What Are the Implications If a Student Has To Withdraw Due To Being Deployed In the Armed Forces?

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

If the student was deployed and had to withdraw, and it is unrelated to the Coronavirus (COVID-19) pandemic, the student may fall under the HEROES Act of 2003, which allows for "waivers of statutory or regulatory requirements to help [students] who are performing qualifying military service and [students] who are affected by a disaster, war or other military operation or national emergency." The student must be considered an "affected individual" which means the student:

For return of Title IV funds (R2T4), the requirement to return any grant overpayments is waived, along with reporting to the National Student Loan Data System (NSLDS) by the school. In regard to post-withdrawal disbursements, the 14-day period that a student or parent has to respond to an offer of a post-withdrawal disbursement is extended to 45 days.

See the September 29, 2017 Federal Register for information on Title IV credit balances when a student withdraws (page 45468).

For satisfactory academic progress (SAP), the school may include deployment as one of the special circumstances under which a student may appeal a negative SAP determination.

If the student was deployed and had to withdraw, and it is a result of the Coronavirus pandemic, the student would fall under the provisions of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act).

For R2T4, please see the following AskRegs Knowledgebase Q&As:

For SAP, the CARES Act states, "Notwithstanding section 484 of the Higher Education Act of 1965 (20 U.S.C. 1091), in determining whether a student is maintaining satisfactory academic progress…an institution of higher education may, as a result of a qualifying emergency, exclude from the quantitative component of the calculation any attempted credits that were not completed by such student without requiring an appeal by such student."

The March 5, 2020 Electronic Announcement also states that COVID-19 may be considered one of the special circumstances under which a student may appeal a negative SAP determination. 

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.