Trending AskRegs Q&A: Can Students Be Paid FWS When the School Does Not Close, Sends Students Home, and Moves All Classes Online Due to Coronavirus?

Can Students Be Paid FWS When the School Does Not Close, Sends All Students Home, and Moves All Classes Online Due to Coronavirus?

Yes. According to guidance NASFAA has received from the U.S. Department of Education (ED), the March 5, 2020 Electronic Announcement guidance under the "Federal Work-Study (FWS)" heading applies in instances when the school closes (temporarily ceases to offer instruction in any format for the remainder of the payment period) and when the school does not close, sends students home, and moves all classes to an online format via distance education for the remainder of the payment period. In fact, the FWS guidance applies in any scenario when the student is unable to continue an FWS job due to the school's or the off-campus employer's decision as a result of COVID-19 interruptions. This guidance has been confirmed in the COVID-19 FAQs document that was later added to the Electronic Announcement.

The FWS guidance in the Electronic Announcement does not apply to students who decide for themselves to leave campus and/or switch to online classes. These students are not eligible to be paid FWS for any hours they do not actually work.

According to ED, the student can be paid for the FWS hours he, she, or they were scheduled to work for the term or nonterm period. By definition, scheduled hours are not average hours. Per ED, the school can have the student submit a timesheet for the hours he or she was scheduled to work and pay FWS wages based on that. ED also indicated that timesheets are not required for students who receive FWS wages while unable to work. However, schools must maintain records of how payment was calculated (e.g., the determination of hours the student was scheduled to work). Beyond that, ED's guidance is silent on how and when the school will pay these students, so it is the school's decision to make. See AskRegs Knowledgebase Q&A, How Do We Determine How Much To Pay FWS Students When Enrollment Is Disrupted By Coronavirus?

There are lots of different combinations, so use your best judgment to apply the Electronic Announcement guidance if and until ED provides further clarifications.

Remember: If your quarter or term has not yet started and enrollment is disrupted by COVID-19, then those students cannot be paid FWS for the upcoming quarter or term under the Electronic Announcement guidance. This includes terms that have not yet started because the school delayed the start date.

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Publication Date: 3/13/2020

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