Your peers on the NAFSA’s Education Abroad Regulatory Practice Subcommittee on Financial Aid provide the following information to help education abroad professionals stay informed of federal financial aid guidance during the disruption of the COVID-19 crisis. Common questions related to Cost of Attendance (COA), Satisfactory Academic Progress (SAP), online learning, and others are answered below. While some authoritative guidance has been issued by the U.S. Department of Education, education abroad professionals should connect with their institution’s financial aid office for interpretation of the rules and their use of professional judgement.

Updates are provided as new information from the Department of Education and insights from the National Association of Student Financial Aid Administrators (NASFAA) are published.

Do we need to adjust the cost of attendance/budget for a term?

Under the new guidance dated March 20, 2020, the Department of Education has discussed several situations where no adjustment of cost of attendance or federal aid is required.

  • Program Never Started: 
    • Yes, if the student files for a leave of absence for the term then their cost of attendance must be updated, and aid returned. In the updated March 20, 2020 guidance, the US Department of Education has also provided unique guidelines for leave of absences related to COVID-19, including that schools do not need to return aid disbursed as credit balances, and waiving the notifying of the loan servicers (usually this would begin the countdown to repayment). 
    • No, an adjustment is not needed if the student can find alternative enrollment on campus for the remainder of the semester. Even if the student receives a waiver or refund of some/all of the abroad costs, schools do not have to complete a revision of costs - unless your institution has a policy that mandates it.
  • Program Was Cancelled: (school closed or no continuation of classes/online options): Depends on if the student is able to find replacement classes at the home institution, or if they will have a transcript of incomplete/withdrawn classes all impact this situation. 
    • Incomplete Grades:
      • Incomplete grades mean that students will at a point complete the credits. No adjustments to cost of attendance or federal aid is needed. Please work with the student to ensure completion of the credits- there is a point they turn to F grades. These can also impact Satisfactory Academic Process (SAP).
    • Withdrawals:
      • If the student will receive a transcript with all W grades, a Return to Title IV (R2T4) calculation review will need to take place. No changes to cost of attendance or federal aid need to be done prior to that process.
      • Things to think about to help students in this Withdrawal position:
        • Can the home institution continue those classes as independent studies?
        • Can the classes be incomplete and be completed later?
        • Will they be given partial credits for what work has been completed?
  • Program Continues with Changes: (move to online/distance learning): As long as the student maintains enrollment, a cost of attendance adjustment should not be needed.
  • What happens if the student continues enrollment for term AND receives a refund for the abroad program? According to the NASFAA site and the Department of Education’s guidance on March 20, 2020, if a student receives a waiver or refund of some/all of the abroad costs, schools do not have to complete a revision of costs - unless your institution has a policy that mandates it.

What about the return of Title IV funds for students who don’t complete their program, also known as R2T4 by financial aid professionals (the recalculation of aid based on time spent actively participating on the program)?

Education abroad officials should connect with their financial aid offices and request a pause in R2T4 processing until refunds and other unknowns become clear. Current regulations give financial aid offices 30 days to make this determination so there is not a rush to do so now given that emergency legislation might change these calculations. 

If a calculation is done under the March 5, 2020 guidance, it does not need to be changed again if further guidance is provided at a later date. It is important to note that this is only done if the student is no longer taking classes for that term - all Fs, Ns or Ws.

Can my students participate in online learning?

It depends.

  • Online learning is acceptable per federal regulations if the student is receiving the aid from the U.S. based institution and that institution has consortium agreements or “written arrangements” with the university offering the online coursework.
  • If the student is receiving their financial aid from a Title IV eligible foreign institution of higher education, then online learning is not authorized at the moment.

There is emergency legislation pending that would waive the current statute which prohibits online learning from Title IV eligible foreign institutions.

Are there any additional financial resources students can utilize for new costs (flight charges, housing, etc)?

Under current regulations, adding additional costs to the current cost of attendance is allowable under professional judgement. If they are related to the semester costs, they should be allowable (additional flight costs, housing while stuck abroad, etc.). Work with your financial aid officers for more information- please note that adding costs may only allow for loan funding to increase.

Under the proposed legislation, there is language about additional emergency funding to aid students that does not take the form of loans. Depending on the final legislation language, there may be grant options available.

What about “Leave of Absence” students participating on a non-approved by the home institution program (credits as transfer credits)?

For institutions that do not use program providers, or have a limit on approved programming, if your student took a leave of absence to go on a program that is now cancelled or altered, there might not be any federal funding to assist in this situation. As they were not on an approved program at their home institution, they should not have used federal financial aid for term. Students should, however, seek institutional emergency funding to help with any additional costs related to COVID-19.

How are schools dealing with financial aid related to their own campus created programming (faculty-leds) in Spring and/or Spring Break?

This depends on your institution.

  • Some schools are offering online courses/independent studies for students to make up for the abroad program not taking place. It is also possible that the costs of the program are being refunded.
  • Some short programming such as Spring Break programs may be postponed and take place at the end of Spring term, causing a slight overlap into summer term without causing issues in this COVID-19 world. See the FAQ provided with the March 20th, update for more details to use when talking to your financial aid office.
How will COVID-19 impact Satisfactory Academic Progress (SAP)?

Students are able to use issues relating to COVID-19 (illness in the family, need to self-quarantine, or general disruption due to the virus) in their SAP appeal.

How are providers handling refunds, future programming, etc.?

At this time most program providers are still working on the recall of students and safety of their international centers and staff. Most programs have not begun to factor in any refunds to impacted students, however, this might change in the coming weeks. This will depend on the program provider. Home institutions are able to make their own decisions on refunds of fees or costs of the programs depending on internal factors.

Future programming remains a ‘wait and see’ situation for most of the field. Some program providers and institutions have cancelled summer programming already. Institutions should discuss what is best for their students.

Veteran Benefits and COVID-19

Legislation has just passed (needs signature) to enable student veterans to continue their coursework online as a temporary measure without disruption to their housing and other benefits. At the moment, education abroad professionals should connect with your School Certifying Officials to hold off on any processing until official guidance related to this bill is published. 

Financial Policies

The federal government will not provide guidance on items like refunds, fees, and other items they consider institutional policy. NAFSA recommends checking with your program provider partners concerning refunds for students on their programming.

In terms of exchanges and direct enrolls, whether to provide refunds will be up to the home and host institutions. 

Education Abroad Regulatory Practice Subcommittee (EARP) Tips
  • Create a task force with stakeholders from financial aid, the registrar, student accounts, academic advising, and others as needed to find points of communication for you and students with questions.
  • Shared documents that list any refunds, or requests for additional funding are critical.
  • Decide a policy about refunds for your own programs, and keep in contact with your program/partner institution providers for updates on their end- note that details won’t likely be available for some time.
  • Centralize messaging within your office to avoid confusion.
  • Connect with your Dean of Students Office and/or Financial Aid Office to ask about emergency student funding available for students.
  • Connect with NAFSA’s EARP & Subcommittee if you have questions or situations that are unique and need a second opinion.