Hot Topic | May 2020



NFP higher education institutions’ CARES Act accounting

Implications of the CARES Act on the accounting of not-for-profit higher education institutions.

Lisa Hinkson

Lisa Hinkson

Partner, Dept. of Professional Practice, KPMG US

+1 212-954-6399

Kayla Futch

Kayla Futch

Managing Director, Dept. of Professional Practice, KPMG US

+1 212-954-6455

Amanda Nelson

Amanda Nelson

Partner, Dept. of Professional Practice, KPMG US

+1 202-533-5560

Approximately $14 billion of relief is available to higher education institutions under the CARES Act through the Higher Education Emergency Relief Fund (HEERF). KPMG addresses the accounting for this aid.


  • All not-for-profit, non-governmental higher education institutions 

Relevant dates

  • CARES Act was signed into law on March 27, 2020
  • $12.56 billion of general HEERF grants were made available to institutions in two parts: student aid on April 9, 2020, and institutional costs on April 21, 2020
  • $1.4 billion of HEERF aid reserved exclusively for minority-serving institutions, other institutions eligible for the Strengthening Institutions Program and certain institutions with unmet needs was made available on April 30, 2020

Key impacts

  • NFP higher education institutions will account for HEERF grants as conditional contributions under ASC 958-605.

Report contents

  • Background
  • Key provisions of the Higher Education Emergency Relief Fund
  • Accounting considerations
  • Internal processes and controls considerations

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