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COVID-19 andFederal Student Aid:

As It StandsJune 12, 2020

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June 2020

NASFAA’s WebinarCOVID-19 and Federal Student Aid:

As It StandsPresented June 12, 2020

© 2020 NASFAA 1 COVID-19 & Federal Student Aid Webinar 6/12/2020

National Association of Student Financial Aid Administrators

COVID-19 and Federal Student Aid: As It Stands

June 12, 2020

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Webinar Housekeeping – Welcome!

• Turn your computer speaker volume up • For technical assistance:

Ø Review the Tech TipsØ Contact us using the Q&A Ø Email [email protected]

• Print your certificate of attendance• Complete the survey

Slide 2 © 2020 NASFAA

2

Speakers

• Justin DraegerØ President & CEO, NASFAA

• Karen McCarthyØ Director of Policy Analysis, NASFAA

• Jill DesjeanØ Policy Analyst, NASFAA

• David FutrellØ Knowledgebase & AskRegs Manager, NASFAA


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http://nasfaa.org




Agenda

• Housekeeping• NASFAA & COVID-19• Scenarios & Hot Topics• ED Timeline• Q&A


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NASFAA & COVID-19 Advocacy• NASFAA created the COVID-19 Web Center to

keep NASFAA members and the financial aid community updated on pertinent news related to the coronavirus.

www.nasfaa.org/covid19Slide 5 © 2020 NASFAA

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R2T4 Scenarios


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R2T4 Waiver Under CARES Act

• What is the “R2T4 Waiver?”• The CARES Act waives the requirement for the

school or the student to return Title IV funds when a student withdraws due to COVID-19

• This R2T4 waiver applies to the entire payment period that includes March 13, 2020, even if the student withdrew for COVID reasons before March 13th or before the disruption on campusØ We have confirmed this with the U.S. Department of

Education (ED)• Does not apply to quarters and payment periods

that begin after March 13th


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R2T4 Waiver Under CARES Act

• Schools are not required to implement the R2T4 waiverØ Encouraged because it’s in best interest of students

• Can choose to implement for certain populations of students (e.g., only those who withdrew after March 13th)

• If using the waiver for a subset of students, follow all steps in the May 15, 2020 Electronic Announcement for those students

• Not required to do anything if you already knew the withdrawal was not COVID-related and the R2T4 was already done


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Scenario 1: AryaR2T4 Waiver—Aid Already Returned

• School chooses to implement the R2T4 waiver for the entire payment period including March 13, 2020

• Arya officially withdrew from the spring term on January 20, 2020 before the school moved from ground-based instruction to distance learning due to COVID-19

• School does not require official withdrawals to indicate why they withdrew

• Financial aid office promptly did the R2T4 calculation under normal rules unrelated to COVID-19

• All aid had already disbursed except the spring Direct Loan disbursement

• School already returned school’s and Arya’s unearned aid• Does the R2T4 waiver apply for Arya?


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• It depends on why Arya withdrew• Waiver applies even though she officially

withdrew before the COVID-19 related disruption occurred on campus and before March 13thØ Waiver applies to entire payment period that includes

March 13th


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• School does not have to ask why Arya withdrew if during the payment period and due to COVID-19 the school:Ø Moved students from ground-based instruction to

distance learning;Ø Closed campus housing or other campus facilities;

orØ Experienced other interruptions in instruction

• School can assume she was a COVID-19 withdrawal because the school moved from ground-based instruction to distance learning due to COVID-19 (no attestation)


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School should:1. Re-disburse to Arya (and parents) all Title IV

funds that were previously returned to ED2. Disburse all “aid for which Arya was eligible

during the payment period, including aid that “could have been disbursed” from the original R2T4 calculation and her second Direct Loan disbursement (spring disbursement)

3. Make required adjustments in COD4. Credit the student's ledger account5. Request any necessary funds from G5


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• Per ED, you re-disburse and disburse aid as if the previous R2T4 calculation never happened, ignoring any post-withdrawal disbursement and late disbursement rulesØ No requesting approval to make the post-

withdrawal disbursementØ No timeframe, etc.

