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The HEERF lost revenue frequently ask question 5 states “An institution may only estimate lost revenue “associated with coronavirus” as specified by CRRSAA section 314(c)(1). Therefore, if the lost revenue is directly attributable to a cause other than the COVID-19 pandemic (e.g., lost housing revenue due to previously planned dormitory remodeling, previously planned elimination of a degree program, research grant income ending, one-time royalty payments), the institution may not include those lost revenues in its estimation of its lost revenue for the HEERF grant programs.”
Question 9 says, the CRRSAA does not specify how institutions may calculate their lost revenue. Accordingly, institutions have flexibility to reasonably calculate their estimated lost revenue. For example, an institution may use:
A year-over-year comparison using the prior year;
A semester-over-semester comparison using the prior year semester (fall 2019 compared to fall 2020 or summer term 2019 compared to summer term 2020);
A comparison using a 3- or 5-year combined average revenue as baseline revenue;
A comparison to previously budgeted revenue or projected revenue for the period; or
A comparison with a baseline year of a fiscal year prior to the March 13, 2020 national emergency declaration, such as the fiscal year from July 1, 2018 – June 30, 2019.
HEERF Roll-up FAQ question 43 institutions must provide documents demonstrating year-over-year decreases in revenue that are the result of a decline in enrollment, a decline in student fees including housing fees and meal plans, a decline in parking and facilities revenue, or a decline in revenue from summer programs or other activities disrupted by COVID-19.
2 CFR 200.305(b) states, “For non-Federal entities other than states, payments methods must minimize the time elapsing between the transfer of funds from the United States Treasury or the pass-through entity and the disbursement by the non-Federal entity whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means.”
Recipient acknowledges that no supplemental grant funds may be used to fund construction; acquisition of real property; contractors for the provision of pre-enrollment recruitment activities; marketing or recruitment; endowments; capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship; senior administrator or executive salaries, benefits, bonuses, contracts, incentives stock buybacks, shareholder dividends, capital distributions, or stock options; or any other cash or other benefit for a senior administrator or executive. (Emphasis Added)