Reminder to Higher Education Institutions of October 30 Deadline for CARES Act HEERF Institutional Fund Reports

Faegre Drinker Biddle & Reath LLP

As communicated in two email blasts from the U.S. Department of Education (ED) — first on September 23, 2020 and again on October 19, 2020 — postsecondary institutions that have received Higher Education Emergency Relief Fund (HEERF) grants under Section 18004 of the Coronavirus Aid, Relief and Economic Security (CARES) Act must post their first HEERF quarterly institutional fund report no later than October 30, 2020. This first institutional fund report must reflect all expenditures of HEERF grant awards, including the institutional portion of Section 18004(a)(1) awards as well as funds received under Sections 18004(a)(2) and 18004(a)(3), between the date such funds were initially received and September 30, 2020. During an October 14, 2020 webinar, which is available here along with other information on HEERF reporting requirements, ED clarified that each quarterly report should be compiled based on the institution’s expenditure dates — rather than the date of reimbursement from its HEERF grant award. ED also requested that the reporting form be completed electronically and not include any handwritten entries.

An institution must post the completed HEERF quarterly institutional fund report form (or a link thereto) on the institution’s public website in the same location where it posts the required HEERF student emergency grant data. Subsequent quarterly reports must be similarly posted within 10 days of the end of the quarter (i.e., January 10, 2021; April 10, 2021; July 10, 2021) and include expenditures only for that previous quarter.

ED also has indicated that all of an institution’s HEERF quarterly reports (both institutional portion and student aid-related) should remain publicly accessible on the institution’s website and not be removed when new quarterly reports are posted. An institution may also provide a readily accessible link to its past quarterly HEERF reports instead of embedding all reports on the same webpage, and these reports must be maintained for a three-year record retention period. ED has not yet indicated, however, when institutions may remove these reports from their public websites.

During its webinar explaining these requirements, ED further requested that institutions email a link to their HEERF reporting page to HEERFreporting@ed.gov. Although that is not expressly required by the CARES Act, we are aware of ED contacting institutions that it believes have not complied with the HEERF reporting requirements to date. Institutions proactively sending ED the links to their HEERF reporting websites therefore will assist ED in monitoring compliance with its requirements.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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