Can Schools Using the COVID-19 R2T4 Waiver Re-Disburse Only Grants and Not Loans?

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

The May 15, 2020 Electronic Announcement does not specify an option to re-disburse only grant funding, stating simply that “Where returns have already been made, the institution should re-disburse Title IV funds to those students, making required adjustments in COD, crediting students’ ledger accounts, and requesting any necessary funds from G5.”

As such, it is NASFAA's understanding that, if the waiver is exercised, all Title IV funds should be re-disbursed. Note, however, that there is another provision in the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) that requires the U.S. Department of Education (ED) to provide loan forgiveness for any portion of a Direct Loan associated with a payment period from which a student withdrew as a result of a qualifying emergency. Therefore, re-disbursing Direct Loans ultimately will not add to the student’s debt, provided the R2T4 waiver is properly reported to ED.

See also AskRegs Q&A “Does the CARES Act Waive R2T4 Requirements When a Student Withdraws Due to COVID-19?

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.