The Council on Governmental Relations (COGR), representing 190 major U.S. research universities and affiliated entities, submitted detailed comments to the U.S. Department of Education regarding the proposed data collection form for the Higher Education Emergency Relief Fund (HEERF) I, II, and III. COGR expressed appreciation for the Department’s commitment but raised substantive concerns regarding the practicality and administrative burden of the new data requirements, particularly in areas such as lost revenue documentation and student demographic data collection. COGR highlighted that the requirement to assign lost revenue to specific expenditure categories is inconsistent with standard accounting practices and previously issued guidance, and that retroactive collection of expanded demographic data is often unfeasible due to data limitations and privacy practices at institutions.
Furthermore, COGR questioned the Department’s estimates of the administrative burden, suggesting that actual time commitments are underestimated and emphasizing that after-the-fact modifications to data requirements impose significant challenges on institutions. The association recommended the deletion or revision of administratively onerous data elements, a more collaborative approach to form development and public data presentation, consideration of funding mechanisms to offset compliance costs, and user feedback mechanisms to improve the data collection portal. Throughout, COGR advocated for ongoing partnership and transparency between the Department and higher education institutions to ensure both regulatory compliance and the effective stewardship of federal funds.
