Except as noted below, the Department is extending the deadline for all flexibilities related to the COVID-19 emergency through the end of the payment period that includes December 31, 2020 or the end of the payment period that includes the end date for the Federally-declared emergency related to COVID-19, whichever occurs later. We outlined the initial flexibilities in Electronic Announcements published on March 5, April 3, May 15, July 9, and July 10, 2020.
Exceptions to the general deadline
Campus-Based Matching Requirements
Section 3503 of the Coronavirus Aid, Relief, and Economic Security (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. Irrespective of when the national emergency declaration is lifted, no institutional match is required for either of these award years. We remind institutions that the CARES Act does not waive the non-Federal share requirement that applies to private for-profit organizations that participate in the FWS program.
Leave of Absence (LOA)
The Department 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 LOA approved since the original flexibility was granted.
Return of Title IV Funds
An institution is not required to return Title IV funds for any student who begins attendance in a payment period or period of enrollment that includes March 13, 2020, or begins between March 13 and the later of December 31 or the last date that the national emergency is in effect, and subsequently withdraws from the period as a result of COVID-19-related circumstances. Standard term programs must use the payment period, i.e., semester, trimester, or quarter, to calculate returns.
Where an institution has opted to use the period of enrollment to calculate its returns for a non-term or non-standard term program, the waiver may apply to a student who begins attendance in a payment period that includes December 31, 2020 or the last date that the national emergency is in effect and withdraws after the conclusion of that payment period but within the applicable period of enrollment.
Section 3510 of the CARES Act authorizes the Secretary to permit any part of an otherwise eligible program to be offered via distance education for the duration of a national emergency declared by the applicable government authorities in the country in which the foreign institution is located, through the payment period following the payment period or the break between payment periods during which the emergency declaration is lifted. The Secretary will permit the use of distance education by foreign institutions offering eligible programs for the full period authorized under the CARES Act.
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. 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.
Reporting and Audit Requirements
Until further notice, financial statement and compliance audit deadlines are extended by six months. This affords institutions an additional six months from the date an audit or financial statement would otherwise be due, to submit the appropriate documentation.
Deadline extensions applicable to Equity and Athletics disclosures (EADA), the Fiscal Operations Report and Application to Participate (FISAP), and Campus and Fire Safety remain as outlined in the July 10, 2020 Electronic Announcement.
Please submit any questions related to these updated deadlines to COVIDfirstname.lastname@example.org.