ED Issues Guidance to Institutions on Title IV Implications of Coronavirus Spread

By Allie Arcese, Sr. Director of Strategic Communications & Engagement

By Allie Bidwell Arcese, NASFAA Managing Editor

As concerns about the potential spread of the coronavirus continue to rise, the Department of Education (ED) on Thursday released guidance providing significant flexibility to institutions with students who may experience interruptions in study. The guidance addresses several situations that may arise as a result of increased spread of the virus and how institutions can maintain compliance with federal financial aid regulations as written — or with new, temporary flexibility provided in the notice. 

Over the last several weeks, colleges and universities both abroad and within the United States have experienced uncertainty as to whether study abroad programs should continue — and whether students currently abroad should return home — whether entire campuses should close due to incidences of the virus, and how the federal government can or should intervene in the meantime. 

The Centers for Disease Control and Prevention on Sunday issued guidance suggesting institutions consider postponing or canceling study abroad programs, and consider asking current study abroad students to return home. Meanwhile, some institutions with campuses abroad have moved those programs online.

The guidance from ED comes after Education Secretary Betsy DeVos announced during a congressional hearing last week that the agency had formed a task force to coordinate response to the outbreak. 

In the announcement, ED presents five different scenarios in which institutions might have trouble complying with federal Title IV regulations, and suggested that institutions document “as contemporaneously as possible, any actions taken as a result of COVID-19, including those actions described in this document.” Those scenarios are: 

  • 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 COVID-19, 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 COVID-19 illness;
  • A campus temporarily stops offering ground-based classes in order to prevent the spread of COVID-19;
  • A foreign school that serves U.S. students who participate in title IV programs temporarily suspends operations due to COVID-19.

“Our goal is to work with institutions and find ways to enable you to accommodate students and help them continue their education despite interruptions caused by COVID-19,” ED said in the announcement. 

Broadly, ED said it will be allowing institutions flexibility with regard to securing approval to offer distance education. While some institutions would normally have to go through an approval process with ED to use or expand distance learning programs, ED is providing “broad approval” to accommodate students “on a temporary basis” without going through that process. It is also allowing accrediting agencies to waive their review requirements for offering distance education for institutions that may need to do so to accommodate students impacted by the spread of the coronavirus. Institutions may also choose to enter into temporary consortium agreements should a student need to complete coursework at another institution. This would not apply to foreign schools, as the Higher Education Act (HEA) does not permit foreign schools to offer distance education and ED only has authority to offer relief on regulations, not statute.

ED addressed specific impacts on the Federal Work-Study (FWS) program if disruptions from the coronavirus occur. Currently, federal law allows institutions to continue making FWS payments in certain circumstances to students in disaster-impacted areas if the student is not able to continue working. While ED said it is “unlikely that an entire region would be declared a federal disaster area,” due to the coronavirus, for students enrolled at an institution that has to close temporarily, “the loss of this important form of financial aid can be devastating.” 

“The impact may be magnified if the institution accommodates students by providing alternative instructional opportunities and the student is required to continue paying tuition, but the student loses FWS as an important part of their financial aid award,” ED continued.

In those circumstances — for FWS students enrolled at an institution that closes temporarily due to the coronavirus, or for those whose employer closes as a result of the coronavirus — the institution will be permitted to continue paying the FWS wages “if it occurred after the beginning of the term, the institution is continuing to pay its other employees (including faculty and staff), and the institution continues to meet its institutional wage share requirement.”

ED will also allow students to take approved leaves of absence for concerns related to the coronavirus, “even if the student notifies the institution in writing after the approved leave of absence has begun.” In that case, the institution would keep any Title IV funds for the student to use when they resume their studies. However, if the student does not return within 180 days, the school would need to move forward with a Return of Title IV (R2T4) funds calculation.

The guidance also addresses other situations including professional judgment, satisfactory academic progress, enrollment status reporting, and length of academic year, among other topics.

Of special note for institutions are the areas ED is not able to offer relief. Students who never enrolled in the payment period because they were unable, due to temporary school closure, are not eligible for any Title IV funds. In such instances, institutions must return all grants and loans that were credited to student accounts for these students. Loan proceeds refunded directly to students need not be returned, and ED has stated that institutions will be exempt from reporting students who were unable to begin attendance due to coronavirus to loan servicers, as they are generally required to do for students who never begin attendance. 

ED cannot provide relief for R2T4; however, the guidance reminds institutions that R2T4 calculations are only required for withdrawals and that, if an institution temporarily closes and reopens during the same payment period, they would not be required to complete R2T4 calculations for students who resumed enrollment when the institution re-opened. 

Finally, ED cannot provide relief for coronavirus-related enrollment status changes — for instance, when a student drops from full-time to three-quarter time status because an internship location closes due to coronavirus-related issues. Students in those situations would have to be treated as three-quarter time for financial aid purposes, such as their Pell Grant amount.

If your institution has a scenario not addressed in the electronic announcement, please email [email protected]. For a full overview of the recommendations and allowances from ED, please refer to the full electronic announcement, and stay tuned for more analysis from NASFAA’s policy team.

ED noted that it has created a website with information and guidance for schools with regard to the coronavirus, and said additional questions may be sent to [email protected]

“While the coronavirus threat to the American public remains low, we encourage school communities to take all steps to ensure the health and well-being of students, faculty, and staff,” ED said in the announcement.


Publication Date: 3/5/2020

Diana S | 3/12/2020 1:50:22 PM

Building off of Alicia's K's comment (looking for clarification regarding students earning FWS for institutions that are not "closed" but offering all online classes for the next 14 days)...

What if the student's FWS position is related to student's being on-campus (e.g. tutoring services, lab support, etc.)? If there are no students on-campus and there is no work to be performed, should those students qualify to be paid (as inability to work/earn is directly related to COVID-19)?

Jennifer B | 3/12/2020 10:16:58 AM

I wanted to get clarification on the recent guidance as it pertain to Study Abroad students. For our student aboard students who are attending host schools, where the institution has an agreement, are the students able to take advantage of distance learning opportunities provided by the host institution and receive Title IV? In reading the section on foreign institution it appears No. Since we have additional students now coming home will ED offer any flexibility.

Monica B | 3/12/2020 10:1:11 AM

Are institutions who are moving classes to an online platform thinking about refunding a portion of room and board charges? If so, will schools adjust COAs and financial aid?

Alicia K | 3/11/2020 5:52:21 PM

Looking for clarification regarding students earning FWS for institutions that are not "closed" but offering all online classes for the next 14 days. The guidance allows students the opportunity to earn work-study when institutions are closed but it's not clear for institutions offering alternative modes of instruction.

Larry C | 3/6/2020 10:38:27 AM

I am interpreting that if the host institution (study abroad school) provides the online experience that the student would not be eligible for Title IV aid because foreign schools are not authorized to distance learning. Reference the guidance under foreign schools. Unfortunate if my interpretation is correct.

Robert F | 3/6/2020 10:15:05 AM

Sean, the way I am interpreting this is that if the course must be moved online due to a COVID-19-related situation the student would still qualify for their Title IV aid. The Department is providing flexibility to work around the normal approval processes we would need to go through, but only if the rationale is related to COVID-19 and it is not a foreign institution that the student is attending.

Allie B | 3/6/2020 10:7:01 AM

Hi Sean! Thanks for your question. If you email [email protected], someone will be able to help you out.

Allie Arcese

Sean S | 3/5/2020 3:44:37 PM

Looking for clarification -- if a student is studying abroad, and the abroad course they are taking is moved online due to COVID-19 -- they are no longer eligible for TIV aid? Even if the coursework will result in the same credits?

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