Can We Award Or Increase an Emergency FSEOG If the Student Is No Longer Enrolled For the Award Year?

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This AskRegs Knowledgebase Q&A was updated on May 19, 2021 to include confirmation NASFAA has received from the U.S. Department of Education (ED).

No. See AskRegs Q&A, How Can Schools Use Campus-Based Funds As Emergency Aid? If you don't see an exception listed there, an exception does not exist at this time, and all other Federal Supplemental Educational Opportunity Grant (FSEOG) rules continue to apply. Cash management rules in 34 CFR 668.164(j) also still apply. For example, in order to be able to make a late disbursement of Emergency FSEOG or FSEOG, the student must receive the award before the student is no longer enrolled for the award year.

According to ED, this also means you cannot award Emergency FSEOG after the end of the award year even if the student already had a regular FSEOG award during the award year. Additionally, the school cannot make a retroactive payment of Emergency FSEOG funds to a student who has withdrawn.

NASFAA has also confirmed with ED that the school cannot increase an FSEOG award or an Emergency FSEOG award after the student is no longer enrolled for the award year, even if the student had already received the same type of FSEOG award before the end of the award year.

Reference the May 15, 2020 Electronic Announcement for guidance related to Emergency FSEOG, which has been extended by the August 21, 2020 Electronic Announcement to apply through the end of the payment period that includes the end date of the COVID-19 federally declared qualifying emergency.

Update Note: This Q&A was updated on August 24, 2020 to reflect extended deadlines in the August 21, 2020 Electronic Announcement.


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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.