Guidance Released on Interruptions of Study Related to COVID-19

April 7, 2020 | Article

By Kristin Diggs and Roger Tovar

On March 5, 2020, the Department of Education issued a memo providing guidance for interruptions of study relating to coronavirus (COVID-19). The memo helps to address concerns expressed by higher education leaders on how they should comply with Title IV, Higher Education Act (HEA) policies for students whose activities are impacted by the COVID-19 either directly or indirectly.

Within the memo, there are five potential student and campus scenarios addressed and how the institution may address these scenarios and comply with Title IV, HEA requirements if there is an impact on the students or campus relating to the coronavirus.

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Potential Student and Campus Scenarios Impacted by COVID-19
Below are the five potential student and campus scenarios that were addressed in the memo:

  • A student was enrolled or was supposed to begin a travel-abroad experience and either the student has been called back to the U.S. or was never able to begin the travel abroad experience.
  • A student was enrolled in a program and met the requirements for full-time enrollment; however, due to the coronavirus, one or more classes—such as an internship, a clinical rotation, student teaching or fieldwork—have been cancelled and now the student has fallen below the 12 credit hour minimum and is no longer considered to be a full-time student.
  • A student is quarantined and misses class or a student is incapacitated due to the COVID-19.
  • A campus temporarily stops offering ground-based classes in order to prevent the spread of coronavirus.
  • A foreign school that serves U.S. students who participate in title IV programs temporarily suspends operations due to coronavirus.

Potential Solutions to Impacted Student Activities by COVID-19
The Department of Education’s primary goal is to work with educational institutions to find ways to accommodate students and allow them to continue their educational experience, despite the interruption of COVID-19.

Specifically, the memo focuses on the need to utilize online education to extend educational experiences for students. Online education can be a great aid for students who were recalled from a travel-abroad program or arrived in a foreign country only to have their program temporarily cancelled or suspended.

In order to do this, the Department of Education has offered the following flexibilities:

  • Approval to offer distance education, without the regular approval process of the Department of Education on a temporary basis. This flexibility only applies to a program during a payment period that overlaps the date of this electronic announcement or the following payment period.
  • Temporary waiver of distance education review requirements for those educational institutions accommodating students whose enrollment is interrupted by COVID-19. This temporary waiver is limited to distance learning opportunities developed for serving students who were already in attendance, but whose attendance was interrupted by COVID-19.
  • Temporary consortium agreements with other institutions where students can complete courses at a different institution but earn credit at their home institution.
  • Approved leave of absence of students for COVID-19 related concerns or limitations. This will allow the institution to retain applicable Title IV funds to apply when the student continues enrollment. If student does not return within 180 days, the school should perform Return of Title IV calculation based on the date the leave of absence began.
  • Offer a non-standard term for students whose travel abroad programs or experiential learning opportunities were cancelled after the semester began. This option is offered so that those students are still able to complete the term.
  • Federal Work Study – Institutions that must close due to COVID-19 can continue paying the student Federal work-study wages during the closure under certain circumstances.
  • Length of Academic Year – School participation team may approve a temporary reduction in the length of its academic year if the institution determines that it will close as the result of a campus health emergency.
  • Professional Judgement can be exercised by financial aid administrators in order to make, on a case-by-case basis, changes to the cost of attendance or to the data elements used in calculating the EFC to reflect a student’s special circumstances. Documentation must be retained in the applicable student file and determinations must be made on a case-by-case basis.
  • Students who did not begin attendance due to school closures – Institutions must return all Title IV grant funds disbursed for the payment period or period of enrollment and all Direct Loan funds that were credited to the student’s account at the institution for that period.
  • Return of Title IV – Currently, no waiver exists impacting the statutory requirement for the return of unearned Title IV funds. If an institution ceases operations during a payment period and fails to reopen by the end of the payment period, the students are considered no longer in attendance and must be considered withdrawn for that payment period and would be subject to Return of Title IV funds requirements. If an institution closes and subsequently reopens during the payment period, any students who began attendance during the payment period, but failed to return when the institution reopens must be considered withdrawn for that payment period.
  • Date of Determination and Timeframes for Returns - The date the institution closes for reasons beyond its control (COVID-19) will be considered the student’s withdrawal date. Therefore, the timeframes for completing Return of Title IV Funds calculations and making the appropriate returns or post-withdrawal disbursements begin on that date.
  • NSDLS Enrollment Reporting – Institutions can defer reporting an affected student’s enrollment status as “withdrawn” if the institution has a reasonable expectation that the institution will reopen at the start of a payment period that begins no later than 90 days following the closure and the student will resume attendance when the institution reopens.

What to Do in the Wake of COVID-19
The ideas and solutions outlined are a brief overview of the Department of Education’s memo in relation to COVID-19. To see the full details of the announcement, make sure to read the memo in its entirety here.

On April 3, 2020, the Department of Education released updated guidance regarding those items above. Please refer to the additional guidance here.

For any decisions taken by the institution, it should be well documented, including those situations described in the Department of Education memo. Additional information can be found at the Department of Education’s Coronavirus website.

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