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

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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 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: 

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.