Can We Disburse Title IV Aid To Students Enrolled In Alternative Skills Assessment Courses Due to COVID-19?

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

Scenario: Our school offers trade programs, such as welding, diesel, automotive, aviation, and machining. We are considering a skills assessment course for students in these programs in order to satisfy program learning outcomes during the COVID-19 outbreak. The courses would be an alternative for students who otherwise need to come on campus for coursework which is normally completed in person.

Answer: No. According to guidance NASFAA has received from the U.S. Department of Education (ED), Title IV aid may not be awarded or disbursed for assessments of students’ knowledge and or skills. Competency-based approaches are allowed, but only within the context of a program of instruction that is being offered and in which the student is participating. For more on competency-based educational programs, see Volume 2, Chapter 2 of the FSA Handbook.

If students in this scenario are not allowed to continue their program via online/distance education courses due to the COVID-19 interruption, these students are either withdrawals or can be placed on Title IV-approved leaves of absence (LOAs) according to guidance in the March 5, 2020 Electronic Announcement. Note the exceptions to the Title IV-approved LOA in AskRegs Q&A, Must It Be a Title IV-Approved Leave Of Absence To Qualify Under the COVID-19 Guidance?



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.