COVID-19: “Flexibilities” for “Interruptions of Study”

Melissa Maichle .

“Know your Electronic Announcements!”

Over the past six months you have seen important publications from the Department of Education using the words “flexibility,” and “interruptions of study.” These allow for a waiver of some rules or an extension of certain normal deadlines due to the COVID-19 pandemic. The key Electronic Announcements are dated March 5, April 3, May 15, June 16, July 9, July 10, and August 21. The IFAP and NASFAA websites have helpful links to important regulations regarding COVID-19.  Some highlights you should be aware of are included below; you should review the relevant Electronic Announcements for further details.

Are schools still required to match Campus-Based Funds?

It’s official; all matches have been waived for both the 2019-20 and 2020-21 award years! This includes those normally required for Federal Work-Study and Federal Supplemental Educational Opportunity Grants (FSEOG). There is an important exception; the CARES Act does not waive the non-Federal share requirement that applies to private for-profit organizations that participate in the FWS program.

What happened with the R2T4 requirements? 

March 13, 2020 is the key date to remember when it comes to all Return to Title IV calculations for the year 2020. You are still required to perform the R2T4 calculation! Schools are NOT required to return federal funds for students who began attendance in a payment period or period of enrollment that includes this specific date through the later of December 31, 2020, or when the national emergency is lifted. Be aware that there are some reporting requirements related to this. As you might expect, the  new rules are slightly different for non-term or non-standard term programs. 

Is there any Leave of Absence flexibility?

You will find the revised guidance to offer straight-forward flexibility. The Department of Education is extending the maximum duration of an LOA from 180 days to also include the number of additional days remaining in the calendar year. This flexibility includes students who are already on an approved LOA since the original flexibility was granted.

Our academic calendars have gone haywire!

This is to be expected at many schools. Flexibilities related to academic calendars, including standard semesters or trimesters consisting of as few as 13 weeks, standard quarters consisting of as few as nine weeks, and overlapping standard terms extend through the end of the academic year that includes December 31, 2020 or the academic year that includes the end date for the federally-declared emergency related to COVID-19, whichever occurs later. Changes in academic calendars should be carefully documented by those who develop academic calendars at your institution, which would typically include at least the Registrar’s Office and the Financial Aid Office. The Department adds: Because it is frequently necessary for institutions to establish academic calendars that cover an entire academic year as opposed to a single payment period, we believe it is appropriate to align the deadline for these flexibilities to coincide with the end of program’s academic year.

Sign up for our October 28 webinar “When the Axis Shifts: Academic Calendar Changes and the Impact on Financial Aid” and find out what you need to know to about changes to the academic calendar as it relates to your role in the financial aid office.

What about our annual audit?

Don’t worry; the required annual audit due date has been extended by a full six months. This gives schools ample time to meet the audit requirements while facing the challenges of remote access to campus, extensions of the academic year, and other issues. 

What other aspects of our financial aid world are impacted?

Honestly, much of what we are involved in has been impacted. A few headlines from the Electronic Announcements mentioned above: Annual Security Reports, Equity in Athletics Disclosures, FISAP deadline, Verification documentation, Accreditation, Verification of High School Completion, Satisfactory Academic Progress, Distance Education, Professional Judgment, and the list goes on. We have only highlighted a few issues here, but you’ll want to stay informed as the Department provides updates, extended deadlines, and additional flexibilities.

How We Can Help

The Higher Education Assistance Group is always here to assist you through the busiest of times in your aid office. If you are struggling to understand the complexities of your academic calendar, need to reconcile your federal aid prior to your year-end closeout, or have other issues or concerns, please contact us at We will assist with analyzing your needs and can arrange for outstanding consultants to help address your specific situation. For questions directed to the Department of Education surrounding COVID-19 changes, you can reach them via email at