Must We Change Disbursement Dates If Our Payment Period Starts Later Than Originally Scheduled Due To Coronavirus?

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

Scenario: Due to COVID-19, our school started the term or payment period later than the originally scheduled start date based on our academic calendar. Title IV disbursements were originally scheduled based on that original term/payment period start date.

Answer: Not as long as the preexisting disbursement date still falls within the 10-day window for making early disbursements under 34 CFR 668.164(i). If the revised academic calendar/payment period dates cause the preexisting disbursement dates to fall outside of that 10-day window, then you will need to obtain approval from your U.S. Department of Education (ED) School Participation Team to keep your disbursements the same. Otherwise, you must adjust the disbursement dates to reflect the revised payment period/term dates.

Schools with credit-hour programs are only required to request a reduced academic year if the new calendar results in fewer than 30 weeks of instructional time. Whether disbursements now fall outside the 10-day timeframe for early disbursements will depend on the start date of the revised calendar.

Reference Dear Colleague Letter GEN-17-08. See also AskRegs Knowledgebase Q&A, What Factors Do We Consider When Deciding To Extend a Break Or Revise Our Term Length Due To Coronavirus?

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.