Tax Tips Logo ImageISSUE:

Some institutions received funding through the Department of Education under the “HEERF” program (CARES Act Section 18004(a).  Now, ED has released reporting requirements regarding all four types of these funds.


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’s CFO called us to ask about HEERF reporting.  “We posted the required information for the Student Portion on our website within 30 days.  What other forms or whatever are required – and when?”

“Well,” we say, “after about six months of back and forth, the Department of Education released reporting requirements on September 28, 2020.  These rules were implemented immediately.  Ultimately, HEERF funds come in four “flavors.”  CARES Act Section 18004(a)(1) has a “Student portion” and an “Institutional portion.”  Then, there are funds under Section 18004(a)(2) and Section 18004(a)(3).

“There are important stipulations and certifications required by each of these four sections.  Schools should be careful to understand the spending rules and diligently follow them.  For the new reporting requirements, the Section 18004(a)(1) Student portion has already been defined and all schools receiving these funds should have publicly posted required information on their primary website.  For the “Student portion,” subsequent reports are due quarterly (posted on your primary website).

“For the other three ‘flavors,’ there are new reporting requirements that must be posted on your primary website – in the same place as the Student portion public reporting – by October 30, 2020.  The reportable items are not yet finalized, but, for an idea, please see the draft form at:

“Institutions are required to provide their first quarterly reports by October 30 for the period between the date of their first HEERF award and September 30; subsequent reports are then due quarterly and must be posted no later than 10 days after each quarter-ending date (due: January 10, April 10, July 10, October 10)..”

“And, finally, there are annual reporting requirements for all four types of funding (most schools did not receive all four).  This will entail an annual report submitted to the Department of Education via a portal system that is currently in development.  It is intended that the first annual reports will be due in ‘early 2021.’  Hope that helps.”

RULES:                                                                        .

From ED, Office of Postsecondary Education webpage “Reporting and Data Collection”:

This table describes the three different reporting requirements for HEERF grant programs. Two requirements are for public posting of information on institutions’ websites, one is an annual report that will be submitted to the Department in early 2021. It describes who reports, the method of reporting, the frequency of reporting, the substance of reporting, and what to do if grantees have expended all their HEERF funds. This information is generally described in the links to the documents posted above the table.  (See table at:



  • Many institutions did not receive HEERF allocations from the CARES Act.
  • For those institutions who did, ED has not been very consistent with their guidance on required HEERF reporting.
  • The reporting requirements released on September 28, 2020 are still incomplete with respect to Section 18004(a)(1) – Institutional portion, Section 18004(a)(2), and Section 18004(a)(3) – but the required reporting dates are certain.
  • For more – and continuing “coverage” – check out our Coronavirus Resources webpage at:

Specific questions? Email Dave Moja

The information provided herein presents general information and should not be relied on as accounting, tax, or legal advice when analyzing and resolving a specific tax issue. If you have specific questions regarding a particular fact situation, please consult with competent accounting, tax, and/or legal counsel about the facts and laws that apply.

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