Can We Pay FWS For a Future Quarter If the Student's Employment Is Interrupted By Coronavirus?
It depends on whether the student begins attendance in the future quarter covered by COVID-19 interruptions guidance.
According to guidance NASFAA has received from the U.S. Department of Education (ED), the March 5, 2020 Electronic Announcement guidance will be extended to cover students who enroll in payment periods that start on or before June 1, 2020. This includes students who begin attendance but are unable to work due to the COVID-19 interruptions. Students who are allowed by the school to continue to work must work the hours in order to be paid FWS funds. Students who are allowed to work remotely must work the hours in order to be paid FWS funds, even though the school is not required to allow students to work remotely. See AskRegs Knowledgebase Q&A, Can an FWS Student Work Remotely Due to Coronavirus?
That having been said, FWS funds still cannot be paid for a payment period in which the student does not begin attendance. This includes payment periods that start later than originally scheduled due to COVID-19 interruptions. As explained in the Electronic Announcement, "Students who were prevented from beginning a term at the institution as a result of a COVID-19-related disruption would not be eligible for Federal Student Aid for that term, and therefore could not be paid FWS wages for hours they did not work." This is consistent with Title IV aid treatment under 34 CFR 668.21.
Note: According to ED and page 3-197 of the 2019-20 FSA Handbook, schools are not required to adjust the cost of attendance (COA) or recalculate Title IV aid when the COA changes from one payment period to the next.
NASFAA will continue to monitor this issue and will update this Q&A if there are changes in guidance. In the meantime, please stay tuned to NASFAA's Coronavirus (COVID-19) Web Center.
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Publication Date: 3/19/2020