HEERF Annual Reporting Primer

By David B. McClintock, CPA | January 20, 2021

During 2020, the Higher Education Emergency Relief Fund (HEERF), included as part of the wide-ranging CARES Act, provided a lifeline to institutions of higher education and their students. As the policy and requirements for both the student and institutional grants evolved over the year, schools were required to post regular reports to their website, and now, the first annual report submission is due to the Office of Postsecondary Education (OPE) by February 1, 2021.

The final form to be completed for this submission was just released in December 2020 and can be found here. OPE has also created a resource page to assist institutions with all aspects of HEERF reporting.

As the submission deadline quickly approaches, we are sharing this HEERF Data Collection Form primer below. We will begin by highlighting changes from the original draft form that was released earlier in 2020, as well as the differences or additional information required by the annual reporting compared to the quarterly disclosures on a school’s website. We’ll follow it up with a breakdown of the form itself.

Significant Differences

  • Reporting Period Changed: The original regulations indicated that the reporting period for the initial annual report would be from March 13, 2020, through June 30, 2020. The final form updates this reporting period to be through December 31, 2020.We were able to confirm with OPE that this date was intentionally changed.
  • HEERF Student Reporting Additions:
    • Provide the aid awarded directly to students versus amounts reimbursed to school for payments made prior to receiving the grant; minimum and maximum amounts awarded to students inclusive of all aspects of 18004(a)(1-3)
    • Provide the number of students who received HEERF grants, number of students who received and dropped out, number of students who received and are still enrolled, number of students who received and graduated.
  • Full-Time Equivalent (FTE) Positions: Provide the institution’s FTE employees as of September 30, 2018; September 30, 2019; March 13, 2020, and December 31, 2020.

Annual Report Primer

Below is a quick breakdown of the sections included in the reporting form and the information required for each.

  • General Information: Provide institutional identifiers, HEERF grant PR/award numbers and amounts, contact information for lead contact at the school.
  • Funds Expended: Answer whether you expended all HEERF funds prior to the reporting period, which could make this the final annual report. The assumption is that very few schools will have expended all of the funds during this timeframe.
  • Websites: Provide URLs for active pages on the institution’s website where quarterly and other required reporting information is posted.
  • Student Eligibility: Questions regarding how the institution determined which students were eligible to receive emergency financial aid grants.
  • Aid Determination: Questions regarding how the institution determined which students received aid, including whether or not students applied for the funds, what needs were prioritized and whether or not the school used pre-existing data to determine amount of funds to students.
  • Aid Distribution: Answer how the institution distributed aid to students: checks, EFTs/direct deposits, debit cards, payment apps or other.
  • Emergency Grants: Explain and provide documentation (PDF/MS Word or URLs) supporting how the institution provided instructions, directions or guidance about the emergency aid to students.
  • Emergency Financial Aid: The most robust section of the form, institutions are required to provide specific information about number of students who received emergency grants and total amounts disbursed, which is used to calculate average grant amount.

The information requested about the emergency grants include:

    • Number of students eligible to receive emergency grants
    • Number of students who received emergency grants
    • Dollar amount of emergency grants disbursed to students

For each question, students are broken down into the following demographics:

    • Undergraduate students
      • Full-time students
        • Pell grant recipients
        • Non-Pell grant recipients
      • Part-time students
        • Pell grant recipients
        • Non-Pell grant recipients
    • Graduate students
      • Full-time students
      • Part-time students
  • Fund Expended Categories: Provide total amount of HEERF institutional grants expended on a number of categories, including:
    • Additional emergency grants to students
    • Reimbursement for tuition, housing, room and board or other fee refunds
    • Providing tuition discounts (only (a)(2) and (a(3) is eligible)
    • Covering cost of technology hardware to students
    • Providing or subsidizing the costs of high-speed internet to students or faculty
    • Subsidizing off-campus housing costs due to dormitory closures or paying for hotels or other off-campus housing to provide better social distancing
    • Subsidizing food service to reduce density in facilities, provide pre-packaged meals or extend food service hours of operation to accommodate social distancing
    • Costs related to additional class sections to enable social distancing
    • Campus safety and operations
    • Purchasing, leasing or renting additional instructional equipment or supplies to reduce sharing
    • Replacing lost revenue due to reduced enrollment (only (a)(2) and (a)(3) is eligible)
    • Replacing lost revenue from non-tuition sources (only (a)(2) and (a)(3) is eligible)
    • Purchasing faculty and staff training in online instruction
    • Purchasing, leasing or renting additional equipment or software to enable distance learning
    • Other uses (include explanatory note)
    • Other uses of (a)(2) or (a)(3), if applicable
    • Total dollars expended
  • Students Who Received Funds: Provide information the number of students who ever received HEERF grants and their enrollment status by the end of the period.
  • Full-Time Equivalent Positions: Provide the number of FTE positions as of a list of reporting dates (see above).

For more on HEERF reporting, see our resources page for helpful infographics and webinars, or reach out to the experts at McClintock & Associates.

Still have questions on HEERF Reporting?

Reach out to one of our experts and let us know how we can help.