NASFAA AskRegs: Does the R2T4 Waiver For Not Returning Unearned Aid Also Apply To Unofficial Withdrawals?

This AskRegs Knowledgebase Q&A was updated on April 12, 2023 to note that the general COVID-19 national emergency ended on April 10, 2023, while the separate public health emergency ends on May 11, 2023. With the introduction of two separate emergency end dates, it is now unclear which date is to be used for the expiration of the COVID-19 flexibility/waiver discussed below. See AskRegs Q&A, When Do the Various Title IV COVID-19 Flexibilities and Waivers End?

Yes. There is no exception in the May 15, 2020 Electronic Announcement guidance for unofficial withdrawals. Therefore, the return of Title IV funds (R2T4) waiver (defined below) applies to all official and unofficial withdrawals during the payment period or period of enrollment within the covered period (defined below), even those who withdrew before the COVID-19 related disruption on campus or before March 13th in the payment period that includes March 13, 2020. It also applies if you are performing your all “F” grade review at the end of the term to determine if the student unofficially withdrew.

See the Electronic Announcement for more information. See also AskRegs Q&As:

R2T4 waiver refers to the fact that the CARES Act, waives the requirement for the school or the student to return Title IV funds when a student withdraws due to COVID-19 anytime during the entire payment period that falls within the covered period.

Covered period refers to the fact that the May 15, 2020 Electronic Announcement now allows schools to apply the R2T4 waiver to: 1) payment periods or periods of enrollment that include March 13, 2020; or 2) payment periods or periods of enrollment that begin between March 13 and the later of December 31 or the last date that the national emergency is in effect. The COVID-19 national emergency is now set to end on May 11, 2023.

Payment Period Or Period of Enrollment: Remember that standard term programs must use the standard term payment period (semester, trimester, quarter) in the R2T4 calculation; they do not have the option to use the period of enrollment. A nonterm or nonstandard term program has a choice to use either the payment period or the period of enrollment in the R2T4 calculation. Therefore, it is NASFAA's understanding (because the Electronic Announcement language is unclear) that whichever period is used in the R2T4 calculation requires a determination of whether a student withdrew during that payment period or period of enrollment due to COVID-19.

August 21, 2020 Electronic Announcement Update: "Where an institution has opted to use the period of enrollment to calculate its returns for a non-term or non-standard term program, the waiver may apply to a student who begins attendance in a payment period that includes December 31, 2020 or the last date that the national emergency is in effect and withdraws after the conclusion of that payment period but within the applicable period of enrollment."

Update Notes:

This Q&A was updated on February 1, 2023 to note that the COVID-19 national emergency will end on May 11, 2023.
This Q&A was updated on August 26 to include clarification from the August 21, 2020 Electronic Announcement for nonterm and nonstandard term programs that use the period of enrollment (rather than the payment period) in their R2T4 calculations. It also reminds schools of the periods covered by the R2T4 waiver.
This Q&A was updated on June 17, 2020 to point out that on June 16, 2020, ED made changes to the May 15, 2020 Electronic Announcement, which now expands the terms and nonterm payment periods to which the R2T4 waiver applies, as well as clarifies that the determination of COVID-19 related withdrawals are made on a payment period or period of enrollment basis.