We have been fielding questions from several clients in regard to the guidance surrounding when a student who withdraws can be treated as a COVID-19 drop and be eligible for the R2T4 relief provided as part of the CARES Act. Thus, we felt a reminder was in order of the key points.
The U.S. Department of Education’s June 16 guidance specifically indicates the following wording under the Qualification for R2T4 Relief section: “Any institution that moved students from ground-based instruction to distance learning, closed campus housing or other campus facilities, or experienced other interruptions in instruction during a term within the covered period may consider all withdrawals from students enrolled in affected programs during that term to have been the result of circumstances related to the COVID-19 national emergency.
For institutions that did not undergo changes in educational delivery or campus operations as a result of the COVID-19 emergency, during a term or payment period within the covered period, the institution will be required to obtain a written attestation (including by email or text messages) from the student explaining why the withdrawal was the result of the COVID-19 emergency. Institutions must also obtain written attestations from students who withdrew from distance education programs, if applicable, explaining why the withdrawal was the result of the COVID-19 emergency.
Allowable circumstances include, but are not limited to, illness of the student or family member, need to become a caregiver or first responder, loss of childcare, economic hardship, inability to access wi-fi due to closed facilities, or an increase in work hours as a result of the COVID-19 emergency. Information (which in the judgment of the institution is reliable) provided by the family member of a withdrawn student whom the institution is unable to contact is acceptable for documentation purposes.”
The key item is the information noted in bold above. If the institution did not undergo a change in the educational delivery during a term or payment period, then the R2T4 relief is not automatic. Thus, a school which transitioned to teaching fully online due to the pandemic does not meet the definition for R2T4 relief unless a specific disruption occurs in the term or payment period subsequent to March 13, 2020. In this case, the students who withdraw in a term or payment period in which no disruption has occurred can only be treated as a COVID-19 drop if the institution obtains a written attestation. The R2T4 relief is not automatic. We have conferred with industry colleagues and reviewed the National Association of Student Financial Aid Administrators (NASFAA) covid-19 webpage, and they have reached the same conclusion.
Please review your internal policies and procedures to ensure these regulations are being properly followed. Misinterpretation could lead to an audit finding. If you have any questions, please contact us to speak to one of our COVID-19 regulatory relief experts.