Must We Recalculate Title IV Aid and the COA If the Student Is Unable To Attend a Module Due To Coronavirus?

Yes and no. Existing rules continue to apply when it comes to recalculating enrollment status when a student fails to begin a course or module within the payment period. The March 5, 2020 Electronic Announcement does not waive enrollment status or enrollment status recalculation rules when a student fails to begin attendance in classes. While the Electronic Announcement only directly addresses failure to begin attendance in any classes under 34 CFR 668.21, the same general rules continue to apply when a student fails to begin a course or module but still attends other courses or modules. See AskRegs Knowledgebase Q&A, Are We Required to Verify That a Student Initiated Attendance In All Classes?

The recalculation rules are different for some of the Title IV aid programs. For Federal Pell Grants, if the student fails to begin attendance in all classes on which the Pell award was based, you must recalculate the student’s enrollment status and take into account any resulting changes to the student's cost of attendance (COA). This is true regardless of any census date or Pell Recalculation Date rules you have chosen to implement. The same rules apply to IASG and TEACH Grants.

If the student’s enrollment status changes, causing the COA to change, campus-based aid may need to be recalculated based on the revised COA.

For Direct Loans, it’s different. There is no recalculation policy for Direct Loans unless the student simply fails to begin attendance in any classes at all for the loan period. As long as the school verifies that the student was enrolled at least half time at the time of disbursement, the student remains eligible for the loan funds even if the student subsequently drops below half time. The school is not required to recalculate the student’s enrollment status or COA.

The same is true if your school disburses Direct Loans up to 10 days before the start of classes, as allowed under 34 CFR 668.164(i). If the student is enrolled, registered, or pre-registered at least half time at the time of disbursement, and then the student only begins one class at less-than-half-time enrollment, the student keeps the Direct Loan funds; you are not required to recalculate or reduce the loan amount based on the less-than-half-time enrollment. You just can't make any further Direct Loan disbursements until and unless the student resumes at least half-time enrollment.

Review the recalculation rules in Volume 3 of the FSA Handbook.

Neither the April 3, 2020 Electronic Announcement, the May 15, 2020 Electronic Announcement, nor the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) changes the above guidance.