Nonprofit Resources


Education Dept. Guidance on Initial Higher Education Emergency Relief Fund Reporting

Higher education institutions that receive funds through the Higher Education Emergency Relief Fund (HEERF) are required to report their methodology for disbursing these funds to the United States Education Department (ED) within 30 days of the date of their Certification and Agreement for the funds. Section 18004(c) of the CARES Act requires institutions to use at least 50% of the funds to provide Emergency Financial Aid Grants to students for expenses related to the disruption of campus operations due to COVID-19.

On May 6, 2020, the ED stated that it will provide instructions for submitting the required information “in the near future” and in the meantime, the following information must be posted on the institution’s primary website:

  1. Acknowledgment that the institution signed and returned the Certification and Agreement to the ED, and assurance that it has used, or intends to use, no less than 50% of the funds received under Section 18004(a)(1) to provide emergency financial aid grants to students.
  2. The total amount of funds that the institution will receive or has received from the ED pursuant to the institution’s Certification and Agreement [for] Emergency Financial Aid Grants to Students.
  3. The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day report and every 45 days thereafter).
  4. 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 thus eligible to receive Emergency Financial Aid Grants.
  5. The total number of students who have received an Emergency Financial Aid Grant.
  6. The method(s) used to determine which students would receive Emergency Financial Aid Grants and how much they would receive.
  7. Any instructions, directions, or guidance provided by the institution to students concerning Emergency Financial Aid Grants.

The ED also noted that that:

  • This information “must appear in a format and location that is easily accessible to the public” within 30 days of when the institution received the allocation.
  • This information must be updated every 45 days after the initial report.
  • Reporting should comply with, and protect personally identifiable information from student education records, under the Family Educational Rights and Privacy Act.
  • Accurately reporting the information above will meet the initial reporting requirements.
  • The ED will notify participating institutions of its preferred reporting method for subsequent reports and reporting for related HEERF programs

Please contact us with any questions. We are here to help.


Additional Resources:

Direct Financial Aid Grants for Students Under the CARES Act

ED’s CARES Act: Higher Education Emergency Relief Fund page

Dan Campbell

Dan serves as Partner and Higher Education Services Director at CapinCrouse. Dan has more than 35 years of public accounting experience leading audit engagements of nonprofit organizations and for-profit industries. He leads the firm’s higher education practice segment, which includes more than 80 client relationships, and commits a significant portion of his professional time to board training, strategic planning initiatives, and accreditation support. He served on the Board of Trustees of Davis College for 25 years. Prior to joining the firm in 2006, Dan managed audits of financial institutions, construction contractors, and manufacturers.

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