ED Releases Updated COVID-19 Guidance Addressing Verification, Need Analysis, Distance Education

By NASFAA Policy & Federal Relations Staff

The Department of Education (ED) late on Friday released an updated COVID-19 Electronic Announcement (EA), providing new guidance and flexibilities on verification, need analysis, and distance education. The EA provides some guidance related to the COVID-19 stimulus bill, the  Coronavirus Aid, Relief, and Economic Security (CARES) Act, but does not address all of the CARES Act Title IV provisions, or the implementation of the Emergency Stabilization Fund. 

Effective Date

Previous guidance from ED applied to students enrolled in payment periods that begin on or before June 1, 2020.

Unless otherwise specifically stated, the most recent EA is effective through June 30, 2020, or the end of a crossover payment period assigned to the 2019-20 award year. Note that the most recent EA includes some flexibilities that were previously authorized in earlier guidance, thus extending their authorized effective period from June 1 to June 30.


The April 3 guidance allows for some relief for the completion of verification for students and institutions. 

For students whose applications are flagged with the V4 and V5 verification codes — those who are required to provide to the financial aid office, in person or via notarized documents, identity and statement of educational purpose — ED has suspended the in-person submission or notarized document requirement. While the documents will still be required, they may instead be submitted in person or electronically, via email, through uploading photos, or through the school’s portal. Requirements to ensure encryption/security of electronically-submitted documents still apply in this situation. 

In addition, ED has canceled the April occurrence of the Pell Grant warning and “deobligation” process, in which Common Origination and Disbursement (COD) records with a verification code of “W” prompt a warning to the financial aid office that any Pell Grants they’ve awarded that term, and already approved in COD, will be regarded as over-awards and the disbursement amount reduced to $0. ED will re-evaluate the scheduled July and October “deobligation” dates as they approach. 

The EA also allows schools to accept expired forms of identification — such as a driver’s license, if the ID expired after March 1, 2020 — and also waives the requirement for the school to collect a parent’s signature to verify the number in the household and the number enrolled in college if the dependent student’s parents are unavailable. 

Last week NASFAA sent a letter to ED requesting verification and c-code documentation relief. Several of NASFAA’s requests are contained in this EA, including the suspension of the in-person V4 and V5 document collection process. NASFAA has followed up with ED regarding additional requests, including temporarily waiving Selective Service requirements and the flexibility for schools to accept signed statements from nonfilers who are unable to obtain W-2 forms from their employers. 

Need Analysis

The EA states that any aid received by victims of an emergency by either a federal or state entity for purposes of providing financial relief will not be counted as income for the calculation of Expected Family Contribution (EFC) or estimated financial assistance (EFA). This would apply to any funds a student will receive from a stimulus check and/or funds a student will receive from the CARES Act Economic Stabilization Fund — the fund to provide emergency grant aid dollars to institutions and students. The same exemption from income is not provided for institutional emergency funds. 

Distance Education

The March 5 guidance allowed institutions flexibility with regard to securing approval to offer distance education. While some institutions would normally have to go through an approval process with ED to use or expand distance learning programs, ED provided “broad approval” to accommodate students “on a temporary basis” without going through that process. In the April 3 guidance, ED further clarifies that this flexibility only pertains to payment periods that overlap with the March 5 guidance, or that begin on or between March 5 and June 1, 2020. 

Schools that want to continue offering distance education with a payment period that starts after June 1, 2020 may need to obtain ED approval and comply with the accrediting agency’s policies, although accreditors may waive distance education review requirements. 

The EA implements the portion of the CARES Act that permits an otherwise eligible program at a foreign school that participated in the Direct Loan (DL) program to be offered via distance education if the government in that country has declared a public health emergency, major disaster or emergency, or national emergency related to COVID-19. This flexibility is retroactive to March 1 for the duration of the emergency and the following payment period. Note that “foreign schools” are those institutions located outside of the United States that participate in the DL program and award their credentials to U.S. students enrolled directly at the foreign school. This term excludes study abroad programs in which a foreign institution provides instruction to a student who is a degree-seeking student at a domestic U.S. institution. Students in this category have always been permitted to engage in distance learning.

