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

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This AskRegs Knowledgebase Q&A was updated on March 30, 2021 to include IRS guidance related to Higher Education Emergency Relief Fund (HEERF I) student grants under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) as well as HEERF II student grants under the 2021 Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA, Section 314 of the Consolidated Appropriations Act, 2021).

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:

"Q5. 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 under section 277 of the COVID Relief Act? (added March 30, 2021)

A5. 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 and A2 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.

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