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Education Department Provides COVID-19 Update

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As the impact of COVID-19 (coronavirus) continues to evolve, we will be sharing resources to help you navigate this unprecedented situation.

The United States Education Department (ED) has published a memo with guidance for interruptions of study related to COVID-19 (coronavirus). You can read the memo here. We’ve summarized these key practical steps for your institution to consider:

  • If you have moved learning to an online platform or distance education platform, please document the dates covered and how you’ve determined participation in the course. This may include gathering email instructions from professors. It will be easier to gather information now than at the end of the semester or during an audit timeframe.
  • If a student withdraws, use the last known academic activity. Most online activity can be tracked and is the most accurate data point. Logging into an online class is not sufficient by itself to demonstrate attendance. Examples of acceptable evidence of academic attendance include:
    • Student submission of an academic assignment,
    • Student submission of an exam,
    • Documented student participation in an interactive tutorial or computer-assisted instruction,
    • A posting by the student showing the student’s participation in an online study group that is assigned by the institution,
    • A posting by the student in a discussion forum showing the student’s participation in an online discussion about academic matters, and
    • An email from the student or other documentation showing that the student initiated contact with a faculty member to ask a question about the academic subject studied in the course.
  • If changes are made to Title IV (R2T4) calculations because additional information becomes known after the initial R2T4 is completed, the change is not considered a correction. An institution is never required to do a recalculation of a change that is not a correction. See page 5-40 of the 2018-2019 Federal Student Aid Handbook.
  • If you are reporting National Student Loan Data System (NSLDS) data the same as the prior period due to COVID-19, please document which reporting period(s) that is covering.
  • Federal Work-Study allows for institutions to continue paying students after the beginning of a term if the institution or employer closes and:
    • The institution is continuing to pay its faculty and staff, and
    • The institution continues to meet its institutional wage share requirement.
    • Also note that instead of documenting hours worked, since there wouldn’t be any, it is important to clearly label documentation to note COVID-19 disruption.
  • Financial aid administrators can use professional judgment in determining Cost of Attendance/Expected Family Contribution (COA/EFC) on a case-by-case basis. This needs to be clearly documented in the respective student’s file.
  • Permission will be granted for distance-learning students who wish to receive a leave of absence related to COVID-19 concerns to do so. Institutions will not have to perform a return of R2T4 calculations if the student returns within 180 days.

Given the rapidly evolving situation, we will be providing information as quickly as possible. Watch for additional email alerts on COVID-19 considerations, updates on developing events, and recommendations for managing the impact. Please also check the ED COVID-19 page frequently, as the situation is changing daily.

Please do not hesitate to reach out to your engagement team or contact us with any questions. Our entire workforce is equipped and trained to work remotely, and we are here to help.

Dan Campbell, Partner
Higher Education Services Director
dcampbell@capinrouse.com

Lisa Saul, Partner
Uniform Guidance Director
lsaul@capincrouse.com

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