Financial Aid Q & A with US Department of Education

Financial Aid Q & A with US Department of Education

NC Community College System Office

Coronavirus and financial aid questions

Responses provided by US Department of Education


(updated March 27-29, 2020)


The electronic announcement from March 5th hand language that said the following:

The impact may be magnified if the institution accommodates students by providing alternative instructional opportunities and the student is required to continue paying tuition, but the student loses FWS as an important part of their financial aid award. For students enrolled and performing FWS at a campus that must close due to COVID-19, or for a FWS student who is employed by an employer that 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.

QUESTION: What do we do if our campus is not "closing", but moving everything to online courses.  Therefore, the students are basically not allowed on campus, but since the college did not "close" I'm not sure that we meet the criteria to continue paying them FWS funds.  Any help or guidance we can get about that would be appreciated.

RESPONSE: Using the flexibility is contingent upon the FWS recipient being unable to complete his or her work obligation as a result of a COVID-19 circumstance. You may pay students FWS who are unable to work because they are now attending online.


QUESTION: For any addendums to policies and procedures due to COVID-19, I have been using a start date of 3/16/2020 on these addendums in order to ensure we are aware of when these procedural changes occurred. I have used this date because that is the date our college reassessed our situation to determine what changes were needed to accommodate COVID-19. Since we received dated guidance on 3/5/2020 of adjustments that could be made, can I instead use the date of 3/5/2020 or would it be best to stick with 3/16/2020?

RESPONSE: This is a matter of institutional discretion. The flexibility extends to all payment periods that begin on or between March 5 and June 1, 2020, so either date will work and be compliant.


QUESTION: We received guidance this week that a possibility for our students that may choose to withdraw is: Withdrawal and application of tuition to a future term.

I wanted to make sure I am interpreting this correctly. If this situation occurs, students would withdraw from their classes for this semester be subject to R2T4 guidelines. If the student chose to return in the Fall 2020 semester, the student could register for the class withdrawn, and not pay tuition and fees for that class, correct?

RESPONSE:  What an institution refunds or charges students is outside of the Department’s purview. Schools may certainly allow students to return in fall and reenroll in classes from which they withdrew without charge. This could be accomplished in one of two ways. The first option would be to not charge at all, the cost for the course(s).  In that case the cost of the course(s) must be excluded from the tuition and fee component of the COA. The other option is to charge for the courses but then apply a voucher or waiver to the student’s account. The amount of the voucher or waiver would be considered EFA.

QUESTION: If yes, it would be my assumption that the tuition and fees would not be prorated because the student would have to take the entire class again.

RESPONSE:   That is an institutional decision.


QUESTION: So, if the tuition and fees for a 3-hour class is $270.20, the student would receive a full $270.20 credit on their Fall 2020 tuition and fees statement, correct?

RESPONSE:   Again, this is up to each institution.


QUESTION: I say the student would receive a credit because there is always the possibility that tuition and fees could increase for the Fall 2020 semester so it may not necessarily be a wash out for the student.

RESPONSE:   As explained above, any credit, voucher, waiver etc. applied to the student’s ledger account for next year’s charges is considered EFA.


QUESTION:  Because the student was withdrawn for the Spring 2020 semester and subjected to R2T4 guidelines, would I still be able to award the student financial aid for the class during the Fall 2020 semester, even though there is a possibility the student will not be charged any tuition and fees for the class?

RESPONSE: Yes. The amount of tuition charged has no bearing on whether the student is eligible to receive aid. Even if there was no tuition charge, the other elements of the COA would exist. It will, of course, potentially affect the student’s financial aid package, i.e., lower costs could lead to less need and/or being eligible for lesser amounts of aid.

QUESTION: In regard to R2T4's for the COVID-19. We have some programs that are looking to assign students "Incompletes" for their classes, i.e. Cosmetology.
Would the incomplete constitute an R2T4 since the student will no longer be attending the class for longer than 14 days?

RESPONSE:  Incomplete grades for all classes may not be used as an alternative to considering a student to be withdrawn.  The 14-day rule is not a factor here, as there is no doubt as to the last day of attendance and withdrawal date/date of determination. Institutions have 30 days from the date of determination to perform the calculation and 45 days to return funds. That clock begins as of the cessation of classes. It is possible to sort of “hold things in abeyance” for that time, but if classes do not resume, students must be considered withdrawn and funds returned. Assigning incomplete grades will not change this. It is far more practical to put all students on an approved LOA (that is, if the school fully expects classes to resume within 180 days). This provides far more flexibility, and our COVID-19 guidance allows schools to do this for all students even when classes are not being conducted.

