This guidance is not award-year-specific and applies across award years.
Yes. Under Section 3503 of the CARES Act, the institutional share requirements of the Federal Work-Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) programs shall be waived for the 2019-20 and 2020-21 award years in cases where the nonfederal share is paid by the institution. According to the May 15, 2020 Electronic Announcement, schools are not required to provide an institutional share for any FWS wages or FSEOG disbursements paid to students on or after March 13, 2020 through the remainder of the 2019-20 award year. NASFAA has confirmed with the U.S. Department of Education (ED) that the August 21, 2020 Electronic Announcement does not change this "on or after March 13, 2020" provision.
The institutional share waiver for FWS and FSEOG also applies to the entire 2020-21 award year, regardless of when the COVID-19 qualifying emergency is lifted.
The CARES Act does not waive the nonfederal share requirement for third-party private for-profit organizations that employ an institution's FWS students under an off-campus agreement under 34 CFR 675.20(b). Under such arrangements, the federal share cannot exceed 50 percent, and the private for-profit organization still must pay the nonfederal share of the student's compensation.
Note that if your institution decides to stop providing its institutional matching funds into its FSEOG fund, the institution will have less FSEOG funds to spend and will deplete those funds more quickly. The CARES Act does not require institutions to stop making the nonfederal match; that is the institution’s choice.
This waiver is automatic; the school does not need to submit a waiver request to ED. Per the May 15th announcement, "An institution may reimburse itself from the FWS allocation for the nonfederal portion of wages paid to students on or after March 13, 2020. Likewise, an institution may, for all disbursements of FSEOG made on or after March 13, 2020, reimburse itself from the FSEOG allocation for the nonfederal portion of FSEOG awards contributed through a fund-specific match." Consult with your business office on how this is done.
See also AskRegs Knowledgebase Q&As:
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.