Waivers & Flexibility
Official documentation of high school completion or documentation of the equivalent of high school completion may be difficult for FAFSA applicants to obtain during this national emergency. For applicants in verification groups V4 or V5, institutions should use documentation of an applicant’s high school completion status that it may already have obtained for other purposes (e.g., documentation maintained in its admissions office). Where an applicant is unable to obtain such documentation and an institution does not already have such documentation, it may accept a signed and dated statement from the applicant in which he or she truthfully attests to his or her secondary school completion or the equivalent. The statement must indicate whether a high school diploma or the equivalent was obtained and date of completion (or approximate date). This guidance applies until December 31, 2020, for both the 2019-2020 and 2020-2021 award years.
The Department of Education waives parent's signatures on the verification worksheet (verification of household size and number in college). Other verification documents that require a parent's signature, such as income verification documents, have not been waived.
Students are no longer required to appear in person or in front of a notary to complete their Statement of Education Purpose form. This document may be signed by the student and submitted to the school with a copy of their government issued identification. The Department of Education also recognizes that forms of identification (such as a driver’s license) may expire with no real and reasonable opportunity for renewal due to social distancing requirements. Institutions may accept a copy of an expired document if it expired after March 1, 2020. This form and identification can be submitted via mail, secure email, or uploaded to the student's school portal.
Return to Title IV (R2T4) Funds:
For any student who begins attendance in a payment period or period of enrollment that begins on or includes March 13, 2020, and subsequently withdraws from the period as a result of COVID-19-related circumstances, an institution is not required to return Title IV funds.
Institutions that transitioned students to distance learning, closed campus housing or other campus facilities, or experienced other interruptions in instruction are permitted to consider all withdrawals of ground-based students during the covered period to have been the result of circumstances related to the COVID-19 national emergency. This includes students who withdrew during the applicable period for whom the institution has already performed an R2T4 calculation and returned funds. Where returns have already been made, the institution should re-disburse Title IV funds to those students, making required adjustments in COD, crediting students’ ledger accounts, and requesting any necessary funds.
An R2T4 calculation is not waived. The R2T4 calculation still must be done, but neither the school nor the student has to return any unearned aid that results from that calculation. So, the school doesn't have to return any unearned aid that remains on the student's bill, and the student doesn't have to return any grant or loan funds. NOTE: Loan borrowers are still bound by terms of their Master Promissory Note (MPN). The above mentioned waiver for R2T4 does not mean that you don't have to repay your student loans. It simply means that if you withdrawal from all classes during the outlined semester(s), the school will not return any loan funds on your behalf, creating a balance due to the school.
Satisfactory Academic Progress (SAP):
The CARES Act allows institutions to exclude from the quantitative component (pace measurement) of satisfactory academic progress (SAP) attempted credits a student was unable to complete as a result of the COVID-19 national emergency. It is not necessary for a student to have filed a SAP appeal for an institution to exercise this flexibility. However, to exclude attempted credits from SAP, an institution must have reasonably determined that the student’s failure to complete those credits was the result of a COVID-19 related circumstance. Allowable circumstances include, but are not limited to, illness of the student or family member, need to become a caregiver or first responder, economic hardship, added work hours, loss of childcare, inability to continue with classes via distance education, inability to access wi-fi due to closed facilities. If an institution temporarily ceases operations during a period of enrollment, attempted credits for all affected students (specific to that enrollment period) may be excluded.
Federal law includes a provision allowing an institution to make FWS payments under certain limited circumstances to disaster-affected students who are unable to continue working. For students enrolled and performing FWS at a campus that must close due to COVID-19, or for a FWS student who is employed by an employer that closes as a result of COVID-19, the institution may continue paying the student Federal work-study wages during that closure if it occurred after the beginning of the term, the institution is continuing to pay its other employees (including faculty and staff), and the institution continues to meet its institutional wage share requirement. Students who were prevented from beginning a term at the institution as a result of a COVID-19-related disruption would not be eligible for Federal Student Aid for that term, and therefore could not be paid FWS wages for hours they did not work. NOTE: This applies to Federal Work-Study, State Work-Study, and the Work-Study Mentorship Program
Federal Supplemental Education Opportunity Grant (FSEOG):
Section 3503 of the CARES Act waives the institutional share (match) requirement associated with the Federal Work-Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) programs for the 2019-2020 and 2020-2021 award years.
The Department of Education released guidance allowing Institutions to transfer up to 100% of its unexpended Federal Work-Study allocation to the FSEOG program. The CARES Act (Section 3504) further provides that an institution of higher education may use any amount of its FSEOG allocation (including funds transferred from FWS) to award emergency financial aid grants to assist undergraduate or graduate students for unexpected expenses and unmet financial need as the result of a qualifying emergency. FSEOG awarding rules, i.e., exceptional need, with grants made first to Pell eligible students having the lowest Expected Family Contributions, are waived for the purpose of making FSEOG Emergency Aid Grants. FSEOG Emergency Aid Grants are not considered Estimated Financial Assistance.
Texas Education Opportunity Grant (TEOG):
Due to the COVID-19 disruption, THECB is temporarily allowing institutions to transfer up to 100% of the institution's unexpended Texas College Work-Study (TCWS) allocation, including the institution's unexpended Work-study Student Mentorship Program (WSMP) allocation, to its TEXAS Grant, Texas Educational Opportunity Grant (TEOG), or Tuition Equalization Grant (TEG) allocation. This will provide institutions with greater flexibility to provide grant funding to students during this COVID-19 public health emergency. This waiver is in effect until rescinded by the THECB or until the state disaster declaration is no longer in effect. Institution's may not exceed the limitations on transferring grant funds from TEXAS Grant, TEOG, and TEG to the TCWS Program. Up to 10% of the institution’s total annual program allocation or $20,000 (whichever is less) may be transferred from TEXAS Grant, TEOG, and TEG into either TCWS or WSMP in a given fiscal year.
Last Updated: May 18, 2020