As initially proposed in June of 2021 and subject to two comment periods, the U.S. Department of Education (ED) has released the revised Annual Performance Reporting (APR) form to capture the use and application of the Higher Education Emergency Relief Fund (HEERF) grants.
As a reminder, the APR filing is based upon the December 31st calendar year and not the institution’s fiscal year. ED indicated that the HEERF grant activities from January 1, 2021, to December 31, 2021, (Year 2) are to be submitted between April 11, 2022, to May 6, 2022. In addition, institutions will be able to correct filing errors on the 2020 activity (Year 1), which was submitted in early 2021.
The revised form has substantial changes as compared to the Year 1 activity APR and capturing this new information may require significant time for the institution. However, for several items, ED has allowed for a delay in reporting this new information until 2023 (Year 3). (See the note in Question 8 on page 6 of the revised APR). Thus, an institution which fully expended HEERF grants in 2021 will need to file a Year 3 APR if the new information is not submitted in the Year 2 report. (See tick mark 1 on page 2 of the revised APR).
Some of the notable changes in the revised APR are as follows:
- Question Nos. 8b – 8f: Expanded reporting of students receiving HEERF grants into various IPEDS categories of race/ethnicity, gender, and age.
- Question Nos. 9c & 9d: If lost revenue was utilized, the source of lost revenue and the estimated amounts.
- Question No. 10: Enrollment status of all degree/certificate seeking students for 2021, 2020 and 2019 by academic level, Pell grant status, enrollment intensity (full-time, part-time), and IPEDS categories of race/ethnicity, gender, and age.
Institutions should take the following steps now to be prepared in advance of the submission period.
- Review the entire revised APR, especially the new information to be reported.
- Determine if institutional systems can generate this information and, if not, what changes, processes or procedures must be updated.
- Based upon the previous point, deciding whether to report the new information in the Year 2 APR or the Year 3 APR.
- Review any prior HEERF audits for corrections to be made to the Year 1 APR which was filed.
- Watch for ED’s emails, user and reference guides, and a webinar over the coming months.
After performing over 40 individual HEERF audits during 2021, we recommend that institutions set up an internal quality control process, as the APR should be reviewed prior to being submitted. During our audits, we uncovered a fair number of findings related to the APR, and many of these could have been resolved through secondary review process. As a reminder, the quarterly reporting is still required and is not replaced or usurped by any annual reporting.
While this blog is being drafted, ED is beginning another negotiated rulemaking process, but it is unlikely that a reduction of information to be reported will result from the process. That’s why the professionals at McClintock & Associates are available to advise institutions. Schedule a call today.