&29,' dqg )hghudo6wxghqw$lg $v,w6wdqgv€¦ · nasfaa’s webinar covid-19 and federal...
TRANSCRIPT
COVID-19 andFederal Student Aid:
As It StandsJune 12, 2020
© 2010-2020 by National Association of Student Financial Aid Administrators (NASFAA). All rights reserved.
NASFAA has prepared this document for use only by personnel, licensees, and members. The information contained herein is protected by copyright. No part of this document may be reproduced, translated, or transmitted in any form or by any means, electronically or mechanically, without prior written permission from NASFAA.
NASFAA SHALL NOT BE LIABLE FOR TECHNICAL OR EDITORIAL ERRORS OR OMISSIONS CONTAINED HEREIN; NOR FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE FURNISHING, PERFORMANCE, OR USE OF THIS MATERIAL.
This publication contains material related to the federal student aid programs under Title IV of the Higher Education Act and/or Title VII or Title VIII of the Public Health Service Act. While we believe that the information contained herein is accurate and factual, this publication has not been reviewed or approved by the U.S. Department of Education, the Department of Health and Human Services, or the Department of the Interior.
The Free Application for Federal Student Aid (FAFSA®) is a registered trademark of the U.S. Department of Education.
NASFAA reserves the right to revise this document and/or change product features or specifications without advance notice.
June 2020
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 1 COVID-19 & Federal Student Aid Webinar 6/12/2020
National Association of Student Financial Aid Administrators
COVID-19 and Federal Student Aid: As It Stands
June 12, 2020
1
Webinar Housekeeping – Welcome!
• Turn your computer speaker volume up • For technical assistance:
Ø Review the Tech TipsØ Contact us using the Q&A Ø Email [email protected]
• Print your certificate of attendance• Complete the survey
Slide 2 © 2020 NASFAA
2
Speakers
• Justin DraegerØ President & CEO, NASFAA
• Karen McCarthyØ Director of Policy Analysis, NASFAA
• Jill DesjeanØ Policy Analyst, NASFAA
• David FutrellØ Knowledgebase & AskRegs Manager, NASFAA
Slide 3 © 2020 NASFAA
3
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 2 COVID-19 & Federal Student Aid Webinar 6/12/2020
Agenda
• Housekeeping• NASFAA & COVID-19• Scenarios & Hot Topics• ED Timeline• Q&A
Slide 4 © 2020 NASFAA
4
NASFAA & COVID-19 Advocacy• NASFAA created the COVID-19 Web Center to
keep NASFAA members and the financial aid community updated on pertinent news related to the coronavirus.
www.nasfaa.org/covid19Slide 5 © 2020 NASFAA
5
R2T4 Scenarios
Slide 6 © 2020 NASFAA
6
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 3 COVID-19 & Federal Student Aid Webinar 6/12/2020
R2T4 Waiver Under CARES Act
• What is the “R2T4 Waiver?”• The CARES Act waives the requirement for the
school or the student to return Title IV funds when a student withdraws due to COVID-19
• This R2T4 waiver applies to the entire payment period that includes March 13, 2020, even if the student withdrew for COVID reasons before March 13th or before the disruption on campusØ We have confirmed this with the U.S. Department of
Education (ED)• Does not apply to quarters and payment periods
that begin after March 13th
Slide 7 © 2020 NASFAA
7
R2T4 Waiver Under CARES Act
• Schools are not required to implement the R2T4 waiverØ Encouraged because it’s in best interest of students
• Can choose to implement for certain populations of students (e.g., only those who withdrew after March 13th)
• If using the waiver for a subset of students, follow all steps in the May 15, 2020 Electronic Announcement for those students
• Not required to do anything if you already knew the withdrawal was not COVID-related and the R2T4 was already done
Slide 8 © 2020 NASFAA
8
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
• School chooses to implement the R2T4 waiver for the entire payment period including March 13, 2020
• Arya officially withdrew from the spring term on January 20, 2020 before the school moved from ground-based instruction to distance learning due to COVID-19
• School does not require official withdrawals to indicate why they withdrew
• Financial aid office promptly did the R2T4 calculation under normal rules unrelated to COVID-19
• All aid had already disbursed except the spring Direct Loan disbursement
• School already returned school’s and Arya’s unearned aid• Does the R2T4 waiver apply for Arya?
