Trending AskRegs Q&A: Must It Be a Title IV-Approved Leave Of Absence To Qualify Under the COVID-19 Guidance?

Must It Be a Title IV-Approved Leave Of Absence To Qualify Under the COVID-19 Guidance?

Yes. The March 5, 2020 Electronic Announcement guidance regarding a leave of absence (LOA), only applies to Title IV-approved leaves of absence defined in 34 CFR 668.22(d). If your school does not have a Title IV-approved LOA, the student is a withdrawal if the school closes and/or does not move classes online, or if the school closes and reopens and the student later withdraws during the same payment period or period of enrollment.

Under 668.22(d), "A leave of absence is an approved leave of absence if—

(i) The institution has a formal policy regarding leaves of absence;
(ii) The student followed the institution's policy in requesting the leave of absence;
(iii) The institution determines that there is a reasonable expectation that the student will return to the school;
(iv) The institution approved the student's request in accordance with the institution's policy;
(v) The leave of absence does not involve additional charges by the institution;
(vi) The number of days in the approved leave of absence, when added to the number of days in all other approved leaves of absence, does not exceed 180 days in any 12-month period;
(vii) Except for a clock hour or nonterm credit hour program, upon the student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior to the leave of absence; and
(viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student, prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on the student's loan repayment terms, including the exhaustion of some or all of the student's grace period."

Per the Electronic Announcement, "The Department will permit students who wish to take an approved leave of absence for COVID-19-related concerns or limitations (such as interruption of a travel-abroad program), to take such leave, even if the student notifies the institution in writing after the approved leave of absence has begun. In such a case, the institution may retain those Title IV funds to apply when the student continues enrollment. If the student does not return to complete their program within 180 days, the school would then be expected to perform the Return of Title IV funds calculation based on the date on which the leave-of-absence began. Note that in term-based programs, if a student takes an approved leave of absence from a term-based program, the institution must ensure that the student is permitted to complete the coursework he or she began prior to the leave of absence."

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Publication Date: 3/19/2020

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