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COVID-19 Q & A’s

Q-1      I know that under normal circumstances we can only put a student on leave of absence when they request it.  However, does the following sentence from The Office of Postsecondary Education say that the school may put its students on leave of absence if they had to close their doors (No operations at school or online) due to COVID-19 without a request from the students?

A-1       Yes that is true unless you have some reason to believe that the student has withdrawn. I would probably send them a LOA form, indicating that the reason is because of closure due to CoViD-19, with a return date of when it is safe to resume class. Ask the student to signed and return, just so you have documentation that the student was aware that they were placed on a LOA.  Also, maybe add an addendum to the catalog to the LOA policy, that the school placed everyone an LOA due to COVID-19 temporary school closure. Remember to review current LOA’s to ensure that no one will exceed the 180 days in 12 months’ rule. Also, make sure that you have approval from the accrediting agency or state to add this policy, if they require it.

Q- 2     Should I exclude high school students enrolled in a Cooperative Cosmetology Program from the HEER funds?

A-2       Yes, non-title IV students are not eligible for the HEERF grant fund to students.

Q-3      It seems clear that emergency funds are not allocated to 100% online schools and students attending 100% online programs.

Will ED discharge FSA loans for students who withdraw from a 100% online school due to COVID?

A-3       The CARES ACT does not address only students that attended a brick and mortar institutions, but all students and small businesses.

Summary below:

With respect to small businesses, the bill:(1) Creates a paycheck protection program; (2) Establishes, and provides funding for, forgivable bridge loans; (3) Provides additional funding for grants and technical assistance; and (4) Offers a subsidy for certain loan programs. The bill also creates added bankruptcy protections. With respect to education, the bill: Sec 3504-3518(1) Temporarily suspends payments for federal student loans; (2) Adjusts student eligibility for Subsidized Loan Usage and Pell;(3) Adopts flexibility for institutional refunds and SAP; and (4) Otherwise revises provisions related to campus ­based aid, Supplemental Educational Opportunity grants, Federal Work­-Study, subsidized loans, Pell grants, and foreign institutions

Q-4      Everyone thought it was a good idea to “dole” out the payments to the students over a number of payments.   The reality is, if some of these students get large checks, they may not return.  Are you of the opinion that would be ok to do.?

A-4       I think it would be ok, as long as it didn’t stretch out over sever months. The need is really now, so many people are struggling even to put food on the table. I think as long as you set a policy and stick with it, it should be ok. Maybe do 2payments a month a part. First you have to determine how much each student is actually going to receive and then decide how many payments. I think ED is expecting schools to disburse most of this pretty quickly to help the students.

Q-5a    I understand from the clarification today that any student who receives any of the CARES grant must be enrolled in a Title IV program, correct?

A-5a     Yes, or any student that could be eligible for IV that met all of the eligibility criteria, cash pay, voc. rehab, VA the recent HEERF Q & As on student grants in April, regarding institutional grants make that clarification It also makes it clear that students in non-title IV short programs are not eligible.

Q-5b    Is there any way to provide grants to students in short term programs from the institutional share of funds?

A-5b     No, those funds cannot be used to provide grants to students not in a Title IV program.

Q-5c    Can you please clarify if it is a REQUIREMENT to open a separate bank account for these funds, or sufficient if we keep these funds separate and code them separately in our FA/Accounting, etc.?

A—5c  No, but definitely a recommendation. It makes it easier to track those funds separately and makes reconciliation much easier. If they are moved to the corporate account, make sure that you don’t accidently borrower even a penny from those funds.

Q-6a     So we CAN use this for students who got a Pell grant?  Can we just take those number of students and divide the total among them all?

A-6a     Yes you can, just document that was your policy because your students have medical issues.

Q-6b     Is this money only to be used to cover the student’s expenses while they are AT HOME only?  Or can we use this to cover our specialized services fee that we charge which includes things like Security, Technology, Healthcare, etc. as the students have been using these services to get things like prescriptions back home, doctor orders sent back home, technology taken care of, security to come back to school to get their items and to take them home when this first occurred?

A-6b     The money is disbursed directly to the student to use with any costs related to CoA, room, food, or any other cost related to completing their education. You might want to send a cover letter telling them to use it to cost of staying healthy so they can attend school, food, and any of the items that you mentioned about. I think all of this would be acceptable in your case

Q-6c    If we have a separate account for them, can we take this money and apply it towards any OVR costs on the student’s bill?  OVR does pay for their transportation, sometimes housing, healthcare, assistive technology, etc.

A-6c     You can NOT apply any of these funds directly to the students account. In this case you must write checks, money order 9fees paid by school), direct deposit into the student’s bank account, apps like Venmo, etc.

Q-7      I know that the single audit requirement for audits due on March 31, 2020 has been extended until June 30th. What about the audit deadlines for institutions with yearend dates of September, October, November, and December?

