Higher Education Emergency Relief Funds reporting requirements

Thompson Coburn LLP

Scott Goldschmidt & Aaron Lacey

December 29, 2020

Funding and Certification Agreement reporting requirements

Institutions that accepted HEERF funds completed two Funding and Certification Agreements – one for Emergency Financial Aid Grants to Students (the “Student Portion”) and another for the Institutional Portion of HEERF funds. The Funding and Certification Agreements direct Institutions to:

• Comply with Quarterly and Annual Reporting Requirements (discussed in more detail below);

• Document that the Institution has continued payment of employees and contractors during the period of any disruptions or closures to the greatest extent practicable, in compliance with Section 18006 of the CARES Act;

• Cooperate with any examination of records with respect to the funds by making records and authorized individuals available when requested; and

• For grant costs, maintain adequate documentation as required by 2 CFR § 200.333 and 2 CFR § 200.403(g) to support the reasonableness of these costs, consistent with the cost principles in 2 CFR part 200 subpart E of the Uniform Guidance. (Higher Education Emergency Relief Fund (HEERF) Round 3 Frequently Asked Questions, Q.1).

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