Department of Education releases new round of COVID-19 funds for colleges and universities

HEERF reporting update

The required annual reporting period for the first Higher Education Emergency Relief Fund (HEERF I) began on Jan. 5, 2021 and ends on Feb. 1, 2021. The grantee reporting portal can be accessed here and additional resources are available here. All HEERF grantees are required to submit an annual report during this reporting period via the Annual Report Data Collection System. Each institution is required to submit the names and email addresses of those individuals who will be authorized to edit and submit the institution’s HEERF I annual performance report to heerfannual@ed.gov. Click here to access the example form provided by the U.S. Department of Education (ED).

Institutions must spend HEERF funds that were issued under the Coronavirus Aid, Relief and Economic Security (CARES) Act within one year from the date of the award in the Grant Award Notice. However, any institutions with unspent HEERF I funds may use the new expenditure requirements described below to spend the funds.

CRRSAA requirements

As part of the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) enacted on Dec. 27, 2020, the ED provided an additional $21.2 billion to institutions of higher education (IHEs) to serve students and ensure learning continues during the COVID-19 pandemic. See the ED funding allocation here. The Office of Postsecondary Education (OPE) released an outline of the second Higher Education Emergency Relief Fund (HEERF II) as well as helpful grant program FAQs.

Similar to the requirements in HEERF I, public and not-for-profit schools can use their awards for financial aid grants to students, student support activities, as well as to cover a variety of institutional costs. Proprietary schools must use their awards exclusively to provide financial aid grants to students.

Also similar to HEERF I, IHEs have one calendar year from the date of their award to expend funds unless the institution receives a no-cost extension. Institutions must provide the same amount in financial aid grants to students from HEERF II that it was required, or which it would have been required, to provide under HEERF I. Funds may be used for pre-award costs incurred on or after Dec. 27, 2020. Institutions must make financial aid grants to students that can be used for any component of the student’s cost of attendance, or for emergency costs that arise due to the coronavirus, including tuition, food, housing, healthcare and child care. Unlike HEERF I, HEERF II requires that institutions prioritize students with exceptional need, such as those who receive Pell Grants, and authorizes grants to students who are exclusively enrolled in distance education.

Institutions have expanded flexibility in their use of the supplemental institutional portion funds. Institutional portion funds under HEERF II may be used to defray expenses associated with the coronavirus (including lost revenue, reimbursement for expenses already incurred, technology costs associated with virtual learning, faculty and staff trainings and payroll), and to carry out student support activities authorized by the Higher Education Act that address needs related to COVID-19. ED has not provided guidance or examples of the lost revenue concept or calculation yet, so stay tuned for more on this topic. Additionally, institutional funds may also be used to provide financial aid grants to students using the same guidelines described above.

Reporting requirements will be specified in forthcoming announcements from ED. A fact sheet comparing HEERF II with HEERF I is available here.

In order to adequately prepare for distribution of HEERF II, institutions should consider the following key questions:

• What is the plan for allocation of the student portion and use of the institutional portion? Any changes based on lessons learned from HEERF I?
• What is the timing for distribution and use of funds considering the institution’s fiscal year end?
• What are the related accounting impacts of receipt and use of student and institutional funds, and the related financial statement considerations including revenue recognition and presentation on the Schedule of Federal Expenditures (SEFA)?
• Who will develop and deploy the methodology used to allocate the student portion of HEERF II, ensuring prioritization of students with exceptional need in distributing financial aid grants to students?
• How will the institution document each student’s eligibility to receiving the emergency grant funds?
• How will the institution document and monitor the process to ensure the institution provided the same amount in financial aid grants to students that were required under the original CARES Act?
• What documentation will the institution provide to show how the institutional portion of the CRRSAA was used?
• Who within the institution will be responsible for overseeing the distribution of the funds, monitoring compliance and documenting controls?

Baker Tilly can help

Our specialized higher education team can help institutions approach HEERF II, review allocation plans, discuss accounting treatment and navigate the CRRSAA.

We can also help guide institutions through the next round of the Paycheck Protection Program (PPP) and Employer Retention Credit (ERC). There have been notable changes to the now extended ERC, creating an entirely new credit for 2021 that is separate and distinct from the ERC available for 2020, and appears to offer a significant opportunity for institutions, even those that received funding through the PPP or PPP2.

For more information, or to learn how we can help, contact our team.