NASFAA AskRegs: What Are the CARES Act Section 15011 Quarterly Reporting Requirements?

This AskRegs Knowledgebase Q&A was updated on December 9, 2020 to combine multiple Q&As into a single Q&A on Section 15011 CARES Act Quarterly Reporting. The guidance did not change.

NASFAA is still looking into this, as federal grant administration is beyond our area of expertise. Here's what we know at this time.

See the July 10, 2020 Electronic Announcement, Update on Required CARES Act Quarterly Reporting, for the detailed list of Section 15011 quarterly reporting requirements.

Per the July 10 announcement, Section 15011 of the CARES Act requires any grantee that receives more than $150,000 in funds to report to the U.S. Department of Education (ED) on a quarterly basis on how those funds are utilized. The announcement goes on to state, "ED has determined that monthly reporting requirements specified in the Federal Funding Accountability and Transparency Act (FFATA) of 2006 would meet this requirement. Presumably, schools that have received grants from the federal government previously have already gone through this process by reporting on any grants in excess of $25,000 through the FFATA Subaward Reporting System (FSRS)."

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 the August 7, 2020 Today's News article, ED Indicates Institutions Without Subawardees Exempt from FFATA Reporting Requirements for CARES Act Funds.

Whether your school has subawardees, is a question for the individual on your campus who oversees federal grant administration or the Federal Service Desk (help desk).

Remember: Section 15011 quarterly reporting is separate from the Section 18004(e) reporting requirements for the student and institutional portions of Higher Education Emergency Relief Fund (HEERF) funds. NASFAA has confirmed with ED that the FFATA reports only meet the requirements of the Section 15011 quarterly reporting for the programs listed in the CARES Act Quarterly Reporting--July 2020 guidance, which includes the HEERF programs. It does not, however, cover the Section 18004(a)(1) Student Portion Public Reporting requirement for HEERF student grants.

ED has since developed the Section 18004(a)(1) Institutional Portion, (a)(2), and (a)(3) Public Reporting, otherwise known as the Quarterly Budget and Expenditure Reporting (QBER). NASFAA does not yet know if the QBER requirements would satisfy the Section 15011 reporting requirements, or if the Section 15011 Quarterly Reporting would satisfy QBER.

See AskRegs Q&A, What Are the Reporting Requirements For Higher Education Emergency Relief Fund Grants? for Section 18004(e) reporting requirements for the student and institutional portions of HEERF.

FFATA reporting continues to be required for other federal grants institutions receive and for which they make subawards, which could include CARES Act funds in the rare instances that institutions make subawards from those funds.

Additional Guidance: Refer to the following sources for additional guidance:

CARES Act Quarterly Reporting--July 2020 guidance, which was sent to schools that received CARES Act funds
NASFAA Today's News article, ED Releases New Reporting Requirements for HEERF Grants to Institutions (published July 9, 2020)

Unfortunately, we do not have guidance on how to complete FSRS reporting beyond what is available on the FSRS website:

As we have more information, we will post it in Today's News. In the meantime, if you have additional questions on Section 15011 reporting, send them to [email protected].

Note: This AskRegs Q&A was previously updated to include available FFATA and FSRS resources.