QUESTION:  If yes, this would be similar to how we handle an "F" grade, correct?  So, the student would still have an "I" for their grade, but we would have to consider them withdrawn from the class because they would not be in attendance in the class for longer than a 14-day period.

RESPONSE:  See above

QUESTION: If we are able to constitute an appropriate Leave of Absence for the student, I understand the student has 180 days to complete the assignment for the class. 

RESPONSE:  An approved LOA is not an incomplete. Accordingly, it is not a time period for students to finish work which they then turn in to have the period of enrollment considered complete. With an approved LOA, there is the presumption that the student come back at a certain point and resume classes at the point he or she left off. Thus, the period of enrollment is competed. If the student does not return, he or she must be treated as a withdrawal. A LOA cannot be used to shorten the academic year or the length of classes.


QUESTION:  Would it be best to still assign the student an "I" in the course?   If yes, in this situation, if the student has a legitimate leave of absence, the "I" grade would not be treated as a withdrawal.

RESPONSE:  An approved LOA is not an incomplete. Accordingly, it is not a time period for students to finish work which they then turn in to have the period of enrollment considered complete. With an approved LOA, there is the presumption that the student come back at a certain point and resume classes at the point he or she left off. Thus, the period of enrollment is competed. If the student does not return, he or she must be treated as a withdrawal. A LOA cannot be used to shorten the academic year or the length of classes.


QUESTION:  I know the FWS community waiver for 2020-2021 waiver is open at this time and due by 4/20/2020. We, at Mayland, have been blessed with the opportunity to fill this position in years past and haven’t required a waiver.  However, I worry that given the current circumstances, if this will be more difficult this go around. I wonder, would it be possible that the deadline will be extended on the waiver until we can better know if this will become an issue for us?

RESPONSE: There is no extension at this time.  It might be better to apply for the waiver. There is no problem if you do end up fulfilling the community service expenditure requirement.

QUESTION:  If the extra week of break took our academic year from 32 weeks to 31 weeks, do we need to seek Ed approval, or as long as we stay at least 30 weeks, is this okay without School Participation Team approval?



QUESTION:  My understanding is that we are to pay FWS students based on their scheduled hours. I understand scheduled hours to be the hours the student agreed to work on their FWS contract. If this is the case, what happens if a College over expends their FWS allocation for the year? This could easily happen especially with a college that matches FWS. Please Advise.

RESPONSE: As you are aware, Campus-Based allocations consist of a fixed amount of funding. The current situation has not changed that. You can only pay scheduled hours up to the point your funding allows. It may not be possible to pay all students.



(updated March 25, 2020)


QUESTION: I learned yesterday that our college will treat the additional spring break week as "inclement weather days". If this is the case, David Bartnicki has advised in the past NOT to exclude those dates for R2T4 based on referring to those days as inclement weather days. Please Advise.

RESPONSE: The additional days will have to be added to your spring break and excluded from the calculation.  Please be aware that we are currently providing guidance based on a national emergency situation, which may differ from guidance that took place in a different context


QUESTION: If we extended spring break but the semester will still end as previously stated, meaning no expansion, do we need to get permission from DOE?

RESPONSE: Only if the revised academic year is less than 30 weeks in length.


QUESTION: What is the anticipated to DOE R2T4 Relief?

RESPONSE: This will require legislation signed into law by the President. When and if this occurs, we will notify schools.

QUESTION: Has guidance regarding RT24 been included in the Stimulus Bill? 

RESPONSE: There is language related to R2T4 in the bill.


QUESTION: NASFAA said last week that extending the break but not the end date equaled shortening the term which requires Ed School Participation team approval. Does the college need approval from DOE?

RESPONSE: Again, you need our permission only if the number of weeks in the academic year is below 30.


QUESTION: The fact that some students have to work to get paid and others do not seem unfair? Can we make sure that answer is correct?

RESPONSE: It is not our intent to be unfair.  The flexibility allows—but does not require--paying students who are prohibited from working, based on scheduled hours. Given the nature of this emergency, we provided the school discretion as to whether a student is reasonably prohibited from working. While it may be physically possible for the student to get to campus, it may not be reasonably possible given the health risks, or restrictions on movement imposed by local and state authorities.  The more difficult question involves the status of those students able to perform job tasks remotely via telework. Such a student is, arguably, not prohibited from working; this is not suggesting that we are requiring schools to set up telework capabilities where they did not exist. Although it may seem unfair, we cannot advise schools to pay students for not working when there is no real reason they could not work simply as a matter fairness because others are not having to perform labor for their compensation. If such a student were to become ill or have to care for someone who is, this could be a circumstance prohibiting him or her from working.


