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3. HEERF: Historically Black Colleges and Universities (HBCU)

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.”

Supplemental Grant Funds for Institutions Agreement – Page 2

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)

Governor's Emergency Education Relief (GEER) Fund