NASFAA AskRegs: Must the School Redo R2T4 Calculations That Were Done Before Payment Period Adjustments Were Made Due To Coronavirus?

This AskRegs Knowledgebase Q&A was updated on February 1, 2023 to note that the COVID-19 national emergency will end on May 11, 2023.

Generally no, unless the return of Title IV funds (R2T4) calculation was done incorrectly in the first place.

According to guidance NASFAA has received from the U.S. Department of Education (ED), the school generally is not required to redo any R2T4 calculations that were correct at the time they were initially performed. This is consistent with existing R2T4 guidance in Volume 5, Chapter 1 of the FSA Handbook. Per the March 5, 2020 Electronic Announcement, any R2T4 calculations for withdrawals that took place after the school's action to close and/or extend a scheduled break need to be performed using the adjusted payment period dates, and need to exclude any scheduled breaks of five or more consecutive days (numerator and denominator). This includes any extended breaks that fall within the payment period/period of enrollment being used in the R2T4 calculation due to COVID-19. The R2T4 calculation is based on the student's withdrawal date, rather than when the calculation is being performed. For example, if the student withdrew after the school extended the payment period or period of enrollment, you use the new extended dates in the R2T4 calculation.

The above guidance also applies when the school chooses not to implement the R2T4 waiver under the CARES Act (defined below). The same general rule applies when the school chooses to implement the R2T4 waiver under the May 15, 2020 Electronic Announcement. There is no requirement to redo or reverse any R2T4 calculations that were correctly performed; you just re-disburse or disburse Title IV aid based on the original R2T4 calculation. See AskRegs Q&As:

R2T4 waiver refers to the fact that the CARES Act waives the requirement for the school or the student to return Title IV funds when a student withdraws due to COVID-19 anytime during the entire payment period that falls within the covered period.

Covered period refers to the fact that the May 15, 2020 Electronic Announcement now allows schools to apply the R2T4 waiver to: 1) payment periods or periods of enrollment that include March 13, 2020; or 2) payment periods or periods of enrollment that begin between March 13 and the later of December 31 or the last date that the national emergency is in effect. The national emergency is now set to end on May 11, 2023. See AskRegs Q&A, How Do We Determine If a Withdrawal Was the Result Of a Qualifying Emergency Due To Coronavirus?, for important details.

Payment Period Or Period of Enrollment: Remember that standard term programs must use the standard term payment period (semester, trimester, quarter) in the R2T4 calculation; they do not have the option to use the period of enrollment. A nonterm or nonstandard term program has a choice to use either the payment period or the period of enrollment in the R2T4 calculation. Therefore, it is NASFAA's understanding (because the Electronic Announcement language is unclear) that whichever period is used in the R2T4 calculation requires a determination of whether a student withdrew during that payment period or period of enrollment due to COVID-19.

August 21, 2020 Electronic Announcement Update: "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."

Notes:

This Q&A was previously updated on August 26 to reflect extended timeframes in the August 21, 2020 Electronic Announcement. The above COVID-19 flexibilities now apply 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 qualifying emergency related to COVID-19, whichever occurs later. There was also clarification for nonterm and nonstandard term programs that use the period of enrollment (rather than the payment period) in their R2T4 calculations.
This Q&A was previously updated on June 17, 2020 to point out that on June 16, 2020, ED made changes to the May 15, 2020 Electronic Announcement, which now expands the terms and nonterm payment periods to which the R2T4 waiver applies, as well as clarifies that the determination of COVID-19 related withdrawals are made on a payment period or period of enrollment basis.