AskRegs Update: What Factors Do We Consider When Deciding to Extend a Scheduled Break Due to Coronavirus?

What Factors Do We Consider When Deciding to Extend a Scheduled Break Due to Coronavirus?

This Q&A was updated on March 20, 2020 to include a clarification from the U.S. Department of Education (ED).

There are several factors to consider when you decide to extend the existing scheduled break due to Coronavirus-related interruptions.

Academic Year Length: First, you must ask yourself, “When we extend our scheduled break, does it shorten the academic year to less than 30 weeks?”

Under 34 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, 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 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, the guidance under "Length of Academic Year" in the March 5, 2020 Electronic Announcement applies, and you must obtain approval from your ED School Participation Division. On the other hand, 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, you do not need ED's approval.

These are the steps to follow:

  1. The institution should determine if the reduction in the number of weeks of instructional time in the term brings the academic year to less than 30 weeks. If not, no further action is necessary.
  2. Assuming the reduction in the length of instruction in the term results in an academic year consisting of fewer than 30 weeks, the institution should submit a request for reduction in the length of an academic year to COVID-19@ed.gov, including the number of weeks that will now comprise the academic year, (e.g., 28 weeks).
  3. The institution’s request will be routed to the appropriate School Participation Division which will inform the institution of its decision.

They 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): 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. The 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 Electronic Announcement.

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?

Adjusting Loan Periods: 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.

NSLDS Enrollment Reporting: 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.

Paying Federal Work-Study (FWS) Students: You may continue to pay FWS students who are unable to continue working due to a COVID-19 related campus closure, provided your institution continues paying its other employees and continues to meet its institutional share requirement. See the March 5, 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

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