QUESTION: How are we going forth with paying our work study during this pandemic? Can we accept email signatures form from students and supervisors as wet signature?

RESPONSE: Yes, if you have no cause to doubt the veracity of the signature.


QUESTION: If we have to extend the end date of the term due to COVID-19, do we have to go back & redo R2T4s that were completed beforehand?



QUESTION: We have classes that fall into three categories now…those that only had one week of spring break extended due to COVID-19, those that were extended three weeks and we have some classes that are suspended until they can come back to campus. If you have a student in all three classes, how are we to treat the R2T4 if they withdraw?

RESPONSE: The denominator of the calculation for each student should include the number of days that student was scheduled to attend. Remember that scheduled breaks of five days or more are excluded from both the numerator and the denominator. The number of scheduled break days will depend on what the break was when the student withdrew.


(updated March 20, 2020)


QUESTION: We do not have an online portal for students to complete documents via a computer. All students print sign and then email / fax or complete in person. Without a portal or doc-e-sign, is there any guidance on how to complete these documents currently? And same for V4/V5. What if someone cannot get to a notary?

RESPONSE: We expect to release additional guidance regarding verification shortly. Please continue to monitor IFAP for the release of FAQs.


QUESTION: Our college extended Spring break for an extra week. Do we have to go back and redo R2T4 calculations already completed with the new total days in the semeste



QUESTION: Can schools that have NOT closed, but have transitioned classes to online discontinue work-study students coming to campus to work, but pay them for hours they were scheduled to work?



QUESTION: Many colleges extended spring break for their students; will we need to exclude those days for R2TR purposes for students who withdraw during or after that period.



QUESTION: I understand that schools may need to get permission from DOE School participation team when shortening term dates, but do we also need permission if we extend terms dates (for example moving from 16 weeks of instruction to 17 weeks)?

RESPONSE: No permission is needed to extend the academic year. Any resulting overlap with the summer term as a result of extending the spring term will be permitted and not result in the program becoming non-term. Your standard terms will remain standard.


QUESTION: If the school closes, will we have to complete RT24 on all students?

RESPONSE: Yes. R2T4 is a statutory requirement.


QUESTION: Do we need to exclude additional break days from the number of days in the period of enrollment, if it is expected that the time will be made up through an online modality?

RESPONSE: Yes. It might end up being a wash if you add those days onto the term at the end. But any scheduled break of five days or more must be excluded.


QUESTION: If our courses transition to primarily an online environment will students still be allowed to do work study?



QUESTION: If students are not allowed to return to campus once the campus reopens, can we continue to pay work-study students based on their expected hours to work?



QUESTION: We have work study students that aren't able to work because our school is closed to students. We plan to pay those students. We, however, have students that have jobs off campus, and those places aren't closed. Are they required to work, even those the others aren't?

RESPONSE: Yes. If those jobs continue to exist and the places of employment remain open, students should continue to work scheduled hours, submit time sheets, and be compensated accordingly.


QUESTION: While NASFAA got clarification from ED about FWS and moving classes online, our administration doesn’t feel like this adequately answered our situation. We are a community college where no students live on campus. We are transitioning to offering all classes online beginning next Monday. However, our college services, like Financial Aid office, Admissions office, etc., are still open to the public. Do students who are working in these offices get to stay home and get paid as it seems to state in the guidance below OR must they report as usual to work if they wish to be paid during this time that we are offering instruction online?

RESPONSE: In the case of students employed in campus operations that remain open (understanding that all students are reasonably local and none reside on campus) it is up to the institution (as the employer) whether these FWS positions are still active and whether, given the circumstances, students are reasonably able to perform their work responsibilities. If it is determined by the institution that students should not be on campus for any reason, including performing work activities, then students are considered unable to work due to the emergency and you may pay scheduled FWS.


QUESTION: Trending Ask Regs Q & A: Can Students Be Paid FWS When the School Does Not Close, Sends All Students Home, and Moves All Classes Online Due to Coronavirus?

RESPONSE: Yes. According to guidance NASFAA has received from the U.S. Department of Education (ED), the March 5, 2020 Electronic Announcement guidance under the "Federal Work-Study  (FWS)" heading applies in instances when the school closes (temporarily ceases to offer instruction in any format for the remainder of the payment period) and when the school does not close, sends all students home, and moves all classes to an online format via distance education for the remainder of the payment period. In fact, the FWS guidance applies in any scenario when the student is unable to continue an FWS job due to classes being moved to a distance education format as a result of a decision made by the school.

