Cares Act Reporting

ED Releases Interim Reporting Guidelines for Student Portion
of the CARES Act Emergency Relief Fund

By Megan Walter, NASFAA Policy & Federal Relations Staff

The Department of Education (ED) on Wednesday released reporting guidelines for institutions that have received the student portion of their Higher Education Emergency Relief Fund (HEERF) allocation, which will be used to make emergency grants to students. While ED develops a process for institutions to directly provide the required reporting data, it has in the meantime called for institutions to make easily accessible to the public — via the institution's website — the following items:

• An acknowledgement that the institution signed and returned the certification and agreement form and that the institution has used, or intends to use the funds to provide the mandated amount of at least 50% of the emergency financial aid grants to students.
• The total amount of funds that the institution will receive, or has received under the HEERF student portion.
• Of those 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 every 45 days 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 and therefore eligible to receive an emergency financial aid grant.
• The total number of students who have received an emergency financial aid grant.
• How the institution determined which students did, or will receive emergency financial aid grants and how much funding they did, or will receive.
• Any instructions, directions, or guidance provided by the institution to students concerning the emergency financial aid grants.

Of note, ED made a change to when the 30-day reporting clock begins. Initially, ED had indicated that institutions were required to submit their first report 30 days from the date the institution signed the certification and agreement form. In this latest guidance, ED changed that date to 30 days from when the institution received its student portion of the HEERF.

ED noted that the above data points are to be reported in the aggregate and in a way that protects personally identifiable information, and should also be updated by the institution every 45 days after the first required 30-day reporting submission.