COVID-19 and Higher Education: FAQs Related to Title IV Aid and Compliance

This article was updated on August 4, 2020.

On March 5, 2020, the US Department of Education (ED) published an electronic announcement responding to higher education leaders’ concerns about complying with Higher Education Act (HEA) Title IV policies if their students’ activities are impacted by the COVID-19 pandemic.

On March 20, 2020, ED updated this announcement and published further guidance in the form of frequently asked questions (FAQs) on the Information for Financial Aid Professionals (IFAP) website. The FAQs concern students who are either directly impacted by COVID-19 because they’re ill or quarantined, or indirectly impacted because they:

  • Were recalled from travel-abroad experiences
  • Aren’t able participate in internships or clinical rotations
  • Can’t attend a campus due to temporarily suspended operations

ED posted further guidance in an April 3, 2020, electronic announcement that expands upon the March 5 guidance and provides additional regulatory flexibilities due to President Trump’s March 13 declaration of the COVID-19 national emergency.

On May 15, 2020, ED issued updated guidance that provides information that expands on ED’s March 5, 2020, and April 3, 2020 guidance.

On June 16, 2020, ED updated its March 5, 2020 announcement again and expanded flexibilities for standard term programs and extending the timeframe for those flexibilities.

We encourage you to read the electronic announcements released on March 5, 2020, April 3, 2020, May 15, 2020, and June 16, 2020 for more detailed guidance.

Below is an overview of key FAQs and the ED’s responses to help your higher education institution better comply with Title IV guidance throughout the COVID-19 pandemic.

Enrollment and Federal Work Study

As an emergency measure to accommodate students, ED provided broad approval for institutions to use distance learning as a way of providing instruction services without going through the standard ED approval process. How long can institutions continue to offer distance learning courses without ED’s approval?

At this time, the flexibility is only for payment periods that either:

  • Overlap with ED’s March 5, 2020, guidance
  • Begin on or between March 5 and December 31, 2020, or the end for the COVID-19 Federally declared emergency, whichever occurs later

Institutions with programs in which at least 50% of the program is offered through distance learning typically must be accredited by an agency that has distance education in the scope of its recognition by the Secretary of Education. ED is waiving this requirement under the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act for payment periods that begin on or before December 31, 2020, or the end for the COVID-19 Federally declared emergency, whichever occurs later.

ED’s guidance indicates that Title IV relief doesn’t apply to students who weren’t enrolled in an institution, or whose term hadn’t yet begun, as of March 5, 2020. If an institution is switching from on-campus operations to an online format for a term that begins in May, does this guidance apply?

The original guidance limited relief to students who were already enrolled when COVID-19-related interruptions occurred. Given advice from the Centers of Disease Control and Prevention (CDC) about the time period during which social distancing may be required, ED states it would be prudent to extend this flexibility to students who are enrolled in payment periods or have terms beginning between March 5, 2020, and June 1, 2020, inclusive. That said, it’s important to continue monitoring these guidelines because the timeframe could be extended.

If an institution isn’t closed, but it has moved classes to a distance education format, can it pay Federal Work Study (FWS) wages to students who aren’t able to work because they’ve been impacted by COVID-19?

Yes. According to ED’s electronic announcement, FWS guidance applies when a student is unable to work because the school has closed or moved to online or distance education. However, the institution must meet the following conditions:

If an FWS student is unable to work [their] scheduled hours because of COVID-19 disruptions (school closures, employer closures, student quarantined, etc.), the school may pay the student for any scheduled hours or allow the student to work by another means (online, remote, telecommute, etc.). Students should be paid the wage rate that they would have been paid if they were able to work the scheduled hours.

When a school pays a student for scheduled—but unfulfilled—work hours, the school isn’t required to submit any documentation to ED. However, the school must document the number of scheduled hours a student should be paid prior to paying the student.

Schools should also document in the student’s file any actions that were taken regarding payment of FWS funds for scheduled hours when the student didn’t work.

ED’s electronic announcement indicates that an institution can pay FWS funds to students who are unable to work as a result of the COVID-19 outbreak if it continues to pay its other employees, including faculty and staff. Can an institution still pay its FWS students if the following points are true?

  • The institution has student workers who don’t receive FWS funds and won’t work as a result of the outbreak.

