Tax Tips Logo ImageISSUE:

The Department of Education has begun to provide guidelines on Higher Education Emergency Relief Fund (“HEERF” – CARES Act Section 18004) Annual Reporting – which differs from the quarterly reporting that is currently ongoing.

 

 

 

SITUATION:

Denali Christian College (DCC) 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.

DCC received allocations under CARES Act Section 18004(a)(1) – Student and Institutional portions and Section 18004(a)(3).  Their CFO called us to clarify an ED “edict” that all schools required to participate in the upcoming HEERF annual reporting send ED an email with the names of their appointed “Submitter” and “Editor(s)” by Friday, December 4, 2020.

“What are the definitions of a ‘submitter’ and an ‘editor’ that we have to report by this Friday?” She asks.

“Well,” we say, “it is interesting and – like much of what we’ve seen in 2020 – details are kind of sketchy.  From the limited information provided by ED, it appears that a ‘submitter’ is the one official at your institution who will have the authority to submit – or “hit the button” under their login – to file the report on behalf of the institution.  It appears that this portal will be available beginning in early January 2021.  The role of ‘editor’ – of which you can appoint two people – can fill out the data collection form through the ED portal, but not ‘submit’ it.  The Submitter will have Editor privileges, that is, Submitters may also answer questions in the data collection form.  Hope that helps.”

 

RULES:                                                                        .

From ED Emails to HEERF Awardees:

Annual Report Data Collection System:

We plan to open the Annual Report Data Collection System the first week of January 2021. The first annual report covering all grant expenditures and activities for the period March 13, 2020 to December 31, 2020 will be due no later than February 1, 2021 when the system will close.

There are two roles in the Annual Report Data Collection System: Submitter and Editor. The Submitter is the one grant official who will have the authority to submit the report on behalf of the grant. The Editor is a user who can answer the questions in the data collection form, but who will not have Submitter authority. The Submitter will have Editor privileges, that is, Submitters may also answer questions in the data collection form.

We need you to tell us who will be the Submitter and who will be the Editor(s) for your HEERF grant by COB December 4, 2020.

Please send the names and email addresses for your Submitter and Editor(s) in the following format to heerfannual@ed.gov.

Submitter: {First Name Last Name} {Email address}

Editor1: {First Name Last Name} {Email address}

Editor2 (if needed): {First Name Last Name} {Email address}

These officials will receive an email in December with their login information for the Annual Report Data Collection System

 

BOTTOM LINE:

  • The Department of Education has already required “website reporting” for the Section 18004(a)(1) Student Portion of HEERF amounts expended.
  • Quarterly reporting (which was due to be posted for March 13, 2020 – September 30, 2020 on the same webpage as the “Student Portion” reporting by October 31, 2020) will next be required by January 10, 2021 for the quarter ended December 31, 2020.
  • Annual HEERF reporting on a new form – using a yet-to-be-active portal – will be in a different format.  The draft form can be found at:  Regulations.gov – Supporting & Related Material Document
  • HEERF recipients that are subject to annual reporting requirements must provide – via email – their appointed “Submitter” and one or two “Editors” by Friday, December 4, 2020.

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