A-7       Not yet, we hope to hear something soon. But if the auditor can’t get the audit done because the school can’t get information to them based on suspension of classes due to COVID-19, the auditor can get them relief for being late in his cover letter.

Q-8      I was hoping you can help us with the dilemma of students trying to retrieve their high school transcript.

A-8       ED doesn’t require that the school actually has a copy of the high school proof unless the student is selected for a V4 or V5 verification, but NACCAS does. I did send an email to Dr. Miranda, asking if they could provide relief during COVID-19 pandemic, but he said it is in the standards. He is willing to discuss the problem with is commission so hopefully they will be able to provide another way to enroll, such as asstestation from the student, until this is over.

A-9       Wonderlic is telling me they do not have the approval through DOE to deliver the ATB test online and none of their proctors will come on campus to proctor the exam (although I have social distancing ability). What can we do?

Q-9      ED has not approved any changes or options for ATB testing due to COVID-19. (this question was for a school who does ATB testing as part of the required entrance acceptance.)

Q-10a  the direct-to-student relief funds had a 75%/25% split where 75% of the funds were to be allocated to PELL recipients and the remaining 25% of the funds were to be allocated to non-PELL recipients.  Can you confirm/clarify if the 75%/25% split is a requirement, recommendation, suggestion, or an example?

A-10a   No, you do not have to divide the funds given to students that way.

Q-10b  Are there any minimum percentages to be allocated for each category (PELL recipient vs. non-PELL recipient)?

Q-10b  No, you can determine which students you believe have the biggest need and allocate all of the funds to that group, or come up with a formula that works.

Q-10c  Is it possible for the school to issue all 100% of available direct-to-student relief funds to PELL recipients?

A-10c   Yes, if that is what you decide that your policy will be.

Q-11    Now we are teaching distance ed. due to the COVID 19, when we enroll students into Fame I would imagine we check the box yes for distance end?

A-11     No, you do not

Q-12    When funds are received in the G5 account will the schools be notified by FAME and do we have to tell FAME which federal account to use?

A-12     When you receive your award letter, you create a ticket in customer support and provide the banking information at that time. Yes, you will be notified of the funds when FAME is able to draw them down.

Q-13    I have two students that went on LOA prior to the pandemic and have used the maximum 180 days. Neither have returned for online education and both have been contacted, one said he’d be back later, and the other one responded that he’d call back but has not. There is no change in the LOA policy for this pandemic correct? No extensions passed 180 days?

A-13     No, you cannot extend the LOA beyond 180 days, so you must drop them.

Q-14    The only part of the grant I don’t understand is what student enrollment list I’m allowed to use when distributing the emergency funds. Can I choose to use the list of student enrolled on March 26 and include students who have since graduated? I want to be able to use this list because I want help to go out to the couple of very recent graduates we have. But they don’t have education costs during the spring term, so I can see how including them could be an issue. Do you know anything about this?

A-14     The funds can be divided equally between the students, more to the neediest () EFC) and less to higher or non-Pell eligible students, you can reserve some for PJ due to economic hardship, loss of job, etc. during this period. The money is not connected to the current cost of education, but used for normal costs in the COA, such as room, food, health insurance, books, supplies, equipment paid for by the student for technology needed to complete their education. Just document how you determined how much everyone received and why. So yes, you can use it for recent grads, they too may have had hardships prior to graduation.

Q-15    You’ve mentioned a few times that we can hold some money for PJ purposes but we (as a school) never perform professional judgment in our financial aid office. So this is PJ being used by the FSA definition or do you just mean, we hold some of the money to dish out later – perhaps a second disbursement students at the start of our summer term in July to assist them at that time as well?

A-15     PJ is usually done when the student, spouse, or student’s parents used on the FAFSA, EFC made them not Pell eligible or only receiving a small Pell grant, have a loss of income due to losing their job, then you gather documentation (fact they applied for unemployment, or statement that they were self- employed and unable to work because of COVID-19, you could run a need needs based on projected income for a year and normal unemployment is not included for the next projected 12 months. The ISIR is reprocessed which normally results in a lower or 0 EFC. Now your student is eligible for more or full PELL, which helps them complete their education. So, if using PJ in this case, you would then be able to give money to non- Pell students.

I don’t think I would reserve it for July starts, the CARES ACT covers, current payment period, next payment period, and new starts through June 1st only. Even those students would have to have had their education interrupted do to COVID-19.

Q-16    If a student completed a FAFSA and was selected for verification but hasn’t completed verification, would they be eligible to receive the emergency grant?

A-16     Guessing on this one, but since the student wasn’t cleared for verification yet, and you know they were selected, I don’t think I would include her at this time, but maybe reserve funds for pending verification, and explained to the student that once verification is cleared the grant funds can be disbursed.