  • The institution has other employees who won’t be paid during the COVID-19 pandemic even though its faculty continue to teach classes.

Yes, an institution can still pay its FWS students if the above two points are true as long as the institution continues to:

  • Pay its essential faculty and staff
  • Meet its institutional wage-share requirement for the FWS program

The institution isn’t required to continue paying all employees who began working prior to the outbreak if it has discontinued some operations as a result of COVID-19.

Wage-Share Requirements

Institutions that have received a waiver of the institutional wage-share requirements under 34 Code of Federal Regulations (CFR) 675.26(d) continue to be exempt from the wage-share requirements, according to ED’s electronic announcement.

Study Abroad Programs

When COVID-19 began, some students were studying abroad at foreign institutions through consortium agreements. Many of these institutions suspended their on-campus classes and transitioned to a distance education format. Some students wish to continue coursework offered by the home institution, and others want to stay enrolled in the foreign institution’s online coursework. Can these students continue to receive Title IV aid?

Yes. Students who are attending a foreign institution as part of a study abroad program are allowed to take online classes from the host foreign school or their home US institution.

There aren’t any prohibitions on utilizing distance education to teach a US student who’s enrolled at a US institution but participating in a study abroad program at a foreign school if the foreign school is either part of a consortium or has a written agreement with the student’s US institution. In these cases, either the home or host school may offer courses via distance learning.

Statutory Prohibition

Statutory prohibition on the use of distance education applies only to eligible foreign schools that enroll US students who intend to earn a degree or certificate from that foreign school and are receiving Title IV assistance.

Class Suspensions and Break Extensions

If we refund a portion of our students’ room and board costs, tuition, or other fees due to the COVID-19 pandemic, do we need to adjust students’ Title IV budgets? Do we also need to consider the cost differences for students who must relocate to off-campus housing?

Your institution isn’t required to make changes to a student’s Title IV awards based on any of the above changes.

ED won’t require a reevaluation of students’ costs of attendance if your institution provides a refund or waiver of expenses for all or part of a student’s:

  • Tuition
  • Fees
  • Room and board charges
  • Other institutional charges

The same principle applies if a student has moved off campus for the remainder of the term.

What’s the impact on Return of Title IV (R2T4) calculations if students withdraw during a COVID-19-related break extension or class suspension? Are institutions required to revise calculations for students who withdrew prior to the outbreak?

When determining R2T4 calculations, institutions should treat days when classes were suspended for COVID-19 as part of a scheduled break. However, the following timing stipulations apply.

Timing Stipulations

If your institution extended its scheduled break and the extension and the originally-scheduled break equals five days or more, your institution should exclude the extension days from any R2T4 calculations performed after the schedule change.

Similarly, if an institution suspends classes for at least five consecutive days, those days must also be excluded from R2T4 calculations for students who withdrew after the schedule change occurred.

Payment and Enrollment Periods

To determine the number of days in a student’s payment period or period of enrollment, an institution should reference the total number of days the student was scheduled to attend at the time when they withdrew.

If the length of the student’s payment period changes—due to extended breaks or extended payment periods—the institution should determine the number of days in the period for R2T4 purposes by referencing the number of days in the revised payment period after the schedule change occurred.

Pre-revision Withdrawals

Institutions don’t need to perform revised R2T4 calculations for any students who withdrew before the change to the schedule.

Student Withdrawals for Qualifying Emergencies

An institution isn’t required to issue a R2T4 for any student who begins attendance in a payment period or period of enrollment that includes March 13, 2020, or begins between March 13 and the later of December 31 or the last date the national emergency is in effect, and withdraws from the period due to a qualifying emergency related to COVID-19.

Institutions are required to report to ED information specific to each student that was waived from returning Title IV funds. The following are the reporting requirements under the CARES Act:

  • Identifying information for each student for whom R2T4 was waived under the CARES Act
  • The payment period begin and end dates for the period that each student didn’t complete as a result of the COVID-19 emergency
  • The amount of Title IV grant or loan assistance, other than Federal Work Study funds, that each such student received for the payment period in which he or she withdrew
  • The total amount of Title IV grant or loan assistance that each institution hasn’t returned to the Secretary as a result of the CARES Act provisions

The CARES Act also directs the Secretary of Education to waive student grant overpayments that result from the R2T4 process for a student who withdraws as a result of COVID-19 circumstances. If the grant overpayment has been waived in accordance with the CARES Act, the institution isn’t required to notify the student or National Student Loan Data System of the overpayment or refer to any of the overpayment to ED. However, documentation of the waiver must be maintained in the student’s file.

