CARES Act Reporting Requirements for Colleges and Universities

Section 18004(e) of the CARES Act (the Act) directs institutions receiving funds under Section 18004 of the Act to submit a report to the Education Secretary describing the use of funds distributed from the Higher Education Emergency Relief Fund (HEERF). The certification agreement states that the institution must submit an initial report to the Education Secretary 30 days from the date of the institution’s signed agreement with the Department.

The Education Department has not issued the required reporting format to the Department, but during the interim the institution must post the information listed below on its primary website:

1. An acknowledgement that the institution signed and returned to the Department the certification agreement and the assurance that the institution has used, or intends to use, no less than 50% of the funds received under the Act to provide Emergency Financial Aid Grants to students.
2. The total amount of funds that the institution will receive, or has received, from the Department for emergency financial aid grants to students.
3. The total amount of emergency financial aid grants distributed to students under Section 18004(a)(1) of the Act as of the date of submission of the report (as of the 30-day report and every 45 days thereafter).
4. The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV funding and thus eligible to receive the grants under Section 18004(a)(1) of the Act.
5. The total number of students who have received an emergency grant under Section 18004(a)(1) of the Act.
6. The method(s) used by the institution to determine which students received emergency grants and how much they would receive under Section 18004(a)(1) of the Act.
7. Any instructions, directions, or guidance provided by the institution to students concerning the emergency financial aid grants.

The above information should be posted to the institution’s website 30 days after they have received their allocation of funding under 18004(a)(a) and then updated every 45 days thereafter. The institutions should use discretion to ensure they are compliant under the Family Educational Rights and Privacy Act. The Education Department does not expect institutions to report information about a group of 10 or fewer students. Institutions who post the above required information will meet the initial reporting requirements for HEERF funding. The Department of Education will notify participating institutions the preferred reporting methods going forward for the 45-day requirements.