This AskRegs Knowledgebase Q&A has been updated to point out that this guidance applies to the 2019-20, 2020-21, and 2021-22 award years. As the federally declared national emergency has not yet been rescinded, the guidance may apply to award years beyond 2021-22.
Scenario: As allowed under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), our school transferred 100 percent of our unspent Federal Work-Study (FWS) funds into our Federal Supplemental Educational Opportunity Grant (FSEOG) Program. We are awarding those transferred FWS funds along with existing FSEOG funds as Emergency FSEOG due to COVID-19.
Answer: It is NASFAA's understanding that the same deadlines apply as regular FSEOG. FSEOG and Emergency FSEOG must be spent by the end of the award year to which the FSEOG allocation applies (June 30), or by the end of the summer crossover payment period that is attached to the end of that award year. Any FWS funds that were transferred to FSEOG and remain unexpended by June 30 of the applicable award year must be transferred back to the FWS Program. The reporting of the transfer occurs on the Fiscal Operations Report and Application to Participate (FISAP). Carry-forward rules also continue to apply. See Volume 6, Chapter 1 of the FSA Handbook. See also AskRegs Q&A, Can We Make Emergency FSEOG Awards For the 2020-21 Award Year?
Also, cash management rules in 34 CFR 668.164(j) still apply. For example, in order to be able to make a late disbursement of Emergency FSEOG/FSEOG, the student must receive the award before the student is no longer enrolled for the award year. See AskRegs Q&A, Can a Student Receive Emergency FSEOG If She Is No Longer Enrolled For the Award Year?
See the May 15, 2020 Electronic Announcement and AskRegs Q&A, How Can Schools Use Campus-Based Funds as Emergency Aid? for further guidance related to Emergency FSEOG. Also see 34 CFR 675.18(e), 676.16(a), and 676.18(b).
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