Q-17    I know that I read somewhere, but I can’t remember where, since I have read so many different things like you.  Do you know where it states that institutional funds as a part of CARES Act can be used for salaries, rent, loss of revenue, distance learning expenses, etc.

A-17     I think you may be mixing the payroll protection plan with Institutional grant funds. PPP allows you to cover payroll, rent, utilities, etc. Institutional grant funds cover any costs associated with significant changes to the delivery of instruction due to coronavirus such as funds to expand remote learning programs, build IT capacity laptops, software for on line platforms, and prepare faculty and staff to function at higher levels in remote learning. It does indicate institutions are permitted to use the institutional grant funds to reimburse themselves for refunds of room, board, and fees, not sure referring to our types of schools.

Q-18    I just read in some guidance from NASFAA that we should only be giving emergency funds to students who have COVID-19 related expenses not need. Can you give me an example of what type of expenses I would be able to demonstrate that our students have as a result of the COVID-19?

A-18     I think they were referring to your selection process, not necessarily giving it to just 0 EFC’s who are considered the neediest from ED’s prospective, but to students that have expenses because they may not be working etc. So as you said, everyone has expenses, housing, food, health care, gas or bus money. You talked about just dividing it among the students which again, I think is fine.

Q-19    Is there any relief for the Parent PLUS borrowers as far as deferments, suspension of loan payments, for 3 months and no loan accruals in the stimulus package?

A-19     To provide relief to student loan borrowers during the COVID-19 national emergency, federal student loan borrowers are automatically being placed in an administrative forbearance, which allows you to temporarily stop making your monthly loan payment. This suspension of payments will last until Sept. 30, 2020, but you can still make payments if you choose. If you have a parent PLUS loan, you are entitled to the same student loan relief options in the Coronavirus Aid, Relief, and Economic Security Act, or CARES Act, as other federal student loan borrowers.

Q-20a- I’ve heard that we can enroll new students for new pay periods until June 1.  Does that mean that any student enrolled into our TDE program after that date IS NOT eligible for CARES Act grant?  We enroll at least once per month.

A-20a   Currently, that is correct, I think even students until then may be questionable as an attend other sessions since they have emphasized in more recently that student money should be paid to students whose study was interrupted due to COVID-19 or has expenses as a result of it. So it sounds like it might be best to only cover current students

Q-20b- Can the institutional grant funds be used to pay standard school employee salaries or is that only expected to be paid through the PPP loan?  Current wording clearly states the grant funds cannot be used for executive salaries and bonuses.  Those and other words seem to IMPLY that standard employee salaries are eligible.

A-20b   That one is a clear no for institutional grant funds, unless you had to hire someone or paid for someone to learn how to teach through distance ed or had to hire a technology IT expert to get your program up on line. You can pay employees through the payroll protection plan.

Q-21    What change did the CARES Act make to FSEOG awards? We do not have FWS.

A-21     The only change to SEOG is that if you are no longer required to match funds.  So if you are a non cash match school and match using scholarships or tuition waivers, you are no longer required to do so.   That is effective immediately and all of the 20/21 award year.  If you have students that you want to increase their current award you can just increase the amount on the last screen of FA input.  If you have other Title IV students with a valid ISIR you can award them as well.

Q-22a  We have a nail tech program that does not receive Title IV funding as it is a 400-hour program. Are we required to inform them that the students enrolled in Title IV programs will be receiving grant money from the Cares Act?  Or can we just inform the students that are in eligible programs?

A-22a   No, but it might be easier in the long run so you don’t have to answer individual questions about the CARES Act since it is all over TV that students are receiving money. You might just send or post a statement indicating that unfortunately the CARES ACT Emergency Grant fund for students, as written by Congress, are only eligible for Title IV programs.

Q-22b  How do you advise when creating a policy for the student grant funds regarding students on LOA due to COVID19?

A-22b   You can just indicate all students on a LOA are eligible for the CARES ACT grant funds, or you could say that only students who took a LOA due to COVID-19 because of child care issues, distance education requirements, or technology challenges, or other extenuating circumstances are eligible.

Q-23    We are almost done with the application in SAM and we have yet another question! We are required to supply the bank account # for the HEERF student funds that the Grant $ will transfer into. If this is a one-time entry into, will we need to redo the application to submit a second account # for the HEERF Institutional money?

A-23     You have to submit a 2nd application for the HEERF institutional funds.

Q-24    Are we eligible to waive the match for FWS? I haven’t been able to find anything from the ED, just interpretations from NASFAAs webinar.

A-24     Yes, that was in the April 20, 2020 Electronic Announcement, but it is only for students not yet paid unless the student works for a for profit entity (not the school but private business). You just tell FMAE the hours worked, total amount and the drawdown is 100% federal money. That was part of the CARES ACT, and addressed in the initial guidance, but we were waiting for more guidance from ED. You also can move any remaining funds to FSEOG without the school getting a waiver, and the 7% community service and one project in America reads is exempt.

