***Update: On March 20, 2020, the U.S. Department of Education provided updated guidance by adding an FAQ attachment to the March 5, 2020 guidance previously released. Note that this update extends the term of flexibility from being based on students who were already enrolled in a term when the COVID-19 related interruptions occurred to students who enroll in payment periods that begin on or before June 1, 2020. Additional guidance is provided around the topics of Federal Work Study (FWS), study abroad students and foreign institutions, payment periods, institutional charges, withdrawal calculations, COD updates, clock hour programs, and overlapping terms. The Department indicates that they will continue to respond to questions.***
The U.S. Department of Education released guidance for institutions to address compliance with Title IV Higher Education Act (HEA) policies for students receiving federal financial aid whose activities have been affected by COVID-19. Institutions will want to review this guidance for all activities that are subject to Title IV policies and regulations. The Department is providing some short-term flexibility for schools to help students complete the term for which the students are currently enrolled.
Institutions may wish to note some parameters: The flexibility does not generally extend to students who have not yet enrolled or whose term has not yet begun. The Department acknowledges that they will continue to monitor the situation and may provide additional guidance as is deemed necessary. The Department will provide updates on the Department’s Coronavirus webpage.
Guidance is for Federal Financial Aid Compliance
Institutions must remember that this is guidance for Federal compliance. The direction from the Department is in regard to options for institutions that fall under current Departmental statutory authority. The directions are to provide flexibility with Federal compliance for institutions to continue to serve students. Flexibility beyond the Department’s authorization are not possible. For example, this guidance addresses issues that the Department requires for accreditation and for institutional approval to offer online education. Accreditors and state higher education agencies may still require certain additional requirements that are not subject to the rules of the U.S. Department of Education.
The Department strongly recommends that institutions document any actions taken as a result of COVID-19.
Compliance Flexibility to Allow Students to Persist
The goal of the Department is to find ways to accommodate students to continue with their education with as little disruption as is possible.
The Department acknowledges that online education may be a viable option to continue teaching students. In order to provide that option, the Department is offering options that will allow institutions to be flexible but also remain in Federal compliance for purposes of Title IV participation.
Key Areas of flexibility include:
- Approval to offer distance education on a temporary basis.
- Permitting accreditors to waive distance education review requirements, with limitations.
- Institutions may enter into temporary consortium agreements with other institutions so that students can complete courses at other institutions but be awarded credit by their home institution.
- Permitting accrediting agencies to waive the requirement that students complete a final number or percentage of credits in residence at the institution, for students impacted by COVID-19 and without objection by the Department.
- Allowing students to take an approved leave of absence for COVID-19 related concerns or limitations, such as interruption of a travel-abroad program, including direction for managing Title IV funds. Students will be permitted to take such leave, even if the student notifies the institution in writing after the leave of absence has begun.
- An institution may request a temporary reduction in the length of its academic year to close as the result of a campus health emergency, by contacting the School Participation team. The Department is authorized under 34 CFR § 668.3 to approve a reduced academic year.
- Specific direction on enrollment status changes, return of Title IV funds, definition of withdrawal rate, and enrollment reporting.
The Department suggests that if you have further questions that you may email them at: COVIDfirstname.lastname@example.org.
WCET Resources on COVID-19
WCET is working to provide resources and updates related to the virus. Please see our webpage with several resources and recommendations, including:
- A joint statement by WCET, OLC, UPCEA, and Quality Matters (QM) to share resources that address Dissemination of Information and Continuity of Operations to help serve our online community.
- Two videos, to discuss general preparedness, current progression and warnings across the United States, and strategies for messaging students, staff, and faculty as well as moving courses online, financial implications, and compliance concerns. Members can access the videos on YouTube in the 1:1 interview channel.
We urge you to review the Department’s guidance and the available resources. Additionally, regarding the Department’s guidance, institution staff may wish to communicate with the financial aid office to plan and develop questions to share with the National Association of Student Financial Aid Administrators (NASFAA). The NASFAA podcasts “Off the Cuff” are very informative.
This is a difficult and confusing time. We invite your questions and we will reach out to experts for more information and to problem solved. WCET pledges to continue providing updates as they become available.