Education Department Issues Temporary Guidance on CARES Act Funds Reporting

While the Department of Education has not finalized the reporting portal for CARES Act funds, the clock is ticking towards the first deadline for reporting on those funds allocated to institutions. To meet the requirement in law to report regularly on the use of funds, the department issued guidance on the temporary reporting requirements that institutions must follow and that instructs institutions to make information public on an easily accessible portion of their websites.

Because the CARES Act requires institutions to make their first report within 30-days of initial receipt of funds, some institutions will be required to file their reports in a matter of days. (NOTE - this is an improvement over the initial announcement by the Department that institutions would have to submit their first report within 30 days of applying for funds.) The elements that must be reported on are:

• An acknowledgement 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.
• 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 Student.
• 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).
• 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.
• The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act.
• 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.
• Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants.

Among the requirements listed, the estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV (#4 above) is one that institutions are likely have no capacity to report on because no student is required to file a FAFSA. Therefore, there is no way of knowing how many students are eligible to participate.

In addition to the short turnaround, there are also privacy requirements institutions have to meet that make an institution’s capacity to produce this information quickly even more challenging.

For more information, please contact:
Stephanie Giesecke