Tax Tips Logo ImageISSUE:

On May 11, 2021, the U.S. Department of Education released a plethora of information about the “HEERF III” funding set forth in the American Rescue Plan Act of 2021 (ARP).  Beyond the allocation table (which includes some schools that were not allocated funds in HEERF I or II), there is guidance on reporting, student and institutional uses, and the new required uses of funds.  Also, it is clarified that HEERF funds may go to international and undocumented students.

 

SITUATION:

Saltwater Christian College (SCC) is a private college exempt under Internal Revenue Code section 501(c)(3) and 170(b)(1)(A)(ii).  They are required to file Form 990 annually.

The CFO at SCC called us wondering when the HEERF III funding and guidance was expected to be released by ED.

“It was released last week,” we answered.

“Great.  Can you send us links?”

“Here they are…”

HEERF III Allocation table   arpa1a2allocationtable.xlsx (ed.gov)

HEERF III FAQs        arpfaq.pdf (ed.gov)

“The quarterly reporting requirements for HEERF III mirror those for HEERF I and II with the student funding “webpage” and the institutional funding “grid.”  Take a look at FAQ #52 which gives a summary of all the guidance that applies to HEERF III.  Disturbingly, they continue to narrow the use of funds for religious purposes (“worship, instruction, proselytization”) are “unallowable” (FAQ #22) .  More on this to follow.”

RULES:                                                                        .

From “HEERF III FAQs”, Question #36:

  1. Question: What are the quarterly reporting requirements for HEERF III grants?

Answer: HEERF grantees receiving ARP funds must continue to adhere to the two quarterly reporting requirements originally implemented through the CARES Act for HEERF I funding.  Those reporting requirements include the following:

  • Quarterly Institutional Public Reporting Form for (a)(1) Institutional Portion, (a)(2), and (a)(3) Funds. This form must be conspicuously posted on the institutions’ website no later than 10 days after the calendar quarter (July 10, October 10, January 10, April 10).
  • Quarterly Student Public Reporting Requirement for (a)(1) Student Aid Portion and the CRRSAA (a)(4) and ARP (a)(4) program. The responses to these questions must be conspicuously posted on the institutions’ website no later than 10 days after the calendar quarter (July 10, October 10, January 10, April 10).

Additional considerations and requirements:

  • Each report is separate for the calendar quarter reporting period and not cumulative.
  • Institutions that expended HEERF grant funds during the calendar quarter from January 1 – March 30 are required to post the two quarterly reports that involved the expenditure of HEERF II CRRSAA and HEERF I CARES Act funds.
  • For the July 10, 2021 quarterly reporting deadline, institutions are encouraged to also submit their two quarterly reports (institutional and student) to the Department by emailing those reports as PDF attachments to HEERFreporting@ed.gov. More information regarding quarterly reporting is available on our HEERF III ARP website ARP: American Rescue Plan (HEERF III) (ed.gov)

 

BOTTOM LINE:

  • HEERF III grant allocations and FAQs were released last week.
  • Generally, HEERF III grants require at least 50% to go to students as a “Minimum Amount for Student Aid Portion.”
  • HEERF III funds may go to all students – including international and undocumented students (FAQ #8).
  • FAQ #52 provides a great summary (with links) of the guidance that applies the HEERF III.

 

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