New HEERF Closeout Guidance Released

In March, the U.S. Department of Education (DOE) hosted two webinar sessions for recipients of Higher Education Emergency Relief Fund (HEERF) awards. The sessions provided updates to HEERF guidance for 2023 and covered No Cost Extensions, HEERF Grant Award close-out and the Education Stabilization Fund (ESF) Improper Payment Study. To ensure compliance with the terms of their award, grant recipients should consider several items covered in the webinars.

No Cost Extensions

The HEERF award budget/ performance period ends June 30, 2023, and grantees are strongly encouraged to spend remaining emergency funds by this date. Grantees may request a one-time no-cost extension on the obligation of funds by submitting a written request to their assigned HEERF Program Specialist. Requests are required to include the following information:

• Name of institution
• PR Award number
• A detailed narrative that clearly explains the need for an extension
• Details on the remaining award balance and information on how the remaining funds will be spent
• A timeline for completing the project.

As HEERF funds were awarded to support those affected by the pandemic and economic downturn, an explanation of how the expenses connect to prepare, prevent, and respond to coronavirus must also be included in the request.

The written request should be submitted no later than June 20, 2023. The HEERF Program Specialists will email a confirmation upon receipt, review the request, and render a determination within 30 days.

HEERF Grant Awards Close-Out

Grantees that have expended all awarded funds should complete drawdowns for all allowable HEERF incurred expenditures and take the following steps to comply with closeout requirements:

• Confirm final record of HEERF expenditures with published quarterly reports posted online
• Submit the HEERF annual report for the last period of grant performance
• Comply with any HEERF Audits if notified
• Proactively respond to all requests from your Program Specialist or DOE affiliates
• Maintain all grant financial records and supporting documents pertinent to the HEERF grant award for a period of three years from the date of submission of the last quarterly or annual performance report

ESF Improper Payment Study

The Improper Payment Study will look to identify any improper or unknown payments by evaluating randomly selected payment data from a sample of 144 drawdowns from FY22. All HEERF grantees who were selected for the study should have provided the DOE with a list of payments associated with the selected drawdown. Using Simple Random Sampling (SRS), the DOE selected four payments from each drawdown for testing. Participating institutions were required to provide documentation for the selected payments by May 12^th, and the DOE will evaluate the support to determine if the payment is proper, improper, or unknown.

For information about HEERF grant compliance, contact us. We are here to help.

Authored by Afton Gillard, CPA.

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