• Do not reverse or re-do the previous R2T4 calculation (reporting will be based on that)

• No requirement to notify student, but probably should as a good practice


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Upon reporting Arya as a COVID-related withdrawal, ED will:• Cancel the Direct Loan and TEACH Grant

disbursement for the entire payment period that includes March 13, 2020Ø Just the disbursement, not the entire loanØ All Direct Loans (student and parent)

• Exclude subsidized loan usage and Pell Grant payment from lifetime limits


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What if Arya was in an exclusively online program did not experience a disruption in instruction?• School has to get an attestation from Arya

indicating the withdrawal was COVID-related before re-disbursing or disbursing aidØ Can be email or text without a signatureØ Phone call is probably not acceptable


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What if Arya’s was in an online program that did not experience a disruption in instruction?• If Arya does not provide attestation by school’s

deadline, or indicates her withdrawal was not related to COVID, the school does nothing elseØ Do not reverse or re-do the R2T4 calculationØ Do not re-disburse previously earned aid or disburse

new aidØ Do not report Arya as a COVID-related withdrawalØ Arya is not eligible for Direct Loan or TEACH Grant

disbursement cancellationsØ Arya is not eligible for exclusions of subsidized loan or

Pell from lifetime limitsSlide 16 © 2020 NASFAA

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Scenario 2: SansaR2T4 Waiver—Unofficial Withdrawals

• Sansa received all “F” grades, so the aid office reviewed classes after the end of the spring term (includes March 13th) to determine if she earned any “Fs” or withdrew

• Professors reported she did not earn any “F” grades; she unofficially withdrew

• School can choose to assign the term midpoint orlast date of attendance in academically related activity (if known) as her withdrawal date

• School has Sansa’s attestation that her withdrawal was due to COVID-19

• School is just now doing the first R2T4 calculation• Does the R2T4 waiver apply for Sansa?


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• Yes, R2T4 waiver applies to all withdrawals, not just official withdrawalsØ Withdrawal was due to COVID and she

withdrew sometime during the spring term• School takes the following steps:1. Disburse any remaining Title IV

disbursements for the payment period, including any second or subsequent disbursements of Direct Loans (that normally cannot be late disbursements)

2. Perform R2T4 calculation ignoring all late and post-withdrawal disbursement rules


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• School takes the following steps (cont’d):3. Except for new disbursements, make no

adjustments to COD as a result of the withdrawal4. Except for new disbursements, make no

adjustments (as the result of the withdrawal) to the amount of Title IV aid credited to the student’s ledger account

• Calculation includes as “aid disbursed” allTitle IV aid for which Sansa was eligible during the spring payment period

• Same rules apply to all unofficial withdrawalsSlide 19 © 2020 NASFAA

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What if Sansa had earned one or all of those “F” grades by failing the coursework?• Student who earns at least one “F”

(completes but fails) is not a withdrawal• R2T4 waiver does not apply

Ø Only applies to students who completely withdraw due to COVID-19

• Do not report as a withdrawal• Loan or TEACH Grant disbursement

cancellation and other benefits do not apply


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Scenario 3: JonWithdrawals After the 60% Point

• Jon officially withdrew from the nonterm clock-hour payment period which included March 13, 2020

• He withdrew after the 60% point, so he earned all of his Title IV aid that was already disbursed for the payment period

• He indicated on his withdrawal form that his withdrawal was COVID-related

• What happens next?


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Scenario 3: JonWithdrawals After the 60% Point

• No unearned aid; R2T4 waiver does not apply

• Included in reporting?Ø Unsure at this time

• Qualify for Direct Loan and TEACH Grant cancellation or restoration of subsidized loan usage or Pell Grant lifetime eligibility used?Ø Unsure at this time


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SAP Guidance—Download AskRegs Q&As in Today’s Handouts


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Answers to Questions on Other Popular Topics


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CARES Act—Student Eligibility• Chronology of ED guidance1. No limitations on student eligibility2. Must meet Section 484 student eligibility requirements3. ED won’t solely enforce Section 484 requirements4. Interim final rules including Section 484 student

eligibility requirements (posted on ED’s website, pending in Federal Register)

• DACA/Other undocumented studentsØ 1996 welfare reform law prohibition

• Still no answer on eligibility for graduated or withdrawn students


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CARES Act - Interim Final Rule

