BEST PRACTICES FOR USING THE CORONAVIRUS INDICATOR

It seems the Coronavirus Indicator might have a bit of a “hair-trigger” because FSA recently put out a document of best practices for using the checkbox which opened with a word of caution.

It read, “ Because a number of events (e.g., loan discharges, usage and eligibility limits) are triggered once the Coronavirus Indicator is selected, and the Coronavirus Indicator cannot be reversed by a school, it is critical that schools only submit the Coronavirus Indicator when no other action is expected to be taken on the disbursement”.

It then went on to say, “To prevent unintended consequences…” Sheesh.

Read this. Print it out. Stick it on your wall. Refer to it as needed.

Whatever you do, don’t click the box unless you really mean it.

Don’t say I didn’t warn you!

RECENT COD SYSTEM CHANGES FOR CARES ACT

Last month the Common Origination and Disbursement (COD) System was updated to support reporting requirements for withdrawn students who qualify for a Title IV waiver under the Cares Act. COD now allows schools to select the Coronavirus Indicator on eligible disbursements for any program with an award year beginning in 2017-2018 or later. The R2T4 calculator on the COD website has also been updated with the Coronavirus Indicator checkbox for the 2017-2018 award year. Valid Payment Period Start Dates for the Coronavirus Indicator can now go back as far as January 1, 2018. Good news for schools with unusually long academic years, or situations that would have extended the academic year like Leaves of Absence or Withdrawals and subsequent Re-entry into a program.

UPDATED DEADLINES FOR FLEXIBILITIES RELATED TO CORONAVIRUS

Last week the New York Times reported that there are presently over 26,000 cases and at least 64 deaths on College and University campuses from COVID-19 since the start of the Fall Semester.

Sadly, COVID-19 continues its slow burn through our country and ED’s Office of Postsecondary Education released updated deadlines for previously announced flexibilities related to COVID-19.

 

Campus Based Matching Requirements – The institutional share (match) requirement associated with the Federal Work-Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) programs for the 2019-2020 and 2020-2021 award years has been waived for public and private non-profit institutions.

 

Leave of Absence – Students on an approved title iv leave of absence may continue beyond the usual maximum 180-day timeframe and may now stay on a LOA until the end of the calendar year.

 

Return of Title IV Funds – Institutions are no longer required to return unearned Title IV funds for any student who withdrew last spring, summer or this fall because of COVID-19. ED caps the date of this flexibility at the later of December 31, 2020 or when the national emergency ends (if it ends later).

 

Academic Calendars – Prior guidance granting institutions flexibility to adjust their academic calendar have been extended to the end of the program’s academic year.

 

Reporting and Audit Requirements – Financial Statement and Compliance Audit Deadlines have been extended by six months from the date they would otherwise be due.

ADDITIONAL REGULATORY FLEXIBILITIES RELATED TO CORONAVIRUS

ED’s Office of Postsecondary Education announced several deadline extensions because of COVID-19 including extensions to Campus Crime, Annual Security Reports, Annual Fire Safety Reports, Equity In Athletics Disclosures and the 20-21 FISAP.

The deadline to for institutions to distribute their Annual Security Reports and Annual Fire Safety Reports has been extended until December 31, 2020. Additionally, the annual crime and fire statistics survey will now be open from November 18, 2020 through January 14, 2021. If you need assistance with the survey, please call the Campus Safety Help Desk at 1-800-435-5985 or by email at campussafetyhelp@westat.com.

The deadline to for institutions to distribute their annual Equity in Athletics Disclosures in compliance with the Equity in Athletics Disclosure Act (EADA) disclosures to required recipients to December 31, 2020. Additionally, the online EADA Survey will now open from December 2, 2020 through January 28, 2021. If you need assistance with the survey, please contact the EADA Help Desk at 1-888-233-5421 or via email at eadahelp@westat.com.

The deadline to for institutions to submit the 2020-2021 FISAP has been extended to November 2, 2020. The December 15, 2020 deadline for submission of FISAP edit corrections and the Perkins Cash on Hand Update remains unchanged.

INCREASE IN PROFESSIONAL JUDGMENT USE DUE TO COVID-19

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With unemployment insurance ending for millions of people this month, financial aid offices around the country have been inundated with requests for financial aid appeals. Earlier this year the Department released guidance encouraging financial aid administrators “use professional judgment to reflect more accurately the financial need of students and families affected by the COVID-19 pandemic. A short while later ED removed references to GEN-0904 and GEN-0905 from the 20-21 FSA Handbook and indicated that the guidance in those Dear Colleague Letters has been archived for historical purposes only and is no longer considered active. For what it is worth…they issued some reassurance that they will not view increased use of professional judgment negatively or use it as a selection criteria for a program review.