P&P Builder Template: Early Implementation of New Regulations

The Policies & Procedures (P&P) Builder, a module of NASFAA’s Compliance Engine, guides you step-by-step through the creation of a centralized, accessible policies and procedures manual. Due to the timing of the release of the P&P Builder template each year, the Department of Education (ED) may provide new guidance which affects the existing template. In response, updates will be made to the P&P Builder template. 

The P&P Builder template for the 2020-21 award year was released in August and provides references to guidance related to the COVID-19 national emergency, as well as any regulatory changes effective July 1, 2020. However, since the publication of the P&P Builder template, two Federal Registers with options for early implementation were released, though the regulations will not be effective for all until July 1, 2021. Please see those summarized below:

Federal Register, 8/14/20 – Federal Perkins Loan Program, Federal Work-Study Programs, Federal Supplemental Educational Opportunity Grant Program, Federal Family Education Loan Program, William D. Ford Federal Direct Loan Program, National Direct Student Loan Program, Teacher Education Assistance for College and Higher Education Grant Program, Federal Pell Grant Program, Leveraging Educational Assistance Partnership Program, and Gaining Early Awareness and Readiness for Undergraduate Programs

    • Schools may choose to early implement regulatory changes to 34 CFR 600, 674, 675, 676, 682, 685, 686, 690, 696, and 694 beginning August 14, 2020.
    • These regulations make it possible for members of religious orders who are also pursuing their postsecondary education at receive Title IV aid. Provisions which specified that members of religious orders are considered to be without financial need will be removed from 34 CFR 674.9, 675.9, 676.9, 682.310(a)(2), 685.200, and 690.75.
      • Some borrowers who volunteer with tax-exempt organizations and/or work for employers who engage in religious instruction, worship services, and proselytizing may also now qualify for Public Service Loan Forgiveness (PSLF).
    • These regulations also revise the TEACH Grant Program. This includes clarifying how recipients may satisfy their service obligation, which now includes the ability to do so through educational service agencies which serves low-income students. TEACH Grant recipients may also request a reversal of a voluntary conversion from the grant to a Direct Unsubsidized Loan if the recipient can fulfill their service obligation. Additional information must also be required during initial, subsequent, and exit counseling for TEACH Grant recipients whose grants are converted to loans. The requirement to certify within 120 days of program completion that the grant recipient has begun qualifying service, has also been removed. For more information and analysis from NASFAA on the changes, please see NASFAA’s Today’s News article, “ED Publishes Final Regulations for TEACH Grant Program.”
  • Federal Register, 9/2/20 – Distance Education and Innovation
    • Schools have the option to early implement as of the date of publication of the Federal Register, September 2, 2020.
    • Major changes to note include to return of Title IV funds regulations regarding modules, the expansion of subscription-based models to all types of programs, and satisfactory academic progress.
      • Some changes of note under 668.22 include the fact that a student who has completed all requirements for graduation before completing the days or hours in the period which were scheduled, is no longer considered to have withdrawn. A student enrolled in a program offered in modules also may not be considered withdrawn if the student successfully completes one module that includes 49 percent or more of the number of days in the payment period or a combination of modules which combined, contain 49 percent or more of the number of days in the payment period, excluding scheduled breaks of five or more consecutive days and all days between modules.
    • For a detailed summary of changes, please see the NASFAA’s Today’s News article, “ED Releases Final Regulations Aimed at Restructuring Regulations Related to Distance Education, R2T4 Module Provisions.”  NASFAA’s Compiled Regulations will be updated soon to reflect the changes to regulations.

Check out the  P&P Builder Template Updates and Guidance Changes page to stay informed.


Publication Date: 12/17/2020

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