• Posted June 11 on ED’s HEERF webpage• Provides justification (questionable) that ultimately

limits HEERF funds to students who are (or could be) Title IV eligibleØ Affirms no undocumented, DACA, or international

students• Requires full compliance with Section 484 Title IV

eligibility requirementsØ Additionally, ED states that students need to be enrolled

in an eligible program to receive funds


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CARES Act - Interim Final Rule (cont’d)

• Allows schools to design their own application to verify Title IV eligibility for students who choose not to fill out a FAFSA but otherwise meet eligibility criteria. Students “attest under the penalty of perjury to meeting the requirements of section 484 of the HEA.”Ø Suggests that schools encourage non-FAFSA filers to file

• Effective once published in the Federal Register(TBD)


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Future COVID-19 Funding

• Congress has already begun work on a 4th COVID-19 relief bill

• House Democrats have passed their proposal, but Senate has not introduced legislation yet

• The higher education community has asked for an additional for $46.6 billion for students and institutions (to account for additional need-based aid and lost institutional revenue)


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Verification Flexibilities and 2020-21

• Good News! But it’s complicated…• Per ED, verification flexibilities in the 4/3/20

Electronic Announcement are date-specific, not award year-specific, so can apply to verification for 2020-21 award year

• Applies to:Ø Identity/Statement of Educational PurposeØ Household size and number in college


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• What does “date-specific” mean?• Two possible deadlines:

Ø June 30, 2020; orØ End date of your summer crossover payment period

that is attached to 2019-20 award year, if you have one• Two possible choices school must make:

Ø Receive 2020-21 verification documents for those four items on or before the deadline; or

Ø Complete 2020-21 verification of those four items on or before the deadline


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Example 1: No summer 2020 classes or summer crossover payment period is not assigned as a trailer to the 2019-20 award year• Deadline to use the flexibilities is June 30, 2020

Ø June 30th for students to submit 2019-20 and 2020-21 verification documents for identity, Statement of Educational Purpose, household size, and number in college; or

Ø June 30th for you to complete 2019-20 and 2020-21 verification for those four items


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Example 2: Summer crossover payment period is assigned as a trailer to the 2019-20 award year and ends on August 15, 2020• Deadline to use the flexibilities is August 15,

2020 for this schoolØ August 15th for students to submit 2019-20 and 2020-

21 verification documents for identity, Statement of Educational Purpose, household size, and number in college; or

Ø August 15th for you to complete 2019-20 and 2020-21 verification for those four items

• August 15th is for this school example; will be different deadline for other schools


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CARES Reporting Requirements

• R2T4Ø ED estimates that it will release process in 1-2 monthsØ In the meantime, keep tracking

• HEERF Student ShareØ Posting on web site, see 5/6/20 Electronic

AnnouncementØ No updates from ED on future reporting

• HEERF Institutional ShareØ CARES requires quarterly reportingØ No updates from ED


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Professional Judgment (PJ)

• NASFAA surveyØ Assist with meeting training needsØ Assist with federal advocacy efforts

• Use of Dear Colleague Letter (GEN 09-05)Ø Allows FAAs to have a blanket policy to use a

letter from the state unemployment agency, or other evidence of receipt of unemployment benefits, to zero out income earned from work and exclude unemployment benefits

Ø Unclear if it’s still in effectSlide 34 © 2020 NASFAA

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CARES Act—Upcoming Terms

• Many ED flexibilities and CARES provisions do not extend into summer or fall, or it’s unclear if they do

• As pandemic continues, ED beginning these discussions now

• Examples:Ø Paying FWS studentsØ Emergency FSEOGØ VerificationØ Overlapping payment periods


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Cost of Attendance (COA) Considerations for 2020-21

• May need to adjust 2020-21 COA depending on your institution’s plans for fall (e.g., living allowances)

• Reminder: Higher Education Act states that "no distinction shall be made with respect to the mode of instruction in determining costs”

• NASFAA Monograph 24: Developing the Cost of Attendance


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ED Guidance Timeline


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Register online at nasfaa.org/letstalk

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Questions


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Submit Your Questions


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Download Your Certificate of Attendance


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Complete the Survey


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Thank you for joining us!NASFAA seeks to shape the future by promoting student access and success in higher education.

Webinars, like this one, are made possible thanks to the annual dues paid by NASFAA members at postsecondary institutions across the country.


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Learn more at: www.nasfaa.org/Join_NASFAA

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