AskRegs Update: How Do We Determine How Much to Pay FWS Students When Enrollment Is Disrupted by Coronavirus?

How Do We Determine How Much to Pay FWS Students When Enrollment Is Disrupted by Coronavirus?

This Q&A contains minor updates as a result of the U.S. Department of Education's (ED's) March 20, 2020 publication of the COVID-19 FAQs attached to the March 5, 2020 Electronic Announcement.

When a student is unable to work during a term or nonterm payment period that is interrupted by coronavirus (see note below), the school must decide how much to pay FWS students for the hours they do not actually work.

According to the COVID-19 FAQs, "If an FWS student is unable to work his/her scheduled hours because of COVID-19 disruptions (school closures, employer closures, student quarantined, etc.), the school may pay the student for any scheduled hours or allow the student to work by another means (on-line, remote, telecommute, etc.). Students should be paid the wage rate that they would have been paid if they were able to work the scheduled hours.

In this circumstance, when a school pays the student for the hours the student was scheduled to work, but did not work, the school is not required to submit any documentation to the Department. However, the school must document the number of scheduled hours a student should be paid prior to paying the student. Schools should also document in the student’s file any actions that were taken regarding payment of FWS funds for scheduled hours that were not worked by the student."

Note that, by definition, scheduled hours are not necessarily the same as average hours.

According to guidance NASFAA has received from ED, ED does not dictate how schools must document the hours the student was scheduled to work, just that schools must maintain records of how FWS payments were calculated (e.g., the determination of hours the student was scheduled to work). 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. It would be a best practice to have the student's FWS supervisor to sign off on whatever documentation that is used; however, there may be instances when the FWS supervisor is unavailable to do so.

Additionally, GEN 17-08 states that “payments may be made in an amount equal to or less than the amount of FWS wages those students would have been paid had they been able to complete the work obligation necessary to receive FWS funds.” And, according to ED, these students can be paid in a lump sum.

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.

Note: According to ED, the March 5, 2020 Electronic Announcement guidance under the "Federal Work-Study (FWS)" heading applies in the following instances:

  • When the school closes (temporarily ceases to offer instruction in any format for the remainder of the payment period);
  • When the school does not close, sends all students home, and moves all classes to an online format via distance education for the remainder of the payment period; and
  • In any scenario when the student is unable to continue an FWS job as a result of the school's (or off-campus employer's) decision because of COVID-19.

The Electronic Announcement guidance 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.

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: 3/17/2020

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