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Post-Secondary Educational Institutions and COVID-19 Considerations – Updated 5-12-2020

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This article is dedicated to resources for post-secondary educational institutions. We have summarized and provided additional information to help institutions of higher education navigate some of the issues they are facing in their industry. If you have any questions not listed here, or need more detailed information relating to any of these topics, please reach out to us, we’re here to help you.

Please check this page regularly as we will be updating it with new information as it becomes available.

In addition to the below content, please visit our page covering issues relating to the impact on financial statements and reporting considerations that will be helpful to understand for your annual audit: Financial Statement Impacts of COVID-19.


Department of Education has a resource page that contains a lot of useful information: https://www.ed.gov/coronavirus

April 21, 2020: The Department of Education has released institutional-level funding amounts for the Higher Education Emergency Relief Fund (https://www2.ed.gov/about/offices/list/ope/allocationsforsection18004a1ofcaresact.pdf) along with guidance on how to use the funds. 50% of the funds are designated as emergency grants to students and must be applied for first. Institutions cannot use this 50% of funds to reimburse themselves for costs or expenses (like the cost of delivering instruction as a result of COVID-19, or for previously issued refunds to students, etc.). They are simply cash grants to students. After getting approved for the students’ portion, then the institution can apply for the other 50% to help cover their own costs incurred as a result of COVID-19. In order to get the funding, an institution will need to sign a certification form attesting that they will use the funds in accordance with the law. The funds will be drawn down through G5. The certification forms have the requirements in them:


IFAP‘s COVID-19 resources:

May 6, 2020: HEERF Reporting Requirements: https://ifap.ed.gov/electronic-announcements/050620HigherEdEmergencyReliefFundRptg

April 3, 2020: Guidance on administering HEERF funds: https://ifap.ed.gov/electronic-announcements/040320UPDATEDGuidanceInterruptStudyRelCOVID19


Federal Student Aid has information on the Coronavirus and Forbearance Info for Students, Borrowers, and Parents (March 27, 2020): https://studentaid.gov/announcements-events/coronavirus


National Association of Student Financial Aid Administrators (NASFAA) has a COVID-19 resource page: https://www.nasfaa.org/covid19

May 6, 2020: The Office of Inspector General (OIG) is taking steps to inspect and scrutinize how institutions are using the students’ portion of HEERF funds and how the Department of Education implements the CARES Act: https://www.nasfaa.org/news-item/21822/ED_s_Internal_Watchdog_Releases_Plan_to_Oversee_Billions_in_COVID-19_Relief_Funding

April 30, 2020: 1098-T reporting requirements for HEERF/FSEOG funds: https://www.nasfaa.org/news-item/21770/Trending_AskRegs_Q_A_Are_Emergency_FSEOG_Awards_Reported_On_IRS_Form_1098-T

April 29, 2020: Verification under the COVID-19 flexibilities do not apply to the summer crossover that is a header to the 2020-21 award year: https://www.nasfaa.org/news-item/21747/Trending_AskRegs_Q_A_Do_the_COVID-19_Verification_Flexibilities_Apply_To_a_Summer_Crossover_That_Is_a_Header_To_the_2020-21_Award_Year

April 22, 2020: Students who were enrolled exclusively in online programs on March 13 are not eligible to receive the emergency grants. Also, institutions may not use the student portion of funding to reimburse themselves for tuition or room and board refunds, and that the student grants may not be used to cover outstanding balances on a student account. Only Title IV eligible students would be able to receive emergency grants, the guidance also excluded international students and those in the Deferred Action for Childhood Arrivals (DACA) program from receiving emergency funding.

April 21, 2020: NASFAA addresses the Department of Education’s additional guidance on use of the emergency funding for students and institutions from the CARES Act: https://www.nasfaa.org/news-item/21646/ED_Releases_Further_Guidance_on_Use_of_CARES_Act_Emergency_Funding_for_Students_Institutions

April 9, 2020: NASFAA discussion on the Department of Ed’s briefing on emergency funding for students https://www.nasfaa.org/news-item/21501/ED_Provides_Details_on_Institutional_Allocation_for_6_Billion_in_Emergency_Funds_for_Students

Guidance addressing verification, needs analysis, and distance education: https://www.nasfaa.org/news-item/21445/ED_Releases_Updated_COVID-19_Guidance_A

March 20, 2020: Adjusting Direct Loan periods end dates if the terms are extended or shortened due to COVID-19: https://www.nasfaa.org/news-item/21273/Trending_AskRegs_Q_A_Are_We_Required_To_Adjust_Loan_Period_End_Dates_If_We_Extend_Our_Terms_Due_To_Coronavirus


