Can We Have a Policy to Re-Disburse Title IV Aid Only For Withdrawals After March 13, 2020?
Scenario: Our school chooses to execute the return of Title IV funds (R2T4) waiver under Section 3508 of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), but we only want to re-disburse Title IV aid for students who withdrew on or after March 13, 2020?
Answer: Yes. According to guidance NASFAA has received from the U.S. Department of Education (ED), schools have the authority to choose whether to implement the R2T4 waiver for not returning unearned aid under the CARES Act. Schools also have the authority to implement the R2T4 waiver on a case-by-case basis or for broad categories of students. That having been said, ED encourages schools to implement the May 15, 2020 Electronic Announcement guidance consistently to all students in the entire payment period or period of enrollment that includes March 13, 2020, not just those who withdrew after March 13, 2020. There are legitimate reasons why a student might have withdrawn due to COVID-19 before March 13th.
There is an exception. According to ED, if you already returned Title IV funds and have documentation that the withdrawal was not due to COVID-19 (regardless of the date of withdrawal), it is reasonable if you choose not to re-disburse those Title IV funds. Likewise, if you have not yet returned funds and have documentation that the withdrawal is not COVID-19 related (again, regardless of the date of withdrawal), you are not required to apply the R2T4 waiver; you can process the R2T4 as you would under pre-COVID regulation and guidance.
See also AskRegs Knowledgebase Q&A, How Do We Determine If a Withdrawal Was the Result Of a Qualifying Emergency Due To Coronavirus?
While there is no consumer information requirement in the CARES Act or in ED guidance that forces schools to inform students of the school's ability to re-disburse Title IV aid, as a matter of good practice, NASFAA encourages schools to inform students of any policies and actions it takes in this regard.
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Publication Date: 5/21/2020