How Will Seat Time Be Treated If Some Courses Are Completed Earlier Than Anticipated?

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

This AskRegs Knowledgebase Q&A has been updated due to an April 3, 2020 Electronic Announcement change in the process to request a reduction in the academic year.

According to guidance NASFAA has received from the U.S. Department of Education (ED), if students complete all of the academic requirements for the term and are being awarded the credits early, those students may be considered to have completed the term (and are not withdrawals). This is on a per student basis as each student completes course requirements, something which is expected to happen at different times for different students. Note that instruction must continue to be offered throughout the entire term. It would not be acceptable to to have a blanket early conclusion of the term with all students being considered to have completed the term early.

Per the April 3rd Electronic Announcement, "If an institution determines it will temporarily cease providing instruction, extend a break, or otherwise reduce the length of its term in a manner that results in fewer than 30 weeks of instruction in the academic year as the result of COVID-19 disruptions, it should send an email to [email protected] to request a temporary reduction in the length of its academic year. The request must:

Institutions should include in the subject line of the email the institution’s name, OPEID, and the state where the main campus is located. The request will be reviewed and forwarded to the appropriate School Participation Division, which will communicate its final determination to the institution."

See also the March 5, 2020 Electronic Announcement for more information on shortening the academic year.

Note: The above guidance does not apply to clock-hour programs and nonterm credit hour programs because Title IV progression is measured in the actual completion of hours and weeks of instructional time in the program's academic year. You have to complete both measures to be considered to have completed the nonterm payment period.


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.