Can We Graduate Our Students Early Due To COVID-19 As Long As We Continue To Meet Academic Year Requirements?

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

Scenario: We have been asked by state authorities to permit our fourth-year medical students to graduate three weeks early to assist on the front lines of the COVID-19 pandemic. In this scenario, our semester would still be 16 weeks in length and our academic year would still exceed 30 weeks of instructional time. In terms of Title IV aid, this population would be eligible for Direct Loans.

 Answers: The following answers were provided to a school's questions by the U.S. Department of Education (ED):

Q1: If we were to offer this to our students, are there restrictions that would require ED approval?
A1: No.

Q2: Could we offer early graduation to all students and allow them to opt out, or must we make a decision to graduate all students early?
A2: That is an institutional decision.

Q3: Would this impact these students' eligibility, as all Direct Loans have already been disbursed?
A3: No impact.

Q4: What would be required on our end for Direct Loan processing? Would we need to alter the loan period for each student affected?
A4: No, ED is not requiring adjustments to loan periods in the Common Origination and Disbursement (COD) System, as would normally be the case otherwise.

Q5: We would obviously report the graduation date to the National Student Loan Data System (NSLDS) but are there other unforeseen issues with Direct Loans to consider?
A5: Not that come to mind now.

[Note: These students will graduate early, so it means they will go into repayment earlier than they originally anticipated. You will want to make sure your students are aware of this.]

Q6: What unintended consequences would we need to consider if this were approved?
A6: From a Title IV aid standpoint, none. You continue to meet academic year requirements. Shortening the program by a few weeks is academic matter.

Reference the December 11, 2020 Federal Register and the March 5, 2020 Electronic Announcement for additional guidance, especially if you reduce the number of weeks of instructional time in your academic year to fall below 30 weeks. See the April 3, 2020 Electronic Announcement for updated process for submitting requests to ED. See also AskRegs Knowledgebase Q&A, What Factors Do We Consider When Deciding To Extend a Scheduled Break Due To Coronavirus?

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