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?
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