Slide 9 © 2020 NASFAA
9
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 4 COVID-19 & Federal Student Aid Webinar 6/12/2020
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
• It depends on why Arya withdrew• Waiver applies even though she officially
withdrew before the COVID-19 related disruption occurred on campus and before March 13thØ Waiver applies to entire payment period that includes
March 13th
Slide 10 © 2020 NASFAA
10
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
• School does not have to ask why Arya withdrew if during the payment period and due to COVID-19 the school:Ø Moved students from ground-based instruction to
distance learning;Ø Closed campus housing or other campus facilities;
orØ Experienced other interruptions in instruction
• School can assume she was a COVID-19 withdrawal because the school moved from ground-based instruction to distance learning due to COVID-19 (no attestation)
Slide 11 © 2020 NASFAA
11
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
School should:1. Re-disburse to Arya (and parents) all Title IV
funds that were previously returned to ED2. Disburse all “aid for which Arya was eligible
during the payment period, including aid that “could have been disbursed” from the original R2T4 calculation and her second Direct Loan disbursement (spring disbursement)
3. Make required adjustments in COD4. Credit the student's ledger account5. Request any necessary funds from G5
Slide 12 © 2020 NASFAA
12
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 5 COVID-19 & Federal Student Aid Webinar 6/12/2020
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
• Per ED, you re-disburse and disburse aid as if the previous R2T4 calculation never happened, ignoring any post-withdrawal disbursement and late disbursement rulesØ No requesting approval to make the post-
withdrawal disbursementØ No timeframe, etc.
• Do not reverse or re-do the previous R2T4 calculation (reporting will be based on that)
• No requirement to notify student, but probably should as a good practice
Slide 13 © 2020 NASFAA
13
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
Upon reporting Arya as a COVID-related withdrawal, ED will:• Cancel the Direct Loan and TEACH Grant
disbursement for the entire payment period that includes March 13, 2020Ø Just the disbursement, not the entire loanØ All Direct Loans (student and parent)
• Exclude subsidized loan usage and Pell Grant payment from lifetime limits
Slide 14 © 2020 NASFAA
14
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
What if Arya was in an exclusively online program did not experience a disruption in instruction?• School has to get an attestation from Arya
indicating the withdrawal was COVID-related before re-disbursing or disbursing aidØ Can be email or text without a signatureØ Phone call is probably not acceptable
Slide 15 © 2020 NASFAA
15
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 6 COVID-19 & Federal Student Aid Webinar 6/12/2020
Scenario 1: AryaR2T4 Waiver—Aid Already Returned
What if Arya’s was in an online program that did not experience a disruption in instruction?• If Arya does not provide attestation by school’s
deadline, or indicates her withdrawal was not related to COVID, the school does nothing elseØ Do not reverse or re-do the R2T4 calculationØ Do not re-disburse previously earned aid or disburse
new aidØ Do not report Arya as a COVID-related withdrawalØ Arya is not eligible for Direct Loan or TEACH Grant
disbursement cancellationsØ Arya is not eligible for exclusions of subsidized loan or
Pell from lifetime limitsSlide 16 © 2020 NASFAA
16
Scenario 2: SansaR2T4 Waiver—Unofficial Withdrawals
• Sansa received all “F” grades, so the aid office reviewed classes after the end of the spring term (includes March 13th) to determine if she earned any “Fs” or withdrew
• Professors reported she did not earn any “F” grades; she unofficially withdrew
• School can choose to assign the term midpoint orlast date of attendance in academically related activity (if known) as her withdrawal date
• School has Sansa’s attestation that her withdrawal was due to COVID-19
• School is just now doing the first R2T4 calculation• Does the R2T4 waiver apply for Sansa?
