Do We Have To Report Students Who Withdrew After the 60% Point As COVID-Related Withdrawals?

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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).

Scenario: Jon officially withdrew from a payment period (term or nonterm) within the covered period (defined below). He withdrew after the 60 percent point, so he earned all of his Title IV aid for the payment period. He indicated on his withdrawal form that he withdrew from school because of COVID-19.

Answer: Yes, but only as long as the student withdrew for reasons related to the COVID-19 qualifying emergency. According to guidance NASFAA has received from the U.S. Department of Education (ED), when a student withdraws after the 60% point, the student has earned all of his or her Title IV aid that was disbursed or could have been disbursed, and there is no unearned aid to be returned. That student is still considered a withdrawal, and in this scenario, the student is a COVID-related withdrawal. ED considers the R2T4 waiver (defined below) to apply to these students even though there is no unearned aid. ED points out that CARES Act and the May 15, 2020 Electronic Announcement require an institution to report to ED information specific to each student for whom it was not required to return Title IV funds under the R2T4 waiver exception. It further requires that an institution report identifying information for each student for whom R2T4 was waived under the CARES Act. In other words, the school must report any student who withdrew as a result of COVID-19, even if the student withdrew after the 60% point of the payment period and earned all aid. See AskRegs Q&A, What Are the R2T4 Reporting Requirements Under the CARES Act?

When the school reports COVID-related withdrawals to ED using the Coronavirus Indicator:

When reporting "Identifying information for each student for whom R2T4 was waived under the CARES Act," ED says to include any student who withdrew from the institution during the payment period or period of enrollment as a result of circumstances related to COVID-19.

All students who withdrew because of COVID are eligible for these benefits. Students who withdrew for other reasons that are not related to COVID do not qualify for these benefits. This is why it’s so important for the school to determine whether their students' withdrawals were related to COVID-19.

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 or period of enrollment that falls within the covered period. For example, for a payment period that includes March 13, 2020, the waiver applies even to students who withdrew in January or before the disruption in campus operations due to COVID-19.

Covered period refers to the fact that the May 15, 2020 Electronic Announcement 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 last date that the national emergency is in effect.

Per the June 14, 2023 Electronic Announcement, this waiver concludes at the end of the payment period or period of enrollment that includes the date of May 11, 2023. Because different programs at the same institution may have different payment periods, this waiver may end at different times for those programs. For example, assume that an institution offers Programs A and B. Both programs have spring terms that include May 11, 2023, but Program A’s term ends on May 26 while Program B’s term ends on June 9. In that situation, this waiver ends for Program A on May 26, while the same waiver ends for Program B on June 9.

Update Notes:

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.