Q-25    Do the Dept. of Ed rules state we can only start a class up to 6/1/20 under the temporary DE guidelines?   Our accreditor told me its 6/30/20?

A-25     Accreditors may have gone to 6/30 in case ED extends, but right now per the 3/20/20 EA Q & A added to the 3/5 EA, said June 1.

Q-26    All of our current students we have in the school right now who are in their 1st payment period can do TDE and if we cannot go back to brick and mortar by the time they reach their 2nd payment period, they can still do TDE and we can still get paid for the 2nd payment period even if it’s after June 1st.?

A-26     Yes, those students would be eligible for their 2nd disbursement. Unless ED changes its rules these students and all continuing students starting up through June 1st all have to go back to brick and mortar once schools can safely open again, that could even be in late May or early June, we don’t know the time frame. Also, it could be different in each city & county, depending on your mayors and governors. So they could attend a week or not even start and no longer be able to do TDE, everyone will probably be in the middle of a payment period when this happens. Everyday right now is an unknown.


  • On the institutional fund portion of the grant. We did receive the PPP for payroll for I weeks, we are closed much longer than that and I was hoping to use these fund to help cover the remaining cost that weren’t covered before we received the PPP. I am assuming that is not allowed after reading above. I am not sure what we are suppose to use the institutional funds for, can you give us guidance on that?

    • Sally Samuels says:

      Hi Natalie,

      My immediate answer is no, but, we are waiting for some additional guidance from ED which hopefully answer questions such as, can we use the institutional grant funds for payroll, rent, utilities, etc. to help during the pandemic. We know the funds can be used to any costs associated with significant changes to the delivery of instruction due to coronavirus related to the disruption of education, which is a pretty broad explanation. We do know you can reimburse the school for laptops purchased for students to access on line classes or work, pay for increase in internet speed, on line platforms, training for instructors, new IT help, etc.

      You do have one year to use these funds, so you could to wait for more guidance. Remember, these funds can also be disbursed to students as additional grant funds.

      Stay Safe,


    • Kass Von der Mehden says:

      Can institutional funds go to pay an employee who is administering, training and attending all webinars associated with covid and distance ed? We wouldn’t be diverting our main job except for these circumstances.

      • Sally Samuels says:

        Hi Kass,

        No, the institutional funds can only be used to pay employees for additional training necessary for them to deliver temporary distance education.

        Stay safe.


  • Can you please clarify the 04/03/2020 guidance on SAP? Specifically, what is the current COVID time period for SAP exception regarding excluding the quantitative component? Guidance states: “Any payment period or term beginning between 3/5/20 and 06/1/20, inclusive. Flexibilities set forth remain effective until and through 6/30/20, unless the payment period crossover extends over award years and is attached oto the 19/20 awared year. In that case the effective date is through the end of the crossover payment period”.

    For example, if we have a term that began 2/20/20 and doesn’t end until 6/20/20, is this term given the SAP exception due to COVID, since we transititioned to online learning in March, 2020 and some students could not grasp the nursing material via online learning? Or another example: term began 3/9/20 and ends on 7/9/20; is this term given the SAP exception? My hiccup occurs with the guidance verbiage stating “term beginning between 3/5/20 and 6/1/20…neither of which these cases do.

    Final question: our SAP policy states that a student who may be failing can be placed on probation with an appeal and continue on to repeat a term. If the student’s reason for failing was due to not being able to transition to online learning (successfully), is he able to have the opportunity of the COVID SAP quantitative exception, even though he’s not withdrawing, just being transferred to another class to repeat the term?

    Thank you.

    • Sally Samuels says:

      Hi Sherri,

      Yes, both of the payment periods fall into the current COVID 19, payment periods that the SAP exception covers.

      Yes, and the student does not have to appeal the SAP to continue to receive financial aid.

      Stay safe,


  • Latoya says:

    Hello Sally,

    Do we have to open a dedicated bank account for the HEERF funds ? if so, where is the guidance can we find this information? Is it ok to post these payments to the ledger ?

    Thank you for your prompt response regarding this matter.

    • Sally Samuels says:

      There is no requirement to open another account, it just makes it easier to identity the CARES money, balances, and account for the HEERF funds.

      Yes, it is okay to post to the ledger, but make sure that they are coded in a way that doesn’t reduce institutional charges, or affect the 90/10 calculation. I believe they will have to be reported on the 1098 T so posting to the ledger may make that process easier.

  • Sherri Adduci says:

    Are students permitted additional term(s) to cope with Covid issues that are preventing them from achieving SAP, or are they limited to only the current term they’re attending?

    Thank you.

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