The FWS guidance in the Electronic Announcement only applies when the student is unable to work because the school made the decision to close or to move to online/distance education classes; it does not apply to students who decide for themselves to leave campus and/or switch to online classes. These students are not eligible to be paid FWS for any hours they do not actually work.

According to ED, the student can be paid for the FWS hours he, she, or they were scheduled to work for the term or nonterm period. Per ED, the school can have the student submit a timesheet for the hours he or she was scheduled to work and pay FWS wages based on that. Beyond that, ED's guidance is silent on how and when the school will pay these students, so it is the school's decision to make. Publication Date: 3/13/2020


QUESTION: With many of us going to working remotely and relying on email, I am concerned about receipt of tax documents and the verification process. If our school does not have a method of providing us a secure email, is it permissible to have students line through or remove any personal identifiable information (PII) from these documents and then email them to us?

RESPONSE: Verification documents without PII would not serve the purpose of collecting those documents. However, we understand the situation you describe and are working on additional guidance related to verification. Please monitor IFAP for issuance of FAQs on this topic.


QUESTION: If we did not offer a summer term, will this affect financial aid in any way?

RESPONSE: Other than that, you would not be able to package aid or disburse for that term, no.


QUESTION: I would greatly appreciate some guidance on adjusting term dates in Datatel due to campus closures, scheduled break changes, adding additional breaks, and adding weeks to current term. I would like to know the effect of the change in scheduled breaks, campus closures, and added weeks to term on R2T4 calculations done before the changes and those processed after changes to term dates are made. Need more specific guidance as to which set of dates will apply to a specific R2T4 based on the Withdrawal Determination date versus when the actual R2T4 process is completed.

RESPONSE: This is a little too all-encompassing to address in a Q/A.  Any scheduled break of five (5) days or more must be excluded from both the numerator and denominator of an R2T4calculation. If a campus closes and all instruction ceases, students are considered withdrawn and R2T4 calculations are necessary for all students. However, schools do have 30 days from the date of determination to perform a calculation and 45 days to return funds. If the school expects to restart classes within those timeframes it could delay processing for that time period. If an R2T4 is affected and students later return to the payment period, the calculation could be undone and aid restored. Adding weeks to a term in order to make up for missed weeks of instruction is allowed. There is no need to be concerned with any resulting overlap of standard terms.

(Questions regarding dates in Colleague should be sent to the NCCCS Help Desk. -W. White)


QUESTION: On the Presidents Council call with the System Office on 3/17/20, all colleges were told to "wind down" classes requiring physical contact such as BLET, Cosmetology, Nursing, etc. What happens to students who received financial aid who will not be able to complete the course(s), if the classes are ended by being wound down?

RESPONSE: If it is not possible to continue those programs in distance format, students in these programs must be considered withdrawn.


QUESTION: If the college extends spring semester into summer semester, will students be eligible for summer Pell?

RESPONSE: Yes. An overlap of spring and summer terms (ordinarily not permitted) will not result in the program being considered non-term. Students attending the summer term who have Pell eligibility would receive disbursements for that term as they normally would. If SAP for spring cannot be assessed prior to the start of the summer term because the spring term is still running and students who will attend summer are enrolled for spring, all of the spring classes for those students should be assessed according to the school’s SAP policy on in-completes which every institution is expected to have.


QUESTION: What happens when face-to-face courses move online and the student decides they cannot do the course online? Can they withdraw with no FA penalty?

RESPONSE: No. if courses continue online and a student decides that he or she will not participate in that format, the student must be withdrawn and an R2T4 calculation performed.


QUESTION: FWS - It is my understanding we are to base any FWS payments to students based on their scheduled hours and not the average. However, most FWS supervisors were flexible with students on when they work and hours per week in order for their studies to be top priority. In this case, how should we move forward with determining hours to pay while students are not allowed to work their jobs due to COVID-19 closings.

RESPONSE: The Department is not being prescriptive in this area. Institutions are expected to determine scheduled hours in a reasonable manner.


QUESTION: Developmental Education transition courses are numbered less than 100. VA restricts Developmental Education courses up to 100% face to face. Will Veterans now be permitted to participate in these courses when they are moved to online due to the Coronavirus?

RESPONSE: We cannot address questions related to VA educational benefits. Those questions must be directed to VA officials. 


QUESTION: Our institution has elected to extend Spring Break by one week to try and combat the spread of the COVID-19 virus. Since this is an extension of a “break," will I need to make any changes to the R2T4’s I have already processed?



QUESTION: Will I need to change the “school calendar” moving forward? I’m just trying to ascertain what I will need to do, at this point, if anything.

RESPONSE: Any scheduled break of five days or more (including those related to COVID-19) must be excluded.