Must the School Redo R2T4 Calculations That Were Done Before Payment Period Adjustments Were Made Due to Coronavirus?
No. According to guidance NASFAA has received from the U.S. Department of Education (ED), the school is not required to redo any return of Title IV funds (R2T4) calculations that were done correctly at the time they were initially performed. This is consistent with existing R2T4 guidance in Volume 5, Chapter 1 of the FSA Handbook.
Any R2T4 calculations that are performed after the school's action to close and/or extend scheduled breaks will need to be performed using the adjusted payment period dates, and will need to exclude any scheduled breaks of five or more consecutive days (numerator and denominator). This includes any extended breaks that fall within the payment period/period of enrollment being used in the R2T4 calculation due to Coronavirus.
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Publication Date: 3/16/2020