Many of our students have loan periods that end at the conclusion of spring term, but our institution has extended spring term by several weeks due to the COVID-19 outbreak. Does this mean we need to extend our loan period in the Common Origination and Disbursement (COD) system?

No. If a loan period is scheduled to end on the term end date, institutions that extend terms beginning on or before June 1, 2020, due to COVID-19 aren’t required to change loan-period end dates in the COD.

Clock-Hour Programs

Many of our students attend clinicals through our clock-hour program, but the hospital has stopped all externships due to the COVID-19 outbreak. Are we required to withdraw these students until we can find a new clinical location for them?

Normally, institutions aren’t allowed to put students on a leave of absence while coursework, including clinicals, internships, or externships, is suspended.

However, if a student’s coursework is cancelled as a result of COVID-19 and the student is enrolled in a clock-hour program, ED will allow the institution to put the student on an approved leave of absence until the institution can either resume coursework or find another placement for the student. This will prevent the institution from withdrawing the student and performing an R2T4 calculation that will later need to be reversed.


This guidance only applies if there’s a reasonable expectation that the institution will be able resume coursework or find a placement for the student. If the institution can’t resume coursework or find a placement for a student within 180 days, or if the student’s number of approved leaves of absence in a calendar period exceeds 180 days, the student must be considered withdrawn and an R2T4 calculation performed.

Our institution is considering moving its clock-hour program to an online format in response to the COVID-19 outbreak. Is there any guidance you can provide us?

Institutions that offer clock-hour programs in a distance education format must be able to verify that each clock hour is supervised by qualified institutional personnel. Generally, real-time virtual instruction that allows students to actively engage with, and be supervised by, an instructor can be an effective learning environment.

If an institution offers virtual clock-hour programs that aren’t in real-time, the instructor must be able to:

  • Continuously monitor each student’s activity through an online platform
  • Verify each student’s engagement for least 50 minutes of each clock hour
  • Complete a student’s timesheet to reflect clock hours earned

Institutions should also make sure that any clock hour offered through distance education meets all state- and accrediting-agency requirements and fulfills applicable educational prerequisites for state licensure.

Nonstandard-Term Schedules

ED’s electronic announcement indicates that institutions can offer courses on a nonstandard-term schedule while continuing to offer Title IV aid using a standard-term academic calendar. Can nonstandard-term courses overlap with an institution’s summer-term courses without causing programs to be treated as non-term programs?

Yes. ED is extending flexibility to schedules that would otherwise be considered nonstandard-term programs, so these courses can overlap without consequences.

For example, if an institution extends the length of its spring term in response to COVID-19 disruptions, causing its spring term to overlap with its summer term, the institution may continue to consider its terms to be standard terms, allowing both to be considered part of the scheduled academic year for Direct Loan funds and Pell Grant Formula 1 purposes.

Some students were recalled from travel abroad programs or experiential learning opportunities after the semester began. Can our institution offer courses to those students on a nonstandard term or nonterm program?

Yes. ED is allowing institutions to offer courses to students on a nonstandard term or nonterm program, if doing so enables those students to complete the term.

Distribution Errors

If an institution makes technical errors when administering Title IV aid, will the institution still be considered fully compliant if the errors were to the benefit of their students and due to providing COVID-19 response and support?

Even in the case of COVID-19 disruption, an institution must appropriately return any Title IV funds for which it’s responsible in accordance with the provisions of 34 CFR Section 668.22.

As of this writing, ED doesn’t have the authority to waive the statutory requirement for the return of unearned Title IV funds if a student who receives Title IV assistance withdraws from an institution during a payment period or period of enrollment after having begun attendance.

Financial Statement Audit and Compliance Audit

The Secretary of Education has extended the financial statement and compliance audit deadlines by six months.

We’re Here to Help

To learn more about how your institution can best interpret and apply ED’s recent electronic announcements and FAQs or other COVID-19-related guidance, contact your Moss Adams professional.

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