AskRegs Update: What Factors Do We Consider When Deciding To Extend a Break Or Revise Our Term Length Due To Coronavirus?
This Q&A was updated on April 29, 2020 to include term length revisions beyond just extending scheduled breaks. It also contains earlier updates from the U.S. Department of Education (ED) in the April 3, 2020 Electronic Announcement, particularly with regard to the process for requesting a reduced academic year.
There are several factors to consider when you decide to extend an existing scheduled break or otherwise reduce the term or academic calendar length due to Coronavirus-related interruptions.
Academic Year Length: First, you must ask yourself,"When we extend our scheduled break or otherwise reduce the length of a term (e.g., starting late), does it shorten the academic year to less than 30 weeks?"
Under34 CFR 668.3, an academic year in a credit-hour program must consist of 30 weeks of instructional time. According to guidance NASFAA has received from ED, if you extend your scheduled break or reduce your term length, it may reduce the number of weeks of instructional time in your term/payment period and thereby your academic year to less than 30 weeks. For example, if you have a program consisting of two 16-week semesters with a 32-week academic year, and the extended break reduces your spring term by two weeks, no further action is necessary. On the other hand, if your academic year consists of two 15-week semesters, and the additional week of scheduled break reduces the 15-week semester to a 14-week semester, you have reduced your academic year length to 29 weeks. If this happens, you must obtain approval from ED. The same is true if you start classes later than scheduled.
Per the April 3, 2020 Electronic Announcement, "If an institution determines it will temporarily cease providing instruction, extend a break, or otherwise reduce the length of its term in a manner that results in fewer than 30 weeks of instruction in the academic year as the result of COVID-19 disruptions, it should send an email to CaseTeams@ed.gov to request a temporary reduction in the length of its academic year. The request must:
Institutions should include in the subject line of the email the institution's name, OPEID, and the state where the main campus is located. The request will be reviewed and forwarded to the appropriate School Participation Division, which will communicate its final determination to the institution."
It is NASFAA's understanding based on the March 5, 2020 Electronic Announcement that ED can grant a reduction to as little as 26 weeks for a credit-hour program at this time. To avoid a reduction in your academic year length, you could choose to add days to the end of the term/payment period to make up for the lost week(s) of instructional time.
Return of Title IV Funds (R2T4): Based on the March 5, 2020 Electronic Announcement, if you extend an existing scheduled break (such as spring break), the number of days in the scheduled break now includes the previously scheduled break plus the additional days resulting from the extension. These new total days in the extended break are then excluded from both the numerator and the denominator in the R2T4 calculation if the extended break is five or more consecutive days. If you extend the payment period (or period of enrollment) by adding days to the end to make up for a loss of instructional time (or some other reason), you will use the revised payment period begin and end dates in the R2T4 calculation, consistent with guidance under "Reentering the Same Payment Period" in the March 5th Electronic Announcement.
According to guidance NASFAA has received from ED, if the term starts later, the revised number of days are used in the R2T4 calculation. The denominator in an R2T4 calculation must always consist of the number of days the student was scheduled to attend. For students beginning enrollment in say a summer term that will now consist of only eight weeks, the revised number of days in that payment period will comprise the denominator.
The school is not required to redo any R2T4 calculations that were done correctly at the time they were initially performed. See AskRegs Knowledgebase Q&A, Must the School Redo R2T4 Calculations That Were Done Before Payment Period Adjustments Were Made Due To Coronavirus?
Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) schools are still required to perform R2T4 calculations, but schools and students are not required to return any unearned aid resulting from the R2T4 calculation. See AskRegs Q&A, Does the CARES Act Waive R2T4 Requirements When a Student Withdraws Due To COVID-19?
Adjusting Loan Periods and Disbursement Dates: According to ED, when you choose to extend a term that begins on or before June 1, 2020, you are not required to change loan period end dates for loan periods that were scheduled to end on the original term end date. See also AskRegs Q&A, Must We Change Disbursement Dates If Our Payment Period Starts Later Than Originally Scheduled Due To Coronavirus?
NSLDS Enrollment: Because your institution is closing temporarily by extending spring break, and assuming the institution will reopen within 90 days from the closure and the student will resume attendance when the institution reopens, you do not need to report your students as withdrawn during the temporary closure. See the April 3, 2020 Electronic Announcement for more on reporting in-school status and in-school deferment status.
Paying Federal Work-Study (FWS) Students: You may continue to pay FWS students who were already working an FWS job before the COVID-19 interruption and who are unable to continue working due to a COVID-19 related campus closure or moving classes online, provided your institution continues paying its other employees and continues to meet its institutional share requirement. See both the March 5, 2020 Electronic Announcement and the April 3, 2020 Electronic Announcement for more on FWS.
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: 3/16/2020