Do the COVID-19 SAP Exceptions Apply To the Summer 2020 Payment Period Or To the 2020-21 Award Year?

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

This AskRegs Knowledgebase Q&A was updated on August 24, 2020 to reflect extended deadlines in the August 21, 2020 Electronic Announcement. Per the announcement, the following guidance applies through the end of the payment period that includes December 31, 2020 or the end of the payment period that includes the end date for the federally declared qualifying emergency related to COVID-19, whichever occurs later.

The COVID-19 SAP exception related to the quantitative component continues to apply for the payment periods noted above. This includes a summer 2020 payment period that is attached to the 2019-20 award year (i.e., a trailer) and a summer 2020 payment period that is attached to the 2020-21 award year (i.e., a header).

Section 3509 of the CARES Act sets forth no timeframe beyond the period of the national emergency, stating, "Notwithstanding section 484 of the Higher Education Act of 1965 (20 U.S.C. 1091), in determining whether a student is maintaining satisfactory academic progress for purposes of title IV of the Higher Education Act of 1965 (20 U.S.C. 1070 et seq.), an institution of higher education may, as a result of a qualifying emergency, exclude from the quantitative component of the calculation any attempted credits that were not completed by such student without requiring an appeal by such student."

See AskRegs Q&As:

Reference Section 484 of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1091]

Note: NASFAA's previous guidance was based on the April 3, 2020 Electronic Announcement, which appeared to limit the SAP exception to the 2019-20 award year.

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