AskRegs Update: How Do We Determine if a Withdrawal Was the Result of a Qualifying Emergency Due to Coronavirus?

How Do We Determine if a Withdrawal Was the Result of a Qualifying Emergency Due to Coronavirus?

This AskRegs Knowledgebase Q&A has been updated to reflect guidance in the May 15, 2020 Electronic Announcement that defines whether a student is a withdrawal due to COVID-19 under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The following guidance refers only to the return of Title IV funds (R2T4) provisions in the announcement, not to satisfactory academic progress (SAP).

It depends on whether there was an interruption of instruction or campus operations due to COVID-19.

Interruptions In Instruction or Campus OperationsALL students who withdrew during the covered payment period or period of enrollment (see below) are considered COVID-19 related withdrawals if any of the following take place:

  • The school moved students from ground-based instruction to distance learning during the payment period/period of enrollment due to COVID-19;
  • The school closed campus housing or other campus facilities during the payment period/period of enrollment due to COVID-19; or
  • The school experienced other interruptions in instruction during the payment period/period of enrollment due to COVID-19.

This is true even if the student withdrew before March 13 or before the COVID-19 related disruption occurred on campus.

Students in this category do not have to provide any attestation or documentation confirming why the student withdrew.

No Interruptions In Instruction or Campus OperationsFor institutions that did not undergo changes in educational delivery or campus operations as a result of COVID-19, the student is considered a COVID-19 related withdrawal only if the student provides the institution with a written attestation (including by email or text message) explaining why the withdrawal was the result of the COVID-19 emergency. Additionally, a student is considered a COVID-19 related withdrawal from a distance education program only if the student provides a written attestation (including by email or text message) explaining why the withdrawal was the result of the COVID-19 emergency. Notice, there is no signature requirement here. If no such attestation is received, the withdrawal is not COVID-19 related and unearned Title IV aid resulting from the R2T4 calculation must be returned.

Allowable circumstances for the attestation include, but are not limited to:

  • Illness of the student or family member;
  • Need to become a caregiver or first responder;
  • Loss of childcare;
  • Economic hardship;
  • Inability to access wi-fi due to closed facilities; or
  • An increase in work hours as a result of the COVID-19 emergency.

Information (which in the judgment of the institution is reliable) provided by the family member of a withdrawn student whom the institution is unable to contact is acceptable for documentation purposes.

Collection of the attestation will need to be done retroactively in some cases. In those cases, after the attestation is received, you must follow the guidance under "Return of Title IV Funds (R2T4) — In general" in the May 15 Electronic Announcement.

Covered Payment Period or Period of Enrollment: According to the Electronic Announcement, the covered period is a payment period or period of enrollment that begins on or includes March 13, 2020, during which the student began attendance and did not complete the payment period/period of enrollment. This guidance does not apply to payment periods that begin after March 13, 2020, although NASFAA is asking ED if the guidance can be extended to subsequent payment periods. If this changes, we will update this AskRegs Knowledgebase Q&A and post it in our Coronavirus (COVID-19) Web Center and in Today's News.

Note: The above guidance also applies to unofficial withdrawals when the calendar midpoint of the payment period falls before March 13, 2020.

See also the following AskRegs Knowledgebase Q&As:

If you are a NASFAA member, you can submit additional questions through the AskRegs Knowledgebase. Our experts will thoroughly research your question and provide you a comprehensive answer, including any applicable regulatory citations. That question and answer may then be added (without identifying information) as appropriate to further expand the Knowledgebase Q&A library.

 

Publication Date: 4/30/2020

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