The U.S. Education Department (ED) is giving colleges and universities flexibility on financial aid requirements in response to the coronavirus (COVID-19).
A March 5 directive from ED’s Office of Postsecondary Education responds to concerns from college leaders about how they should comply with federal Title IV regulations regarding students who are ill or quarantined, recalled from travel-abroad experiences or can no longer attend classes, internships or clinical rotations due to the coronavirus.
Distance learning
ED has loosened the requirements for distance education to accommodate students if their campus has temporarily closed or their study-abroad program is canceled. In these instances, colleges can “use online technologies to accommodate students on a temporary basis, without going through the regular approval process,” the department’s memo states.
The flexibility only applies if a payment period overlaps the date of the announcement or the following payment period, ED says. After that, institutions must seek approval under the department’s normal process.
The department is also permitting accreditors to waive their distance education review requirements for institutions where student enrollment is interrupted as a result of coronavirus.
The memo also clarifies that for Title IV purposes, distance learning does not require the use of sophisticated learning management systems or online platforms – but it does require instructors to “initiate substantive communication with students.” An instructor could use email to provide instructional materials, use chat features to communicate with students, set up conference calls to facilitate group conversations, and require students to submit work electronically.
Institutions may also enter into temporary consortium agreements to allow students to complete courses at other institutions.
In cases where accrediting agencies require students to complete a final number or percentage of credits in residence at the institution, ED will allow accreditors to waive that requirement for students affected by COVID-19.
Title IV funds
ED is allowing students to take an approved leave of absence for COVID-19 even if the student notifies the institution in writing after the leave of absence has begun.
In that case, the college may retain Title IV funds for when the student continues enrollment. If the student does not return within 180 days, the school would be expected to perform the “return of Title IV funds calculation” based on the date when the leave-of-absence began.
Students unable to complete travel abroad or experiential learning opportunities could be offered courses on a schedule “that would otherwise be considered a non-standard term, if doing so enables those students to complete the term,” the department says.
Work-Study payments
ED is also allowing more flexibility in the Federal Work-Study program if the campus or employer closes as a result of COVID-19.
“The institution may continue paying the student federal work-study wages during that closure if it occurred after the beginning of the term, the institution is continuing to pay its other employees (including faculty and staff) and the institution continues to meet its institutional wage share requirement,” the memo says.
Schools that close due to a health emergency can request a temporary reduction in the length of their academic year.
In addition, ED advises higher education leaders that financial aid administrators have statutory authority to use professional judgment to make adjustments on a case-by-case basis for students affected by the coronavirus.
In cases where students already traveled abroad but couldn’t begin classes because of coronavirus outbreaks, ED requires the institution to “return all Title IV grant funds disbursed for the payment period or period of enrollment and all Direct Loan funds that were credited to the student’s account at the institution for that period.”
According to the memo, an institution must comply with the rules on the return of Title IV funds for students who withdraw, even if the withdrawal results from a COVID-19 disruption. The guidance from ED includes instructions for calculating the withdrawal date.
The department has set up a page on its website for updates related to the coronavirus.