Slide 17 © 2020 NASFAA
17
Scenario 2: SansaR2T4 Waiver—Unofficial Withdrawals
• Yes, R2T4 waiver applies to all withdrawals, not just official withdrawalsØ Withdrawal was due to COVID and she
withdrew sometime during the spring term• School takes the following steps:1. Disburse any remaining Title IV
disbursements for the payment period, including any second or subsequent disbursements of Direct Loans (that normally cannot be late disbursements)
2. Perform R2T4 calculation ignoring all late and post-withdrawal disbursement rules
Slide 18 © 2020 NASFAA
18
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 7 COVID-19 & Federal Student Aid Webinar 6/12/2020
Scenario 2: SansaR2T4 Waiver—Unofficial Withdrawals
• School takes the following steps (cont’d):3. Except for new disbursements, make no
adjustments to COD as a result of the withdrawal4. Except for new disbursements, make no
adjustments (as the result of the withdrawal) to the amount of Title IV aid credited to the student’s ledger account
• Calculation includes as “aid disbursed” allTitle IV aid for which Sansa was eligible during the spring payment period
• Same rules apply to all unofficial withdrawalsSlide 19 © 2020 NASFAA
19
Scenario 2: SansaR2T4 Waiver—Unofficial Withdrawals
What if Sansa had earned one or all of those “F” grades by failing the coursework?• Student who earns at least one “F”
(completes but fails) is not a withdrawal• R2T4 waiver does not apply
Ø Only applies to students who completely withdraw due to COVID-19
• Do not report as a withdrawal• Loan or TEACH Grant disbursement
cancellation and other benefits do not apply
Slide 20 © 2020 NASFAA
20
Scenario 3: JonWithdrawals After the 60% Point
• Jon officially withdrew from the nonterm clock-hour payment period which included March 13, 2020
• He withdrew after the 60% point, so he earned all of his Title IV aid that was already disbursed for the payment period
• He indicated on his withdrawal form that his withdrawal was COVID-related
• What happens next?
Slide 21 © 2020 NASFAA
21
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 8 COVID-19 & Federal Student Aid Webinar 6/12/2020
Scenario 3: JonWithdrawals After the 60% Point
• No unearned aid; R2T4 waiver does not apply
• Included in reporting?Ø Unsure at this time
• Qualify for Direct Loan and TEACH Grant cancellation or restoration of subsidized loan usage or Pell Grant lifetime eligibility used?Ø Unsure at this time
Slide 22 © 2020 NASFAA
22
SAP Guidance—Download AskRegs Q&As in Today’s Handouts
Slide 23 © 2020 NASFAA
23
Answers to Questions on Other Popular Topics
Slide 24 © 2020 NASFAA
24
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 9 COVID-19 & Federal Student Aid Webinar 6/12/2020
CARES Act—Student Eligibility• Chronology of ED guidance1. No limitations on student eligibility2. Must meet Section 484 student eligibility requirements3. ED won’t solely enforce Section 484 requirements4. Interim final rules including Section 484 student
eligibility requirements (posted on ED’s website, pending in Federal Register)
• DACA/Other undocumented studentsØ 1996 welfare reform law prohibition
• Still no answer on eligibility for graduated or withdrawn students
Slide 25 © 2020 NASFAA
25
CARES Act - Interim Final Rule
• Posted June 11 on ED’s HEERF webpage• Provides justification (questionable) that ultimately
limits HEERF funds to students who are (or could be) Title IV eligibleØ Affirms no undocumented, DACA, or international
students• Requires full compliance with Section 484 Title IV
eligibility requirementsØ Additionally, ED states that students need to be enrolled
in an eligible program to receive funds
Slide 26 © 2020 NASFAA
26
CARES Act - Interim Final Rule (cont’d)
• Allows schools to design their own application to verify Title IV eligibility for students who choose not to fill out a FAFSA but otherwise meet eligibility criteria. Students “attest under the penalty of perjury to meeting the requirements of section 484 of the HEA.”Ø Suggests that schools encourage non-FAFSA filers to file
• Effective once published in the Federal Register(TBD)
Slide 27 © 2020 NASFAA
27
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 10 COVID-19 & Federal Student Aid Webinar 6/12/2020
Future COVID-19 Funding
• Congress has already begun work on a 4th COVID-19 relief bill
• House Democrats have passed their proposal, but Senate has not introduced legislation yet
• The higher education community has asked for an additional for $46.6 billion for students and institutions (to account for additional need-based aid and lost institutional revenue)
Slide 28 © 2020 NASFAA
28
Verification Flexibilities and 2020-21
• Good News! But it’s complicated…• Per ED, verification flexibilities in the 4/3/20
Electronic Announcement are date-specific, not award year-specific, so can apply to verification for 2020-21 award year
• Applies to:Ø Identity/Statement of Educational PurposeØ Household size and number in college
Slide 29 © 2020 NASFAA
29
Verification Flexibilities and 2020-21
