan of 2021 (ARP). As soon as they do, we will update this AskRegs Q&A.

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.