Are We Allowed To Extend Or Shorten Our Terms Or To Have Overlapping Terms Due To COVID-19?

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This AskRegs Knowledgebase Q&A was updated on December 18, 2020 to reflect the December 11, 2020 Federal Register which reaffirmed previously stated flexibilities for standard term programs through the end of the academic year that includes December 31, 2020 or the end of the academic year that includes the end date for the federally-declared qualifying emergency related to COVID-19, whichever occurs later.

Scenarios Due To COVID-19: One school extended the spring quarter into the summer crossover payment period due to the COVID-19 related disruptions of instruction and campus operations. Another school now offers courses on a schedule that normally would change its program format from standard terms to nonstandard terms. Another school wants to offer a shorter fall term. Another school wants to start fall semester classes earlier so they can send students home after Thanksgiving, and that fall semester will now overlap the summer term classes. Some schools will have overlapping terms during the 2020-21 award year/academic year--an occurrence that normally would result in nonterm programs. The original March 5th guidance also required the school to obtain U.S. Department of Education (ED) approval when reducing the academic year length to less than 30 weeks of instructional time.

Answer:  Yes to all of the above.

Under the March 5th Electronic Announcement and its attached Q&As, schools were previously allowed to extend a spring term and keep the program as a standard term program under limited circumstances. Schools were also allowed the spring term to overlap the summer term without having to change the entire program to a nonterm program. Per the attached Q&As, "
If an institution extends the length of a term to respond to COVID-19, causing the term to overlap a subsequent term, in this limited circumstance the institution may continue to consider its terms to be standard terms, allowing both the use of a scheduled academic year (SAY) for Direct Loan funds and Pell Grant Formula 1."


According to the June 16, 2020 changes to the March 5th announcement, ED is extending those flexibilities as follows:

“The Department is aware that, due to ongoing concerns over the COVID-19 emergency, many institutions have found it necessary to adjust their academic calendars. In recognition of this, we are expanding these flexibilities to include all programs, regardless of whether students are returning from travel abroad programs or have been cancelled out of experiential learning opportunities and extending applicable deadlines. All standard terms will be permitted to overlap with an adjacent term without the program being considered non-term. Additionally, a standard semester or trimester may consist of as few as 13 weeks of instructional time and a standard quarter as few as 9 weeks of instructional time without the program being considered a non-standard term program. It should be noted that any reduction in a program’s defined academic year to less than 30 weeks of instructional time must be specifically approved by the School Participation Division (SPD). Submit your request by email to [email protected]. This guidance is applicable through the end of the academic year that includes December 31, 2020 or the end date for the COVID-19 Federally declared emergency, whichever occurs later.”

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.