The Career Education Colleges and Universities (CECU) has also put out a resource page: https://www.career.org/coronavirus.html

May 11, 2020: Template to assist in meeting the reporting requirements of HEERF funds: https://cecu.informz.net/cecu/data/images/Template%20for%20Higher%20Education%20Emergency%20Relief%20Fund%20Reporting.pdf

April 15, 2020: CECU’s Grant Guide for use of funds designated for students under the CARES Act, with an ongoing Q&A: https://www.career.org/grant-guide.html

April 9, 2020: CECU’s discussion on the Department of Ed’s briefing on emergency funding for students: https://www.career.org/uploads/7/8/1/1/78110552/4.10_gr_update_-_cecu_readout_of_the_u.s._department_of_education%E2%80%99s_briefing_on_covid-19_and_cares_act_2020-4-9.pdf


Cooley law firm discusses the CARES Act and how it relates to higher-education:

April 9, 2020: Guidance on issues related to implementation: https://ed.cooley.com/2020/04/09/managing-covid-19-disruption-ed-updates-and-consolidates-guidance/

  • Verification;
  • Leave of absences;
  • Audit submission;
  • Cash management;
  • Needs analysis;
  • Academic year reduction notice requirements;
  • Federal work study community service;
  • And more.

April 3, 2020: Institutional and student relief efforts: https://ed.cooley.com/2020/04/03/institutional-relief-under-the-cares-act

  • Approved leave of absence;
  • R2T4 and overpayments;
  • FSEOG and FWS under the CARES Act;
  • Student emergency aid;
  • And more.

National Association of College and University Business Officers (NACUBO) resources can be found here: https://www.nacubo.org/Topics/COVID-19

The NACUBO also had a telephone town hall on March 31, 2020. A recording can be listened to here: https://www.nacubo.org/-/media/Documents/Advocacy/2020/33120TelephoneTownHallWashingtonUpdate.ashx?la=en&hash=5D96A7AAEA00BF9A7F382A42301D8AACCEA4F760
Some of the topics discussed on this call were:

  • Efforts to postpone implementation of the new lease and revenue recognition standards, as well as all major new standards by a year. This is currently only being considered, and not in effect as of March 31, 2020;
  • Grants for Emergency Support for Educational Institutions;
  • Campus based aid considerations (SEOG, FWS, etc.);
  • Waiving of certain R2T4 requirements;
  • Aid that goes directly to students and what it includes;
  • Employer and tax issues that schools might face;
  • Small Business Administration loans (SBA), Paycheck Protection Program (PPP), and Economic Injury Disaster Loans (EIDL);
  • Payroll credits, and who is eligible;
  • Employer student loan repayment benefits;
  • Efforts made relating to Composite Score compliance requirements for fiscal year-ends 2020.

The American Council on Education has provided a resource page to assist schools: https://www.acenet.edu/pages/covid-19-information.aspx


Cornell Law School outlines what the legal requirements are for student eligibility which should be considered when determining how to allocate HEERF funds to students: https://www.law.cornell.edu/uscode/text/20/1091


Congress‘s CARES Act: https://www.congress.gov/bill/116th-congress/house-bill/748/text
Some highlights from the CARES Act above relating to your higher educational institution:

  • Sec 3501 Short Title;
  • Sec 3502 Definitions;
  • Sec 3503 Campus-Based Waivers;
  • Sec 3504 Use of Supplemental Educational Opportunity Grants (SEOG) for Emergency Aid;
  • Sec 3505 Federal Work-Study During a Qualifying Emergency;
  • Sec 3506 Adjustment of Subsidized Loan Usage Limits;
  • Sec 3507 Exclusion from Federal Pell Grant Duration Limit;
  • Sec 3508 Institutional Refunds and Federal Student Loan Flexibility;
  • Sec 3509 Satisfactory Academic Progress;
  • Sec 3510 Continuing Education at Affected Foreign Institutions;
  • Sec 3511 National Emergency Educational Waivers;
  • Sec 3512 HBCU Capital Financing;
  • Sec 3513 Temporary Relief for Federal Student Loan Borrowers;
  • Sec 3514 Provisions Related to the Corporation for National and Community Service;
  • Sec 3515 Workforce Response Activities;
  • Sec 3516 Technical Amendments;
  • Sec 3517 Waiver Authority and Reporting Requirement for Institutional Aid;
  • Sec 3518 Authorized Uses and Other Modifications for Grants;
  • Sec 3519 Service Obligations for Teachers.