Can We Pay FWS Students If We Don't Pay Non-FWS Students Who Are Unable To Work Due To Coronavirus?

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This guidance is not award-year-specific and applies across award years.

Scenario: The guidance in the March 5, 2020 Electronic Announcement indicates that we can pay FWS funds to students who were unable to work as a result of the COVID-19 outbreak if we are continuing to pay our other employees, including faculty and staff. We have student workers who do not receive FWS that will not work as a result of the outbreak. We also have certain other employees who will not be paid even though our faculty continue to teach classes.

Answer: Yes. According to the COVID-19 FAQs attached to the March 5, 2020 Electronic Announcement, "As long as the institution continues to pay its essential faculty and/or staff and continues to meet its institutional wage share requirement for the FWS program, it may pay students FWS funds for hours the students were scheduled to work, but could not work as a result of the COVID-19 outbreak. The institution is not required to continue to pay all employees who had been working prior to the outbreak if it has discontinued certain operations as a result of COVID-19.

Institutions that have received a waiver of the institutional wage share requirements under 34 CFR 675.26(d) continue to be exempt from the wage share requirements for purposes of the guidance in the March 5 Electronic Announcement."

See also AskRegs Knowledgebase Q&A, Can We Continue To Pay FWS Students Who Are Unable To Work FWS Jobs For the 2020-21 Award Year Due To COVID-19?

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