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student is able to find replacement classes at the home institution, or if they will have a transcript of incomplete/withdrawn classes all impact this situation.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.