Trending AskRegs Q&A: Does the R2T4 Waiver to Not Return Unearned Funds Really Only Apply to Payment Periods That Include March 13, 2020?

Does the R2T4 Waiver To Not Return Unearned Funds Really Only Apply To Payment Periods That Include March 13, 2020?

Scenario: The school has quarters, terms, and nonterm payment periods that start after March 13, 2020.

Answer: Yes. Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), neither the student nor the school is required to return unearned Title IV funds resulting from the return of Title IV funds (R2T4) calculation when the student's withdrawal was related to the COVID-19 qualifying emergency. The May 15, 2020 Electronic Announcement narrowly defines the payment period or period of enrollment to which this CARES Act waiver applies — that is only a payment period or period of enrollment that begins on or includes March 13, 2020.

If the payment period/period of enrollment does not include March 13, 2020 (for example, a nonterm payment period or quarter that starts after March 13), regular R2T4 rules apply, and unearned Title IV aid must be returned under 34 CFR 668.22. The CARES Act waiver does not apply to these students, unfortunately.

We are reaching out to the U.S. Department of Education (ED) in hopes of relaxing the May 15th Electronic Announcement language to include subsequent terms or payment periods. We don't quite understand why ED took such a narrow approach. For now, you have to follow the guidance in the Electronic Announcement.

If we receive updated guidance, we will update an AskRegs Knowledgebase Q&A and post it in our Coronavirus (COVID-19) Web Center and in Today's News.

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Publication Date: 5/19/2020

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