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As the coronavirus emergency continues, the Department of Education has adjusted (and readjusted) deadlines for grant applications, annual reporting requirements, and previously announced waivers of certain regulatory requirements.

Higher Education Emergency Relief Fund (HEERF)

Application Period. ED has reopened the application period for HEERF grants to allow eligible institutions more time to submit the required certifications, agreements, and data. The deadline, originally set for August 1, is now September 30.

Deadline to Spend HEERF Funds. Institutions generally have one year from the date of award to spend their HEERF grant. Due to the emergency, ED notes in an update to an FAQ on HEERF posted on August 6 that some institutions may have difficulty obligating the funds in that timeframe. Schools may request no-cost extensions for up to 12 months.

Public Posting of Grant Information. In an August 31 Federal Register notice, ED reiterated its earlier instructions to institutions on meeting the reporting requirements in the CARES Act related to HEERF grants. Schools are directed to report by posting the required information on their primary website “in a format and location that is easily accessible to the public.” The seven reporting elements remain as outlined in an earlier announcement, but a footnote has been added explaining how institutions should determine the number of eligible students.

While the report was originally due 30 days after the date ED obligated funds to the institution, the Federal Register notice provides some leeway. Institutions are encouraged to report as soon as possible, but no later than 30 days after the date of the notice or obligation of funds, whichever is later. Subsequent updates, which originally were scheduled for every 45 days, will now be required on a quarterly basis (within 10 days after September 30, December 31, March 31, and June 30).

Data Collection Form. A draft data collection form that schools would use to report to ED how they used HEERF funds is available for public comment. In addition to detail on the amount of funds provided to students, the form seeks information on the criteria institutions used to determine who would receive funds and how funds were disbursed. Comments are due September 28.

Routine Reporting Requirements

FISAP. The Fiscal Operations Report for 2019-20 and Application to Participate for 2021-22 (FISAP) is now available. Schools will have until November 2 to complete it. An August 3 electronic announcement provides special instructions for completing the FISAP to cover circumstances related to CARES Act funding and temporary changes to programs in response to the COVID-19 emergency.

Campus Security and Fire Safety. Colleges and universities are usually required to distribute annual reports on campus security and on fire safety to their campus community by October 1. While ED encourages schools to keep to this schedule, a July 10 electronic announcement extended the deadline to December 31. The annual survey that institutions are required to complete to share crime and fire statistics with ED will be open from November 18 to January 14, 2021.

Equity in Athletics. The July 10 notice extended the deadline for distributing the annual disclosures required by the Equity in Athletics Disclosure Act (EADA) from October 15 to December 31 as well.

Deadlines for COVID Flexibilities

In an August 21 electronic announcement, ED extended the deadline for the various regulatory flexibilities it has provided institutions related to the COVID-19 emergency. Generally, these waivers will be in effect through the end of the payment period that includes December 31, 2020, or the end of the payment period that includes the end date for the federally declared emergency. Additional details for specific regulations include:

  • No institutional match is required for either the 2019-20 or 2020-21 award years, regardless of when the emergency ends.
  • The maximum duration of a leave of absence is extended from 180 days to the number of days remaining in the calendar year.
  • The waiver of the requirement to return unearned Title IV funds for students who withdraw due to circumstances related to the COVID emergency is extended as noted above. Additional guidance is provided for institutions that use the period of enrollment to calculate returns for a non-term or non-standard term program.
  • Flexibilities related to academic calendars will remain in effect until the end of the academic year that includes December 31 or the end of the declared emergency, whichever occurs later.
  • The deadline for financial statement and compliance audits are extended by six months. The Office of Management and Budget has previously announced similar extensions.