Can Students Be Paid FWS When the School Does Not Close, Sends Students Home, and Moves All Classes Online Due to Coronavirus?

This AskRegs Knowledgebase Q&A was updated on September 22, 2020 to note that, under certain conditions, the following guidance applies to both the 2019-20 and 2020-21 academic years when a student's Federal Work-Study (FWS) job is interrupted due to COVID-19. See AskRegs Q&A, Can We Continue To Pay FWS Students Who Are Unable To Work FWS Jobs Due To COVID-19?, for the conditions and timeframes under which this flexibility applies. Otherwise, the following guidance has not changed.

Yes. According to guidance NASFAA has received from the U.S. Department of Education (ED), the March 5, 2020 Electronic Announcement and April 3, 2020 Electronic Announcement FWS guidance applies in instances when the school closes (temporarily ceases to offer instruction in any format for the remainder of the payment period) and when the school does not close, sends students home, and moves all classes to an online format via distance education for the remainder of the payment period. In fact, the FWS guidance applies in any scenario when the student is unable to continue an FWS job due to the school's or the off-campus employer's decision as a result of COVID-19 interruptions. This guidance has been confirmed in the COVID-19 FAQs document that was later added to the March 5th Electronic Announcement.

According to ED and the April 3, 2020 Electronic Announcement the school may choose to continue to pay students who are unable to continue working an FWS job due to a COVID-19 related disruption during the academic year (award period) only if all of the following conditions are met:

• The student was enrolled at an eligible institution and received an FWS award for the academic year during which a COVID-related disruption occurred;
• The student had already begun working and earning funds in that FWS job for that academic year before the COVID-related disruption occurred; and
• The student was prevented from fulfilling his or her FWS obligation for all or part of the academic year due to a COVID-19 related disruption, such as: 1) when a campus closes and/or must temporarily cease providing instruction due to COVID-19; 2) when a campus moves classes from ground-based classes to online classes due to COVID-19; 3) when an FWS student is employed by an employer that temporarily or permanently closes as a result of COVID-19; 4) when a student is quarantined due to COVID-19 and unable to travel to campus or his, her, or their jobsite; or 5) when other such disruptions occur due to COVID-19.

The FWS guidance in either Electronic Announcement does not apply to students who decide for themselves to leave campus and/or switch to online classes. These students are not eligible to be paid FWS for any hours they do not actually work. Also, if a student does not begin attendance in a term or nonterm payment period, then the student cannot be paid FWS for that term or nonterm payment period, as explained in the March 5th announcement.

According to ED, the student can be paid for the FWS hours he, she, or they were scheduled to work for the term or nonterm period. See AskRegs Q&A, How Do We Determine How Much To Pay FWS Students When Enrollment Is Disrupted By Coronavirus?

Notes: 

• The August 21, 2020 Electronic Announcement extends the above guidance 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.
• This AskRegs Q&A was previously updated on August 24, 2020 to inform schools that we remained unsure on whether the August 21, 2020 Electronic Announcement extends the ability for students to continue to be paid FWS funds if they are unable to work due to COVID-19 during the 2020-21 award year. That has since been clarified, as noted above.