Is Emergency Aid Received For a Summer 2024 Period Of Nonattendance Treated As Other Financial Assistance?

Scenario: The school will be providing emergency aid/assistance to a student who is not attending classes during the summer 2024 period. The emergency aid will be provided to the student prior to July 1, 2024.

Answer: As a general rule, any student aid or benefit provided to a student during a period of nonattendance (like summer) will be treated as other financial assistance (OFA; formerly EFA) when packaging the student for the upcoming period of enrollment. According to guidance NASFAA has received from the U.S. Department of Education (ED), the emergency aid in this scenario would not be included as OFA because it is being packaged for the 2024-25 award year. Under Section 480(i) of the Higher Education Act of 1965 (HEA), as amended [20 USC 1087VV] and effective with the 2024-25 award year, emergency financial assistance provided to the student for unexpected expenses that are a component of the student's cost of attendance (COA) shall not be treated as OFA for Title IV purposes. The exclusion of emergency aid provision is for aid being packaged for the 2024-25 award year--not aid being packaged before or after a specific date.

Reference Dear Colleague Letter GEN-23-11.