On September 23, 2020 ED released new, additional HEERF guidance providing further clarification and favorable responses to issues raised by the higher education community on four key topics.  This is the first of several pieces of new guidance that we have been informed by the ED will be forthcoming “shortly.”

The key takeaways from this email blast include:

  • The release of institutions from the reporting requirements under FFATA related to subawards!  This is very helpful clarification that makes it clear that institutions are not required to fulfill this reporting requirement as part of the Recipient’s Funding Certification and Agreement signed by all institutions receiving HEERF Institutional Grant assistance and
  • Additional guidance on compliance with the reporting on the disbursement of Emergency Financial Aid Grants to Students based upon the revised Electronic Announcements that preceded this publication – essentially reminding institutions of the new quarterly reporting requirement, October 10, 2020 reporting deadline for institutions to post information to on their respective website, and a footnote to explain the process.

In addition, the guidance clarifies acceptable forms of Personal Protective Equipment that it is permissible to use HEERF Institutional Grant funds to purchase and reminds all institutions of the pending September 28, 2020 deadline for submission of recommendations related to the posting of Institutional Grant information by institutions receiving and administering such funds.

Here is a comprehensive reprint of ED’s guidance:

The purpose of this email is to inform you of several recent updates to the CARES Act, Higher Education Emergency Relief Fund (HEERF) programs for institutions of higher education (IHEs):

(1) Personal Protective Equipment (PPE) is an allowable expenditure under HEERF

Just to clarify, purchases to ensure the physical safety of students on campus is an allowable use of a grantee’s Institutional Portion of its allocation under section 18004(a)(1) of the CARES Act, when these costs are new or added and needed to implement “significant changes to the delivery of instruction due to the coronavirus.”

This may include the reasonable costs of PPE, cleaning supplies, facility cleaning, or the purchase of items to help detect or prevent the spread of COVID-19 (e.g., thermometers, plastic barriers, or face masks). Grantees may also use these funds to make non-permanent changes to existing instructional facilities to ensure social distancing.

The purchase of PPE, cleaning supplies, facility cleaning, or the purchase of items to help detect or prevent the spread of COVID-19 items is also an allowable use of funds for grants received under sections 18004(a)(2) and 18004(a)(3) of the CARES Act.

(2) Federal Funding Accountability and Transparency Act of 2006 (FFATA) reporting not required for HEERF

Following the Department’s July 9 statement (published as an Electronic Announcement (EA) to institutions of higher education on July 10, 2020) regarding the use of the FFATA Subaward Reporting System (FSRS) for purposes of reporting the use of HEERF funds, we received a number of questions and concerns raised about reporting for HEERF grantees. We have since concluded that institutions receiving HEERF formula funding will not likely have subawards and will not be able to use FSRS for reporting their use of HEERF funds.

Therefore, the Department will be using the authority provided by Section 18004(e) of the CARES Act to specify how institutions will publish certain information on a quarterly basis on their websites. To this end, we have prepared a draft information form to accomplish this that is attached to this email. We intend to publish the form in the Federal Register shortly for public comment for a first report due October 30, 2020, covering the period from the date of the first HEERF grant award through September 30, 2020.
More information is available at our HEERF Reporting webpage https://www2.ed.gov/about/offices/list/ope/heerfreporting.html.

(3) Changes to the section 18004(a)(1) Student Aid allocation public reporting requirement

The Department has recently revised our May 6th Electronic Announcement (EA) on institutional reporting for the emergency financial aid grants to students made with institutions’ allocations under section 18004(a)(1), Student Aid Portion, of the CARES Act. This EA has been superseded by our August 31st EA found here in the Federal Register. It can also be found on our CARES Act HEERF homepage here.

This revised EA, in conjunction with approved information collection under OMB control number 1801-0005, requires grantees receiving awards under section 18004(a)(1) of the CARES Act to publicly post certain grant information on the institution’s primary website as part of the reporting requirements under section 18004(e) of the CARES Act. This revised EA maintains the same seven reporting elements, but it adds a clarifying footnote for reporting item four and decreases the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter.

Grantees posting a 45-day report on or after August 31, 2020 should instead post a report every calendar quarter, with the next calendar quarter report due by October 10, 2020 and covering the period from after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020.

If you have any questions regarding this revised notice, please send them to Jack Cox at Jack.Cox@ed.gov. Please also remember to check our HEERF Reporting webpage regularly for future CARES Act reporting requirements and updates.

(4) HEERF Annual Reporting Form 60-day public comment period closing soon
The HEERF Annual Information Collection Form was posted for a 60-Day public comment period. Please see our Federal Register Notice here and Form and Instructions and Supporting Statement here. Public
comments for this notice will be accepted through September 28, 2020, via Regulations.gov.


For additional information about HEERF programs, please visit the HEERF website. If you have any questions regarding these announcements, please contact the Department of Education’s HEERF Call
Center at (202) 377-3711 or HEERF@ed.gov.