March 18, 2020 - Executive Briefing: Guidance on Federal Student Aid During Pandemic
As colleges and universities around the country wrestle with decisions about how best to protect their communities from the new coronavirus (COVID-19), one concern is to avoid running afoul of federal student aid rules concerning withdrawals, method of instruction, length of terms, and more. Another is ensuring that care is taken to treat students as fairly as possible and avoid leaving them without the support that they need.
On March 5, the Department of Education (ED) issued guidance to institutions on interruptions of study due to COVID-19 that provides welcome flexibility to schools in several areas.
- Switch to Distance Education. Institutions may temporarily move to online instruction or other technology supported
instruction for the current term or the following one without seeking approval from
ED. Accrediting agencies are also being permitted to waive their distance education
review requirements for programs developed to serve current students whose attendance
is interrupted by COVID-19.
ED cautions institutions that, under its rules, instructors utilizing distance education technology must initiate substantive communication with students on a regular basis. Complicated technology is not required; email, chats, conference calls, and other easily accessible tools can be used effectively.
- Consortiums. Institutions may enter into temporary consortium agreements in order to enable students to complete courses at other schools but be awarded credit at their home institution. Accrediting agencies are permitted to waive related residence requirements for affected students.
- Leaves of Absence. ED is easing rules on leaves of absence for aided students, allowing a leave of absence for COVID-19 related reasons to be approved even if the student notifies the institution after the fact. This will be helpful for students whose planned study-abroad program was cancelled or had to stop out due to illness or quarantine, for instance. If a student takes a leave of absence from a term-based program, they must be permitted to complete the coursework that was interrupted when they return. If the student does not return within 180 days, the school must calculate a return of Title IV funds.
- Nonstandard Terms and Shortened Year. ED is giving colleges the flexibility to provide alternative courses to students whose study-abroad or experiential learning programs were curtailed, or if the institution, other locations, or programs need to temporarily close due to COVID-19, even if the class schedule would not fit into the school's defined academic term. An institution must, however, request approval from ED for a temporary reduction in the length of its academic year if necessary due to emergency closure.
- Federal Work Study (FWS). Students who rely on FWS wages as an important component of their aid package will be financially stressed if they can't work when their institution or other employer closes temporarily. Under its authority to provide relief to disaster-affected students, ED is allowing institutions to continue paying FWS wages to students during a closure that began after the beginning of the term, if the institution (1) is continuing to pay its other employees (including faculty and staff), and (2) continues to pay its institutional share of wages.
For several other regulatory compliance issues, ED does not have authority to waive existing requirements but provided guidance to institutions on how to comply under these circumstances. These include:
- using professional judgment to adjust federal aid to reflect special circumstances on a case-by-case basis;
- allowing circumstances related to the COVID-19 outbreak as a basis for satisfactory academic progress reviews;
- returning federal aid to the respective federal aid program(s) for students who did not begin attendance;
- confirming changes to student enrollment status (full-time, at least half-time) on aid;
- calculating return of Title IV funds if the school closes during the payment period and fails to reopen by the end of the period, or if the school reopens before the end of the period but some students fail to return; and,
- reporting enrollment to the National Student Loan Data System (NSLDS).
ED has established a page on its website to provide information to educational institutions which currently includes this guidance and a document from the Centers for Disease Control specific to higher education. More information will likely be added.
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