How Long Can We Extend a Term Or Payment Period Due To Coronavirus?

This AskRegs Knowledgebase Q&A was updated to include the latest guidance about the end date of the following COVID-19 waiver or flexibility in the June 14, 2023 Electronic Announcement (GENERAL-23-46).

Scenario: The COVID-19 FAQs attached to the March 5, 2020 Electronic Announcement indicate that a school can extend the spring term even if it overlaps with a summer term. We're wondering if the spring term can be extended into the regularly scheduled fall term (August/September).

Answer: According to guidance NASFAA has received from the U.S. Department of Education (ED), ED has not set a limit on how long you can extend a term, stating, "We have not limited the extent to which terms may overlap. But at some point, a reasonable person test should apply. Students can reasonably be expected to complete the academic requirements for only so many courses. An institution could, under professional judgment, adjust COA elements to account for expenses associated with a longer term."

According to the COVID-19 FAQs attached to the announcement: "The March 5, 2020 Electronic Announcement indicates that, in response to COVID-19, we can offer courses to students on a schedule that would otherwise be considered a non-standard term while continuing to offer Title IV aid using a standard term academic calendar. Can those courses also overlap courses in our summer term without causing our programs to be treated as nonterm programs?

Yes, the Department is extending the flexibility described in the electronic announcement to schedules that would otherwise be nonterm as well; for example, an extended spring term that will overlap with a summer term. If an institution extends the length of a term to respond to COVID-19, causing the term to overlap a subsequent term, in this limited circumstance the institution may continue to consider its terms to be standard terms, allowing both the use of a scheduled academic year (SAY) for Direct Loan funds and Pell Grant Formula 1."

The June 16, 2020 update to the March 5th announcement states: "The Department is aware that, due to ongoing concerns over the COVID-19 emergency, many institutions have found it necessary to adjust their academic calendars. In recognition of this, we are expanding these flexibilities to include all programs, regardless of whether students are returning from travel abroad programs or have been cancelled out of experiential learning opportunities and extending applicable deadlines. All standard terms will be permitted to overlap with an adjacent term without the program being considered non-term. Additionally, a standard semester or trimester may consist of as few as 13 weeks of instructional time and a standard quarter as few as 9 weeks of instructional time without the program being considered a non-standard term program. It should be noted that any reduction in a program’s defined academic year to less than 30 weeks of instructional time must be specifically approved by the School Participation Division (SPD). Submit your request by email to [email protected]. This guidance is applicable through the end of the academic year that includes December 31, 2020 or the end date for the COVID-19 Federally declared emergency, whichever occurs later." In other words, the flexibility lasts through the end of the academic year that includes April 10, 2023, which was the last day of the COVID-19 national emergency. See the December 11, 2020 Federal Register.

NASFAA cannot define "reasonable person test" for the school. The school will have to use its own discretion to determine what is and what is not reasonable in this regard. Any additional questions must go to your ED School Participation Division directly.

Update Notes:

• This Q&A was updated on April 11, 2023 to note that the general COVID-19 national emergency ended on April 10, 2023, while the separate public health emergency ended on May 11, 2023. With the introduction of two separate emergency end dates, it was unclear at the time which date was to be used for the expiration of the above COVID-19.
• This Q&A was updated on January 31, 2023 to note that the COVID-19 national emergency will end on May 11, 2023.
• This Q&A was updated on December 21, 2020 to reflect the December 11, 2020 Federal Register which reaffirmed above flexibilities for standard term programs through the end of the academic year that includes December 31, 2020 or the end of the academic year that includes the end date for the federally-declared qualifying emergency related to COVID-19, whichever occurs later. This extension was already granted under the June 16, 2020 changes to the March 5, 2020 Electronic Announcement.
  
• This Q&A was updated on September 1, 2020 to reflect the August 21, 2020 Electronic Announcement, which extended the above flexibilities for the same timeframe noted above.
• This Q&A was updated on June 17, 2020 to reflect June 16, 2020 updates made to the March 5, 2020 Electronic Announcement, which extended the above flexibilities for the same timeframe noted above.