ED just released guidance for institutions to report how they are using CARES Act Emergency Grants distributed to students under the HEERF. Schools must submit an initial report to ED within 30 days of the institution’s Certification and Agreement and 45 days thereafter. Instructions on the reporting process will be forthcoming in addition to other announcements.
In the meantime, the Department is instructing institutions to post information publicly on their school’s website. To be in compliance schools must post the following information on their website within 30 days after the date when the institution received its allocation of Emergency Grants for students under 18004(a), and update it every 45 days thereafter until such time as the Department provides other guidance.
1. An acknowledgment that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES 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 pursuant to the institution’s Certification and Agreement [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 CARES Act as of the date of submission (i.e., 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 of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act.
5. The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act.
6. The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act.
7. Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants.
ED’s Office of Postsecondary Education noted in their recent announcement that institutions must be sure to protect the confidentiality of student data such as student Personally Identifiable Information (PII), adhere with FERPA requirements and use appropriate data suppression methods to do so. Read the May 6, 2020 announcement for more details.