On June 23, 2021, the Department of Education posted a proposed new data collection form for HEERF I, II and III. The Department of Education is inviting comments on or before August 23, 2021. A copy of the proposed form can be downloaded here. Make sure to click on the tab “Browse & Comment on Documents,” then “forms and instruments,” and download the file with the name “HEERF APR Revision Data Collection Form 6.15.21 FINAL”)

A few initial observations:

• The initial draft form has 18 pages, so the information requested is substantial, and will likely require some time to gather and sort underlying data in order to properly complete the form. A significant amount of demographic and enrollment data is being requested regarding the populations of students that received HEERF grants.
• The form requests information about how much was spent for “Implementing evidence-based practices to monitor and suppress coronavirus in accordance with public health guidelines” and how much was spent to “Conduct direct outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student, or other circumstances, described in section 479A of the Higher Education Act of 1965.” These two categories are included in the HEERF III FAQ as requiring some amount of spending on these efforts, but the FAQ gives no indication of how much is to be spent.
• Although question 12 of the lost revenue FAQs for HEERF III indicates that an institution does not need to assign specific costs or expenses once it has charged its HEERF grant award for its estimate of lost revenue, the draft of the form currently asks for information about how the lost revenue receipts were ultimately spent.

Please contact any member of the RubinBrown Colleges & Universities Group for more information.

 

^{Readers should not act upon information presented without individual professional consultation.}

^{Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.}