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The Department of Education has added an FAQ to its Electronic Announcement that outlines instructions for schools to comply with Title IV, Higher Education Act policies for students whose educations are impacted by COVID-19. The document addresses questions around Federal Work-Study, study abroad programs, and spring break as it relates to the Return to Title IV (R2T4) regulations, among others.

Room and Board Considerations

The FAQ also addresses a common question as many schools consider issuing full or partial refunds for room and board for the spring 2020 term. It states:

Q: We are planning to close our dormitories as a result of the COVID-19 outbreak. If an institution provides a refund for a portion of the costs for a student’s room and board as a result of the outbreak, does the institution need to adjust student budgets? Do we also need to consider the difference in costs for students who must relocate to off-campus housing? What if we provide a partial refund of tuition and fees?

A: No. If, as a result of the COVID-19 outbreak, you provide a refund or waiver of expenses for all or part of a student’s tuition, fees, room and board charges, or other institutional charges, or if you become aware that a student has moved off campus for the remainder of the term, the Department will not require a re-evaluation of the student’s cost of attendance. Therefore, you are not required to make changes to a student’s Title IV awards on the basis of such changes.

It is important to note that the above situation could result in a Title IV credit balance. This occurs when Title IV funds credited to a student’s account exceed the amount assessed the student for allowable charges associated with a payment period. ED has not waived the rules on Title IV credit balances, so institutions will need to continue to follow those regulations. Even if a school has authorization from a student to hold a Title IV balance, the funds must ultimately be paid to the student by the end of the loan period if the balance is the result of Title IV loans, or by the end of the last payment period in the award year if the balance is the result of other remaining Title IV program funds.

As lawmakers consider economic relief packages, there could be additional action on Title IV provisions. NACUBO will continue to report on updates for business officers.

Other COVID-19 Resources

NACUBO continues to update its coronavirus resources for college and university business officers.

The National Association of Student Financial Aid Administrators (NASFAA) also has a number of COVID-19 Title IV resources. An on-demand webinar, including a transcript of questions and answers, is available for free. In addition, NASFAA has scheduled a free follow-up webinar on COVID-19 on April 2.


Bryan Dickson

Director, Student Financial Services and Educational Programs


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