COVID-19 and Federal Financial Aid for Education Abroad FAQ’s

Students studying abroad may receive HEERF emergency financial aid grants from the recipient institution where they are enrolled. These students must meet the criteria based on prioritizing exceptional need that the institution has established for distributing its HEERF emergency financial aid grants. This FAQ from the U.S. Dept of Education (FAQ 11) addresses the requirement that a school prioritize for exceptional need, and other eligibility requirements.

Currently there are no federal restrictions on the use of Title IV federal financial aid based on an education abroad location's travel advisory/warning.

However, institutions may choose to place their own restrictions on student travel and/or institutional aid based on their policies and the travel advisory/warnings issued by the Department of State.

This decision to restrict the use of aid would be an institutional matter, and study abroad offices should connect with their financial aid office and any other risk management offices for more information.

The Gilman Scholarship does have restrictions on location; however, this is not a federal financial aid program and subject to different funding requirements from Title IV funds.

Students who are or were enrolled in an institution of higher education on or after the date of the declaration of the national emergency due to the coronavirus (March 13, 2020) are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. The CRRSAA requires that institutions prioritize students with exceptional need, such as students who receive Pell Grants or are undergraduates with extraordinary financial circumstances, in awarding emergency financial aid grants to students.

Under the guidance updated on March 20th, 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. 
  • 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 need to be done prior to that process.
    • In the CARES Act, institutions are able to use a statutory waiver to assist with negating the repayment of several types of unearned aid due to the calculation.
      • Also check to see if your state is declared with a state of emergency by FEMA, as this can further relax some rules. 
    • 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?

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.

Institutions still need to complete the calculation for unearned aid when students are no longer actively participating in all of their courses. Under the new guidance, the negative impacts of repaying federal loans and grants have been addressed in the CARES Act. 

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.

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.
• It is important for advisers/study abroad offices to connect with the financial aid office to ensure that online/remote abroad programming will fulfill all requirements for aid to follow students. We have seen a mix of institutions allowing federal aid to work with programs, and others not. Please note that there may be state and program accreditation rules that pose issues allowing the aid to follow, even if there are consortium agreements between the school and the program.
• The CARES Act allows Title IV eligible foreign institutions to offer distance education for the duration of a declared emergency and the following payment period. NASFAA’s analysis states “The bill (CARES Act)  also grants Title IV-participating foreign institutions, which are currently excluded from providing distance education to U.S. students not enrolled in a study abroad program, the ability to offer distance education for the duration of a declared emergency and the following payment period. ED is also granted authority to permit a Title IV-participating foreign institution to enter into a written arrangement with a U.S. institution that participates in the Direct Loan program, for purposes of allowing a borrower at a foreign institution to take courses from the U.S. institution, for the duration of a qualifying emergency and the following payment period.”

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.

Yes, each institution will gain access to different amounts of federal funding to use for students on their campus. There is guidance on how institutions can use this money. Please connect with your financial aid office for details on how to get these resources to students.

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.

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 moved to an online program type, or (if your institutions allow) postponed and take place at the end of Spring term, causing a slight overlap into summer term without causing issues. See the FAQ provided with the March 20 Dept of Education - update for more details to use when talking to your financial aid office.

Under the CARES Act, credits not complete due the emergency of COVID-19 may be excluded from the SAP process. No appeal should be needed, however, it is always best to check in with your financial aid office for their procedures/policies.

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. Institutions should discuss what is best for their students given the guidance from the Centers for Disease Control and U.S. State Department. Fall programming remains in this category as well.

According to the National Association for Student Financial Aid Administrators (NASFAA) guidance, any costs pre or post program such as quarantine procedures or COVID testing which are specific to certain locations/airlines, are NOT covered in the Cost of Attendence flexibility during COVID or professional judgement power for financial aid administrators. Students will have to secure their own funds to cover those additional costs.

Yes. The Department's final rule on student eligibility for HEERF III funds states that all students who are or were enrolled in an institution of higher education during the COVID-19 national emergency are eligible for emergency financial aid grants from the HEERF, regardless of whether they completed a FAFSA or are eligible for Title IV. That includes citizens, permanent residents, refugees, asylum seekers, Deferred Action for Childhood Arrival (DACA) recipients, other DREAMers, and similar undocumented students.

International students may also receive HEERF funds. However, as noted in Questions 11 and 12 from the Department of Education’s May 11, 2021 FAQs, institutions must ensure that funds go to students who have exceptional need. The U.S. Department of Education encourages institutions to prioritize domestic students, especially undergraduates, in allocating this funding. This includes citizens, permanent residents, refugees, asylum seekers, DACA recipients, other DREAMers, and similar undocumented students.
 

Legislation passed to enable student veterans to continue their coursework online as a temporary measure without disruption to their housing and other benefits. School Certifying Officials should have received the new guidance regarding this bill, please connect with them for additional details.

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. 

• 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.

From NAFSA:

• NAFSA COVID-19 Critical Resources
• NAFSA Resources for Operational Resilience

From the National Association of Financial Aid Administrators:

• ​​​​​NASFAA COVID-19 Web Center
• NASFAA Online Learning and Title IV Aid
• NASFAA Major Disaster/State of Emergency Guidance 
   

From the U.S Department of Education:

• U.S. Department of Education's COVID-19 Page
• U.S. Department of Education's March 5 Guidance Page (with March 20 updates)

From the Forum on Education Abroad: 

• Forum on Education Abroad COVID-19 Page