• What does “date-specific” mean?• Two possible deadlines:
Ø June 30, 2020; orØ End date of your summer crossover payment period
that is attached to 2019-20 award year, if you have one• Two possible choices school must make:
Ø Receive 2020-21 verification documents for those four items on or before the deadline; or
Ø Complete 2020-21 verification of those four items on or before the deadline
Slide 30 © 2020 NASFAA
30
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 11 COVID-19 & Federal Student Aid Webinar 6/12/2020
Verification Flexibilities and 2020-21
Example 1: No summer 2020 classes or summer crossover payment period is not assigned as a trailer to the 2019-20 award year• Deadline to use the flexibilities is June 30, 2020
Ø June 30th for students to submit 2019-20 and 2020-21 verification documents for identity, Statement of Educational Purpose, household size, and number in college; or
Ø June 30th for you to complete 2019-20 and 2020-21 verification for those four items
Slide 31 © 2020 NASFAA
31
Verification Flexibilities and 2020-21
Example 2: Summer crossover payment period is assigned as a trailer to the 2019-20 award year and ends on August 15, 2020• Deadline to use the flexibilities is August 15,
2020 for this schoolØ August 15th for students to submit 2019-20 and 2020-
21 verification documents for identity, Statement of Educational Purpose, household size, and number in college; or
Ø August 15th for you to complete 2019-20 and 2020-21 verification for those four items
• August 15th is for this school example; will be different deadline for other schools
Slide 32 © 2020 NASFAA
32
CARES Reporting Requirements
• R2T4Ø ED estimates that it will release process in 1-2 monthsØ In the meantime, keep tracking
• HEERF Student ShareØ Posting on web site, see 5/6/20 Electronic
AnnouncementØ No updates from ED on future reporting
• HEERF Institutional ShareØ CARES requires quarterly reportingØ No updates from ED
Slide 33 © 2020 NASFAA
33
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 12 COVID-19 & Federal Student Aid Webinar 6/12/2020
Professional Judgment (PJ)
• NASFAA surveyØ Assist with meeting training needsØ Assist with federal advocacy efforts
• Use of Dear Colleague Letter (GEN 09-05)Ø Allows FAAs to have a blanket policy to use a
letter from the state unemployment agency, or other evidence of receipt of unemployment benefits, to zero out income earned from work and exclude unemployment benefits
Ø Unclear if it’s still in effectSlide 34 © 2020 NASFAA
34
CARES Act—Upcoming Terms
• Many ED flexibilities and CARES provisions do not extend into summer or fall, or it’s unclear if they do
• As pandemic continues, ED beginning these discussions now
• Examples:Ø Paying FWS studentsØ Emergency FSEOGØ VerificationØ Overlapping payment periods
Slide 35 © 2020 NASFAA
35
Cost of Attendance (COA) Considerations for 2020-21
• May need to adjust 2020-21 COA depending on your institution’s plans for fall (e.g., living allowances)
• Reminder: Higher Education Act states that "no distinction shall be made with respect to the mode of instruction in determining costs”
• NASFAA Monograph 24: Developing the Cost of Attendance
Slide 36 © 2020 NASFAA
36
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 13 COVID-19 & Federal Student Aid Webinar 6/12/2020
ED Guidance Timeline
Slide 37 © 2020 NASFAA
37
Register online at nasfaa.org/letstalk
38
Questions
Slide 39 © 2020 NASFAA
39
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 14 COVID-19 & Federal Student Aid Webinar 6/12/2020
Submit Your Questions
Slide 40 © 2020 NASFAA
40
Download Your Certificate of Attendance
Slide 41 © 2020 NASFAA
41
Complete the Survey
Slide 42 © 2020 NASFAA
42
NASFAA’s WebinarCOVID-19 and Federal Student Aid:
As It StandsPresented June 12, 2020
© 2020 NASFAA 15 COVID-19 & Federal Student Aid Webinar 6/12/2020
Thank you for joining us!NASFAA seeks to shape the future by promoting student access and success in higher education.
Webinars, like this one, are made possible thanks to the annual dues paid by NASFAA members at postsecondary institutions across the country.
Slide 43 © 2020 NASFAA
43
Slide 44 © 2020 NASFAA
Not a NASFAA Member? Join now to gain access to member-only benefits and to help fund more training content, like this webinar.
Learn more at: www.nasfaa.org/Join_NASFAA
44
45
NOTES:
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
NOTES:
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
_______________________________________________________________
The National Association of Student Financial Aid Administrators (NASFAA)
provides professional development for financial aid administrators;
advocates for public policies that increase student access and
success; serves as a forum on student financial aid issues;
and is committed to diversity throughout all activities.
1801 PENNSYLVANIA AVENUE, NW, SUITE 850 WASHINGTON, DC 20006-3606
202.785.0453 FAX. 202.785.1487 WWW.NASFAA.ORG
© 2020 National Association of Student Financial Aid Administrators