[Cobo] FW: Clarification on HEERF Reporting Requirements

Fri May 14 12:08:10 CDT 2021

Please see this information shared with your Presidents this morning.

From: Johnson, Dr. Glen
Sent: Friday, May 14, 2021 12:07 PM
To: Presidents <pres at osrhe.edu>
Cc: Alyssa Cravens <acravens at rsu.edu>; Amy Caskey <acaskey at mscok.edu>; Amy Cobb <amy.cobb at wosc.edu>; Brandi Schur <bschur at ecok.edu>; Brenda Weber <bweber at cameron.edu>; Calandra Rose <crose at opsu.edu>; Candace Raney <craney at eosc.edu>; Carrie Bateson <carrie.bateson at tulsacc.edu>; Cortney Smith <clsmith at carlalbert.edu>; Derotha Rivenbark <derotha.rivenbark at connorsstate.edu>; Elaine Preston <ecpreston at langston.edu>; Kendra Cummins <Kendra.cummins at neo.edu>; Hull, Kenzi <hullk at redlandscc.edu>; Velleca, Kim <kvelleca at occc.edu>; Mechell Downey <m.downey at sscok.edu>; Melissa Meredith <melissa.meridith at okstate.edu>; Nutter, Michelle <mnutter at rose.edu>; Misty Zink <misty.zink at swosu.edu>; Myra Davison <MEDavison at nwosu.edu>; Northern Oklahoma College (Denise.Bay at noc.edu) <Denise.Bay at noc.edu>; Robin Hutchins <HUTCHINR at nsuok.edu>; Tamra Cossey <tcossey1 at uco.edu>; Taylor Austin <tjaustin at ou.edu>; Terri Rogers <trogers at se.edu>; McNabb, Vanessa <vmcnabb at usao.edu>
Subject: Clarification on HEERF Reporting Requirements

OKLAHOMA STATE REGENTS FOR HIGHER EDUCATION

Memo

To:                  Presidents
From:             Chancellor Glen D. Johnson
Date:               Friday, May 14, 2021
Subject:          Clarification on HEERF Reporting Requirements

Following up on my memo from Tuesday, May 11, 2021, regarding Higher Education Emergency Relief Fund requirements under the American Rescue Plan, I want to let you know that the U.S. Department of Education (USDE) has confirmed that higher education institutions will be required to post Quarterly Institutional Public Reporting Form and the Quarterly Student Public Reporting Form for both HEERF II - Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) and HEERF III - American Rescue Plan (ARP) funds to their websites by the tenth day following the end of each calendar quarter (July 10th, October 10th, January 10th, April 10th), as was the requirement for HEERF I funds. A copy of the "Notice of Public Posting Requirement of Grant Information for Higher Education Emergency Relief Fund (HEERF) Grantees" has been attached for your review (Attachment 1).

Because the USDE never established HEERF II reporting requirements, it has extended the deadline by which institutions must submit retroactive reports for HEERF II for the first quarter of 2021 (January - March) to the end of the second calendar quarter, which is June 30, 2021.

The required quarterly public reporting forms for HEERF II and HEERF III grants can be accessed online at: https://www2.ed.gov/about/offices/list/ope/heerfreporting.html.

Additionally, HEERF II and HEERF III funds are also subject to the annual reporting requirement, which is next due in early 2022. While the USDE will provide more information regarding the annual report in advance of the annual reporting deadline, preliminary guidance indicates that annual reporting requirements may require institutions to report:

  *   How they prioritize students with exceptional need in distributing emergency financial aid grants to students;
  *   Practices used to monitor and suppress COVID-19; and
  *   Outreach to financial aid applicants about the opportunity to receive a financial aid adjustment due to the recent unemployment of a family member or independent student or other circumstances.

Specifically, the recently released Frequently Asked Questions document prepared by the USDE (Attachment 2) notes that institutions should carefully document "(1) the strategies used to monitor and suppress COVID-19, (2) the evidence to support those strategies, (3) how those strategies were in accordance with public health guidelines, (4) the manner and extent of the direct outreach the institution conducted to financial aid applicants, and (5) how the amount of the HEERF grant spent on these two required activities was reasonable and necessary given the unique needs and circumstances of the institution" (page 20).

We will keep you advised regarding HEERF reporting requirements.

Thanks.

Glen

Glen D. Johnson

Chancellor

Oklahoma State Regents for Higher Education

655 Research Parkway, Suite 200

Oklahoma City, Oklahoma 73104

405.225.9122

gjohnson at osrhe.edu<mailto:gjohnson at osrhe.edu>

follow us on Twitter @okhighered

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