The school has a student who is employed 20 hours per week in its office of financial aid in a Federal Work-Study (FWS) position and is also employed with another department on campus in a non-FWS position. The student desires to work 20 hours in each position. Is a student who already works 20 hours per week in a FWS position allowed to work an additional 20 hours in a non-FWS position?
Yes. However, keep a few things in mind. The premise of the Federal Work-Study (FWS) program is to provide an opportunity for students to earn funds when they are not in class to help fund their education. There are no regulations which state a student cannot work a FWS and non-FWS position at the same time. The student should not be working either job during a time they would be attending class.
In assigning a FWS job, a school must consider the student’s financial need, the number of hours per week the student can work, the period of employment, the anticipated wage rate, and the amount of other assistance available to the student. While there is no minimum or maximum award, the amount for each student should be determined based on these factors. Taking into account the rates of pay applicable to the position, the qualifications for each pay level, and the qualifications of the student applicant, the financial aid administrator (FAA) can determine the number of hours that a student would need to work in order to earn the full amount of the student’s FWS award. The school should also determine the number of hours a student can work based on the student’s financial need and how the combination of work and study hours will affect the student’s health and academic progress. There are no statutory limitations on the number of hours per week or per payment period a student may work, provided no over-award occurs. However, as a good practice, schools may cap the number of hours worked per week by FWS students to ensure that work does not interfere with academics.
With regard to working in a FWS position during a period when he or she is not attending classes, e.g., the summer term or winter term, the school must apply the attributed earnings to the cost of attendance for the next period of enrollment. So, while there is no limitation on the number of hours a student may work during a period of non-enrollment, you should be mindful of how these earnings will affect a student’s eligibility for FWS funds during the next period during which the student is enrolled.
For additional information, try NASFAA's Student Aid Index. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other Department of Education and NASFAA references. It is updated on a rolling basis with the latest news and changes. Search Federal Work-Study Program.
Also see 34 CFR 675.25(b) and Volume 6, Chapter 2 of the FSA Handbook.
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Publication Date: 8/13/2019
Peter G | 8/16/2019 11:46:11 AM
I would add that, even though it's allowable, before actually proceeding with a first-time live test case you would want to work through your school's process (particularly with payroll but also HR if that's a separate department) and make sure they can do this correctly in practice, that all the data will flow correctly, and what limitations exist.
Things like muddled job codes, time card reporting, can make your life interesting, etc. If for example, you used a single job code for all lab monitors, and the student is an FWS lab monitor for physics, but non-FWS lab monitor for chem, then it may be hard for the system to parse out at the individual student level how much should be assigned to FWS vs. non-FWS.
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