No. According to guidance NASFAA has received from the U.S. Department of Education (ED), schools that are graduate or professional schools with no undergraduate programs, and that have a Federal Work-Study (FWS) allocation but no Federal Supplemental Educational Opportunity Grant (FSEOG) allocation, cannot transfer unused FWS funds into FSEOG to make Emergency FSEOG awards to students. The school must already be participating in the FSEOG Program. A graduate-only institution has no FSEOG allocation and no FSEOG fund into which FWS funds may be transferred.
ED cites Section 3503 of the CARES Act (bolded for emphasis):
"CAMPUS-BASED AID WAIVERS.
(a) WAIVER OF NON-FEDERAL SHARE REQUIREMENT.—Notwithstanding sections 413C(a)(2) and 443(b)(5) of the Higher Education Act of 1965 (20 U.S.C. 1070b–2(a)(2) and 1087–53(b)(5)), with respect to funds made available for award years 2019–2020 and 2020–2021, the Secretary shall waive the requirement that a participating institution of higher education provide a non-Federal share to match Federal funds provided to the institution for the programs authorized pursuant to subpart 3 of part A and part C of title IV of the Higher Education Act of 1965 (20 U.S.C. 1070b et seq. and 1087–51 et seq.) for all awards made under such programs during such award years, except nothing in this subsection shall affect the non-Federal share requirement under section 443(c)(3) that applies to private for-profit organizations.
(b) AUTHORITY TO REALLOCATE.—Notwithstanding sections 413D, 442, and 488 of the Higher Education Act of 1965 (20 U.S.C. 1070b–3, 1087–52, and 1095), during a period of a qualifying emergency, an institution may transfer up to 100 percent of the institution’s unexpended allotment under section 442 of such Act to the institution’s allotment under section 413D of such Act, but may not transfer any funds from the institution’s unexpended allotment under section 413D of such Act to the institution’s allotment under section 442 of such Act."
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