The Council on Governmental Relations (COGR), representing 190 U.S. research universities and affiliated institutions, submitted formal comments to the U.S. Department of Education regarding the revised Higher Education Emergency Relief Fund (HEERF) I, II, and III Data Collection Form. COGR acknowledged improvements in the revised form, specifically the Department’s willingness to address prior concerns about lost revenue documentation, opting for broad functional estimates over detailed financial categories. However, COGR expressed significant reservations regarding expanded requests for student demographic data, emphasizing the impracticality and administrative burden of retroactively collecting data that was not initially required and is often optional or incomplete. The organization recommended that the Department clarify permissible use of generalized data fields, especially for students not categorized in national databases like IPEDS, and, where appropriate, remove or modify data requests that are unduly burdensome or potentially impossible to fulfill.
Further, COGR raised concerns about new instructions warning of adverse actions for reporting noncompliance, suggesting such language could have an unintended chilling effect and should be omitted. While the Department’s revision to allow deferred reporting for certain challenging data fields is acknowledged as helpful, COGR continued to question whether these additional data points are statutorily necessary and recommended simplifying the report to reduce unnecessary burden. The revised estimate of 40 hours for report completion is considered more accurate, yet COGR reiterated concerns over the overall administrative impact and the risk of imposing an unfunded mandate. The letter encourages ongoing collaboration between the Department and higher education institutions to ensure data collected and presented meets stakeholder needs without excessive administrative costs, ultimately supporting transparency and effective stewardship of federal resources.
