Is a Public State School Considered a State Entity When Excluding Emergency Relief From Income and EFA?

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

No. According to guidance NASFAA has received from the U.S. Department of Education (ED), a public state postsecondary institution is not considered a state entity for purposes of providing emergency funds to students due to Coronavirus (COVID-19).

According to the April 3, 2020 Electronic Announcement, "Any aid (in the form of grants or low-interest loans) received by victims of an emergency from a federal or state entity for the purpose of providing financial relief is not counted as income for calculating a family’s Expected Family Contribution (EFC) under the Federal Methodology or as estimated financial assistance [EFA] for packaging purposes."

According to ED, "This exclusion pertains to emergency relief offered by federal or state governmental entities for which the qualifying factor is having been the victim of an emergency or disaster. Additional institutional aid, even if offered by a public college or university which receives part of its funding from the state, is considered EFA. State support does not make the institution an entity of the state that is providing emergency relief and/or loans." 

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