HEERF Funding Tips and Tricks

Michael Cosgrove CPA

Michael Cosgrove, CPA, MST

7 April 2021

A simple google search will reveal the level of funding to each institution. Presidents, Board members and the general public have all this information at their fingertips. What can you do, as an institution, to ensure compliance along the road with HEERF funding?

The first step along the long road of HEERF funding is to ensure that you’re properly communicating to key stakeholders the key aspects. Many stakeholders may misunderstand the process and believe that the funding that is allocated to the institution is now cash in the bank and available for general expenditures. It is critical that all stakeholders understand the process and that while the funds have been allocated to institutions, the institution itself still needs to ensure compliance and then draw down the funds accordingly.  They were not deposited in a similar manner to the individual stimulus checks. All key stakeholders need to understand that difference.

A key to any grant funding is documenting the rationale for grant eligibility of expenses at, or near, the time of expenditure. This provides the institution an opportunity to ensure compliance at the onset of the expenditures. This would also help reduce any possible reporting issues that may arise, should expenses be changed over time to different expenses that would be classified differently in any quarterly or annual reporting. It is important to get input and work with your auditors during the fiscal year as the expenditures are occurring. Management is responsible for ensuring compliance, but since the auditors will be testing compliance, then it would behoove everyone within the process to be as informed as possible and as early as possible. Another significant resource during this time period is your peers. The colleagues at similar schools who you know through your personal network can truly be resources. You have the ability to discuss very specific expenditures and their thoughts or opinions on them. You will be able to bounce ideas off of one another, which will help each of you develop new ideas and thoughts as to eligible ways to spend the funding.

Lastly, as the rules and regulations continue to evolve over time, it is critical now, more than ever, to review, revise and stay current. Every institution should be reviewing the expenses that were deemed and documented as eligible, at a minimum, when they begin to prepare the quarterly reports. It would be great if it were done monthly, but that may not be reasonable, but when the quarterly reports are being prepared, then a review of expense eligibility must be completed. If necessary, revise the expenditures during this process if new information has come to light and expenses would no longer be deemed eligible. Again, as rules are constantly evolving, staying current is absolutely vital. There are many free webinars that are offered as well as some other sources, and all that information should be reviewed to help determine what is applicable to your institution. As always, it’s important to know the source of the information, so that you know what is authoritative versus an interpretation from a non-authoritative source.

All the items discussed here are important for any grant, but given the circumstances and current environment, they are more important than ever. As mentioned, this information is even more readily available than typical grants, so it’s critical that each institution take the necessary steps to ensure compliance.


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