Can a Student Receive the CARES Act Withdrawal Benefits More Than Once?

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This AskRegs Knowledgebase Q&A was updated on December 2, 2020 to include additional guidance from the U.S. Department of Education (ED), indicating that the school does not need to wait for the National Student Loan Data System (NSLDS) to be updated before restoring annual loan limits to an affected borrower.

Yes. NASFAA has confirmed with ED that a student can withdraw due to COVID-19 and receive the CARES Act withdrawal benefits multiple times. That said, the school might consider asking for more "robust documentation" from the student should that happen.

Under the CARES Act, if the student withdraws from a payment period or period of enrollment as a result of COVID-19, the student will receive the following withdrawal benefits, as noted by marking the Coronavirus Indicator on eligible disbursements in COD. ED will:

It is possible for a student to withdraw due to COVID-19 during one term/payment period and then withdraw again due to COVID-19 during another term/payment period within the covered period (see below). When this happens, the student can receive the withdrawal benefits for both terms/payment periods.

According to ED, it is the school's decision as to whether it will accept a student's assertion that his, her, or their withdrawal was due to COVID-19. If the school finds a student repeating such behavior, "there is a reasonable person threshold beyond which a school might ask for more robust documentation."

For Example: The school treats summer 2020 as a header to the 2020-21 academic year. A student withdrew for reasons related to COVID-19 in the summer, and the school applied the R2T4 waiver by marking the Coronavirus Indicator in COD to indicate the Direct Loan disbursement for the summer loan should be cancelled. The student withdraws again in fall 2020 for COVID-19-related reasons.

According to ED, this is permissible. The student would be able to withdraw in summer, have the summer loan disbursement cancelled, and then return and borrow the full annual loan limit for fall-spring. Then, if the student withdraws due to COVID-19 again during the fall term, the fall disbursement would be cancelled, and the student could borrow the full annual loan limit during the spring 2021 term.

Once the school has determined that a loan disbursement will be cancelled due to CARES Act relief, it may exclude that loan disbursement from the student’s annual loan limit. The school does not need to wait for the NSLDS to be updated. The school may rely on its own records to determine that the loan disbursement will be cancelled. COD has been updated to prevent Direct Loan disbursements with the Coronavirus Indicator from counting toward a student’s annual loan limit and triggering edits that could result in the disbursement being rejected.

See also AskRegs Q&A, Can a Student Re-Borrow the Direct Loan Amount That Was Cancelled During the Same Academic Year Due To COVID-19?, which also addresses transfer students.

Covered Period: The May 15, 2020 Electronic Announcement now 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 later of December 31 or the last date that the national emergency is in effect. This is what we are calling the "covered period." In other words the covered period includes multiple payment periods or periods of enrollment. See AskRegs Knowledgebase Q&A, How Do We Determine If a Withdrawal Was the Result Of a Qualifying Emergency Due To Coronavirus?

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.