Does the COVID-19 Verification Flexibility Allow the Student To Self-Certify Her Diploma Is the Equivalent To a U.S. High School Diploma?

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

This AskRegs Knowledgebase Q&A was updated to include the latest guidance about the end date of the following COVID-19 waiver or flexibility in the June 14, 2023 Electronic Announcement (GENERAL-23-46).

No. The flexibility in the May15, 2020 Electronic Announcement applies to both U.S. and foreign high school completers, but it only allows the student to self-certify that he or she has completed high school and received a high school diploma or its equivalent. That guidance does not permit the student to attest to the fact that the foreign high school diploma is the equivalent of a U.S. high school diploma or recognized equivalent under 34 CFR 600.2, "Recognized equivalent of a high school diploma." Making that determination is the responsibility of the school. See Volume 1, Chapter 1 of the FSA Handbook.

End Date of COVID-19 Flexibility: Per the June 14, 2023 Electronic Announcement, the above guidance now applies through the end of the first payment period that begins after April 10, 2023. For example, if April 10 falls during the spring term/payment period at your school, the flexibilities apply through the end of the summer term/payment period at your school. Because different academic programs at the same institution may have different payment periods with different end dates, waivers and flexibilities for those programs will end at different times depending on the end date of that first payment period that begins after April 10, 2023 for students in that program. See AskRegs Q&A, When Do the Various Title IV COVID-19 Flexibilities and Waivers End?

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.