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The Department of Education has updated its guidance for interruptions of study related to COVID-19 . The April 3 Electronic Announcement (EA) primarily expands on the guidance issued by ED on March 5 and subsequent FAQ.

In the interim, the Coronavirus Aid, Relief, and Economic Security Act was signed into law by President Donald Trump. ED has indicated that further guidance, as it relates to the CARES Act (Return to Title IV, FSEOG, campus-based aid allocations, etc.), is forthcoming.

NACUBO strongly encourages members to read the guidance in its entirety. ED also recommends that “institutions document in their records, as contemporaneously as possible, any actions taken as a result of COVID-19,” including actions described in the guidance.

The emergency flexibilities provided by ED apply to students who already had begun their current term as of March 5, and also to any payment period or term beginning between March 5 and June 1, 2020. ED acknowledges that it may extend the effective period of the guidance.

Accommodating Students

Students may have been recalled from travel abroad programs or experiential learning opportunities after the semester began. ED will allow institutions to offer courses to those students on a schedule that would otherwise cause the program to be considered a non-standard term or a nonterm program, if doing so enables those students to complete the term. If an institution utilizes this flexibility, it can continue to disburse aid based on its original academic calendar. 

Distance Education

ED provides broad approval to institutions to use distance learning without going through the standard approval process. ED notes that this flexibility applies only to payment periods that overlap with the March 5 guidance or that begin on or between March 5 and June 1, 2020. Schools that elect to continue offering a new program or use distance education after that point may be required to obtain approval under the applicable policies of ED and the accrediting agency. 

These distance education flexibilities are different from provisions recently published in proposed distance education rules. ED is currently accepting comments on that draft.

ED also recommends institutions review “FERPA and Virtual Learning Related Resources,” a March 30, 2020 webinar, and related materials from ED’s Student Privacy Policy Office (SPPO).

The guidance also allows institutions to enter into consortium agreements with other Title IV institutions to allow students to complete courses at other institutions while their home institution awards credit. Accrediting agencies may waive requirements for impacted students to complete a final number (or percentage of) credits in residence at the institution without objection from ED.

ED also reminds institutions to consider appropriate accommodations for students with disabilities, noting “whether an institution serves students in a brick-and-mortar or an online environment, the institution must ensure that students with disabilities have an equal opportunity to access educational programs, consistent with protecting the health and safety of the student and those providing that education to the student.”

General Provisions

Single Audits

The Office of Management and Budget (OMB) has extended its due date for submission of single audits to the Federal Audit Clearinghouse. ED has indicated that it will provide additional details on this extension. 

Cash Management

Institutions must comply with the cash management regulations unless unable to do so due to COVID-19 disruptions. If an institution cannot comply, it should document the reasons for instances where it unable to do so and retain the documentation in its records. 

Length of Academic Year

Schools may request a temporary reduction in the length of a term (and thus, an academic year) by emailing to submit the request. The EA provides detailed instructions for these requests. 

Clery Act and Emergency Notifications

ED states that an institution may satisfy the notification requirements of Clery and other reporting regulations by either:

  1. Providing students and employees a single notification through the regular means of communicating emergency notifications informing them about COVID-19 and necessary health and safety precautions, as well as encouraging them to obtain information from health care providers, state authorities, and the CDC, or
  2. Create a banner at the top of the school’s homepage that contains the same information, including a statement about the pandemic and a link to the CDC’s website.

Need Analysis

Aid received by victims of an emergency from a federal or state entity is not counted as income for calculating a family’s Expected Family Contribution (EFC) or as estimated financial assistance (EFA) for packaging purposes. The National Association of Student Financial Aid Administrators interprets this to mean stimulus checks and other CARES Act benefits would not be counted towards EFC or as EFA, while institutional emergency funds would. 

Federal Student Aid Programs

Zero Interest and Suspension of Payments

The CARES Act implemented an automatic forbearance on student loans held by the federal government until September 30, 2020. Interest will not accrue on these loans. 

Under ED’s April 3 guidance, Federal Family Education Loan (FFEL) Program lenders and institutions holding Perkins Loans may provide the same zero-interest and cessation of payments benefit to loans they hold on a voluntary basis.

Other Perkins Provisions

Schools may grant forbearance for up to three months for Perkins borrowers who are unable to make payments due to a COVID-19-related interruption. A borrower may make this request orally or in writing and is not required to submit documentation, though the school must document the forbearance in the student’s file.

An institution may stop collection of defaulted Perkins Loans through September 30, 2020, upon notification by the borrower, a family member, or another reliable source that the borrower has been affected by COVID-19. The institution must document in the loan file why it suspended collection activities and is not required to obtain evidence of the borrower’s status while collection activities have been suspended.

An institution should not treat a scheduled payment the borrower fails to make as a missed payment in the stream of six on-time consecutive, monthly payments required for the borrower to make satisfactory repayment arrangements on a defaulted Perkins Loan and to re-establish their Title IV eligibility.

An institution should not treat a scheduled payment the borrower fails to make as a missed payment in the stream of nine on-time, consecutive payments required for the borrower to rehabilitate the defaulted loan.


Bryan Dickson

Director, Student Financial Services and Educational Programs


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