Foreign schools may enter into written agreements with U.S. schools that participate in the DL program for the purpose of allowing a student borrower enrolled at the foreign school to take courses from an American school, with limitations. 

ED encourages schools to review recent “FERPA and virtual learning related resources” guidance to ensure they are in compliance. 

The new guidance also reminds institutions as they create online programs where they may have not existed before, about the importance of the need to work to accommodate students with disabilities in a distance education environment. As standard in-person methods of teaching may no longer be available, it's crucial for institutions to ensure that students with disabilities have an equal opportunity to access educational programs. 

General Provisions

For institutions adjusting the length of their academic years due to COVID-19, ED reiterates guidance from March 5 and adds instructions for schools to follow when requesting a temporary reduction in the length of an academic year to less than 30 weeks. Institutions should send an email to [email protected] (note this is a process change from previous EAs) to request a temporary reduction in the length of the academic year. Included in their email request, institutions must establish the “program or programs for which the institution is requesting a reduction and the updated instruction time for those program(s)” and “demonstrate “good cause” for the reductions” (i.e. prove they are COVID-related). Institutions may request a waiver for all education programs. 

For institutions that make the decision to temporarily close because of COVID-19 related disruptions, ED has ensured that this closure will not result in the loss of institutional eligibility. 

Related to the Clery Act, ED does not interpret the law to require that institutions provide regular updates about the COVID-19 pandemic or identify any confirmed cases of COVID-19 on their campus. To meet the requirements of the emergency notification provision of the Clery Act, institutions may give students and employees a single notification through regular means of institution-wide communication from credited sources about the pandemic or create a banner on the school’s homepage that displays the same information. 

For institutions unable to comply with cash management requirements because of the ongoing COVID-19 pandemic, they should ensure that they are documenting the requirements they are unable to complete, including the reasons why they are unable to comply. 

The EA also allows institutions and commercial lenders that service Perkins Loans to extend the same zero percent interest and cessation of payment benefits being offered on federally-held loans on a voluntary basis to borrowers for six months. For the same period, ED also authorizes schools the option to grant, at a maximum, a three-month forbearance on Perkins Loans for borrowers who are unable to make payments due to a COVID-19 interruption. 

Under normal operating conditions, ED does not allow institutions to approve a leave of absence (LOA) for students during the suspension of coursework, clinicals or internships. Due to the COVID-19 pandemic, ED has reversed that rule, allowing Title IV-approved LOAs for students until the institution can resume any suspended coursework or find alternate clinical or internship placements. This is in addition to the guidance already released by ED on March 5th that allows students to take an approved LOA even if the student notifies the schools after the LOA has begun. The CARES Act also allows schools to provide students with an approved LOA that does not require the student to return at the same point in the academic program that they began the LOA, if the student returns in the same semester. 

As guidance continues to be released, NASFAA in agreement with ED, “recommends that institutions document in their records, as contemporaneously as possible, any actions taken as a result of COVID-19”, including those actions described in the EA. 

NASFAA has ongoing conversations with ED and asks that if your institution has a scenario not addressed in any of the guidance released by ED or answered in NASFAA’s AskRegs Knowledgebase thus far to please email [email protected]. All COVID-19-related AskRegs Q&As  are also posted on NASFAA’s COVID-19 Web Center, where you can stay up to date with all of NASFAA’s COVID-19 resources. 

Additionally, ED noted it has created a website with information and guidance for schools with regard to the coronavirus and said additional questions may be sent to [email protected]. ED states that they are currently reviewing the implications of the CARES Act and will provide appropriate guidance as soon as possible.

Additional Guidance Forthcoming

The Department did not address several items within the CARES Act that require ED implementation, including R2T4, and additional flexibilities related to FSEOG and Standard Academic Progress (SAP). In addition, NASFAA has several outstanding questions yet to be answered by ED. NASFAA has been assured that ED staff are working as quickly as possible to distribute new funding, provide answers to unanswered questions, and issue additional guidance.


Publication Date: 4/4/2020

Brenda M | 5/4/2020 1:58:36 PM

For proof of graduation, are we accepting self certification for this or do we need the high school transcript or copy of diploma for 2019/20 and is this the same requirement for 2020/21?


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