Does the CARES Act Waive R2T4 Calculations When a Student Withdraws Due To COVID-19?

This AskRegs Knowledgebase Q&A was updated on January 31, 2023 to note that the COVID-19 national emergency will end on May 11, 2023.

No. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) does not provide a blanket waiver of R2T4 requirements. Schools still must complete the return of Title IV funds (R2T4) calculation for all withdrawn students for whom the calculation would normally be required, including those who withdraw as a result of a qualifying emergency.

The CARES Act waives the requirement for schools and students to return unearned Title IV grant and loan assistance as a result of the R2T4 calculation for students who withdraw from a qualifying period because of a COVID-19 emergency--that is, the "R2T4 waiver." This includes all Direct Loans (subsidized unsubsidized, graduate PLUS, and Parent PLUS). As a reminder, students and parents are already not required to return unearned loan funds under R2T4 rules; they repay the loan in accordance with the terms of the promissory note.

When the school later reports that the student was a COVID-related withdrawal, ED will cancel the Direct Loan and TEACH Grant disbursement for the entire payment period or period of enrollment within the covered period (defined below). ED will also exclude any Direct Loan subsidized usage period and Pell Grant payment from their respective lifetime limits.

In exercising the R2T4 waiver, schools will be required to report the following information to ED:

• Identifying information for each student for whom R2T4 was waived under the CARES Act;
• The payment period begin and end dates for the payment period or period of enrollment that the student did not complete as a result of the COVID-19 emergency;
• The amount of Title IV grant or loan assistance received for the payment period or period of enrollment in which the student withdrew; and
• The total amount of Title IV grant or loan assistance that each institution has not returned to ED as a result of the CARES Act R2T4 waiver.

For additional information, please see also AskRegs Q&A "What are the R2T4 Reporting Requirements Under the CARES Act?"

See also AskRegs Q&As, How Do We Implement the R2T4 Waiver If We Are Performing the First R2T4 Calculation For the Student? and How Do We Implement the R2T4 Waiver If We Are Re-Disbursing Aid We Already Returned Under the R2T4 Calculation?

R2T4 waiver refers to the fact that the CARES Act, waives the requirement for the school or the student to return Title IV funds when a student withdraws due to COVID-19 anytime during the entire payment period that falls within the covered period.

Covered period refers to the fact that the May 15, 2020 Electronic Announcement now allows schools to apply the R2T4 waiver to: 1) payment periods or periods of enrollment that include March 13, 2020; or 2) payment periods or periods of enrollment that begin between March 13 and the later of December 31 or the last date that the national emergency is in effect. See AskRegs Q&A, How Do We Determine If a Withdrawal Was the Result Of a Qualifying Emergency Due To Coronavirus?, for important details.

Payment Period Or Period of Enrollment: Remember that standard term programs must use the standard term payment period (semester, trimester, quarter) in the R2T4 calculation; they do not have the option to use the period of enrollment. A nonterm or nonstandard term program has a choice to use either the payment period or the period of enrollment in the R2T4 calculation. Therefore, it is NASFAA's understanding (because the Electronic Announcement language is unclear) that whichever period is used in the R2T4 calculation requires a determination of whether a student withdrew during that payment period or period of enrollment due to COVID-19.

August 21, 2020 Electronic Announcement Update: "Where an institution has opted to use the period of enrollment to calculate its returns for a non-term or non-standard term program, the waiver may apply to a student who begins attendance in a payment period that includes December 31, 2020 or the last date that the national emergency is in effect and withdraws after the conclusion of that payment period but within the applicable period of enrollment."

Notes:

• This Q&A was previously updated on August 26 to include clarification from the August 21, 2020 Electronic Announcement for nonterm and nonstandard term programs that use the period of enrollment (rather than the payment period) in their R2T4 calculations. It also reminds schools of the periods covered by the R2T4 waiver.
• This Q&A was previously updated on June 17, 2020 to point out that on June 16, 2020, ED made changes to the May 15, 2020 Electronic Announcement, which now expands the terms and nonterm payment periods to which the R2T4 waiver applies, as well as clarifies that the determination of COVID-19 related withdrawals are made on a payment period or period of enrollment basis.