Coronavirus Updates

Your latest Coronavirus (COVID-19) updates.

FAS Assistance

Financial Aid Services, Inc, and Genesis Software will:

  • Continue to operate during this Pandemic / State of Emergency with normal operating hours. We have made arrangements to be able to process and communicate with our client institutions should any or all of our team have to remain at home for a period of time.
  • Send updates directly to client schools on what to do next via email.   Watch your in box for these updates including how to obtain funds from the CARES Act Stimulus relief package.
  • Create a COVID-19 landing page on website to display all important updates higher education institutions need to be aware of.
  • Continue to make technical updates in its software and service adjustments and enhancements to allow remote working and distance learning.
  • Work with client schools during the Corona virus challenges. Help us Help YOU! Please call and ask for any assistance you can think of and we will discuss openly.

Updates

July 2, 2020

FAS ‘Cares’ , We are in this together!
High Volume Processing
Good afternoon,
We at FAS would like to share a reminder that we are in our peak processing months and COVID 19 is forcing a different work environment thus adding a little extra challenge this year. We also have extra-large processing volumes coming in at once, due to schools being closed then opening back up and many sending student disbursements in larger than normal batches. We are adding resources to turn around all student processing as
quickly as possible.  However, please anticipate processing to take a little longer than usual. We ask for your patience during this peak processing time. If you have any emergency processing, please email FAS versus calling and please only check on status if it is truly an emergency.
Thank you for understanding.
~The Team at FAS

 

July 2, 2020

FAS & Genesis will be closing today at 2:00 PM EST.
The office will also be closed on Friday, July 3rd, and will reopen on Monday, July 6th.
We hope you have a safe and wonderful
Holiday weekend!
Thank you!

June 25 2020

Urgent – Borrower Defense to Repayment Guidance Effective 7/1/2020

Borrower Defense Regulation: Spotlight on Direct Loan Discharges and Pre- Arbitration
Schools need to be aware that the BDR revises a Federal standard and a process for determining borrower defenses to repayment claims for Federal student loans first disbursed on or after July 1, 2020, and provide for actions the Secretary may take to collect from schools the amount of financial loss due to successful borrower defense to repayment loan discharges.

Closed School Discharge

· No longer supports the automatic discharge process for schools that close on or after 7/1/2020.
· Schools are encouraged to come up with a well-planned teach out for students before closing to reduce liability from having to reimburse ED for losses under closed school discharges.
· Student options – may apply for closed school discharge or participate in offered teach out.
· Extends qualifying closed school discharge enrollment periods from 120 days to 180 days before the school closed.
False Certification Discharge
· Federal loans discharged if the school certifies loans when the student was not a high school graduate.
· Exempt from false discharge if student knowingly claimed they were a high school graduate, when they were not; and had submitted a written attestation to school that they were.
Subsidized Eligibility / Interest Accrual
· Students not responsible for accrued interest in cases of discharge.
· Some instances where Subsidized Usage Period may be reduced due to remaining subsidized eligibility period greater than zero.
Allows use of Pre-Dispute Arbitration Agreements and Class action Waivers

**If your school requires students to sign a pre-dispute arbitration agreement and/or class action waiver as a condition for enrollment, PLEASE TAKE NOTE OF THE FOLLOWING:

· Plain language disclosure must be made available to the students, prospective students, and the public that this is a condition for enrollment. Certain verbiage must be included. Please see information below from Chris DeLuca.
· Must be plain language disclosure
· Place disclosure on website
· Create additional Entrance Counseling document to be signed by student
· Entrance Counseling Disclosure must include a clear description of the school’s internal dispute and arbitration process (*additional guidance below from Chris DeLuca)
· Must be signed off by the student prior to making any loan disbursements.
* Please note that FAS cannot provide a template due to variable school- specific procedures that should be included in your disclosures. We recommend seeking legal counsel.

FAS is proud to announce that we can share some additional guidance from Attorney Chris DeLuca *:
“While the new regulations allow a school to use pre-dispute arbitration agreements and class action waivers, that use is conditioned upon new disclosure requirements. Under 34 CFR 668.41, institutions must make certain disclosures of pre-dispute arbitration agreements and class action waivers to enrolled students, prospective students, and the public.
Paragraph (h)(1)(i) states that an institution must make available to students, prospective students, and the public:
a written (electronic) plain language disclosure of those conditions of enrollment. This plain language disclosure also must state that: The school cannot require the borrower to participate in arbitration or any internal dispute resolution process offered by the institution prior to filing a borrower defense to repayment application with the Department pursuant to § 685.206(e); the school cannot, in any way, require students to limit, relinquish, or waive their ability to pursue filing a borrower defense claim, pursuant to § 685.206(e) at any time; and any arbitration, required by a pre-dispute arbitration agreement, tolls the limitations period for filing a borrower defense to repayment application pursuant to
§ 685.206(e)(6)(ii).
The new regulations further provide that all statements in the plain language disclosure must be in 12-point font on the institution’s admissions information web page and in the admissions section of the institution’s catalogue.
The regulations also require that institutions that require students to sign pre- dispute arbitration agreements or class action waivers as a condition of enrollment include information in the borrower’s entrance counseling regarding the school’s internal dispute and arbitration processes. The school must provide:
a written description of the school’s dispute resolution process that the borrower has agreed to pursue, including the name and contact information for the individual or office at the school that the borrower may contact if the borrower has a dispute relating to the borrower’s loans or to the provision of educational services for which the loans were provided;
a written description of how and when the school’s pre-dispute arbitration agreement applies, how the borrower enters into the arbitration process, and who to contact if the borrower has any questions; and
an explanation of how and when the class action waiver applies, alternative processes the borrower may pursue to seek redress, and who to contact if the borrower has any questions.
Note that the new regulations also include a provision that an individual with expertise in the title IV programs is reasonably available shortly after a student borrower’s entrance counseling to answer questions (34 CFR 685.304(a)(5)).”

*Additional legal guidance provided by:
Christopher DeLuca
Attorney at Law | DeLuca Law LLC
Of Counsel, Rouse Frets White Goss Gentile Rhodes, P.C. 4743 Gallop Run | Mason, OH 45040
513.401.8977 Main | 513.401.8597 Fax| 513.382.4035 Mobile
DeLucaLawLLC.com 

June 18, 2020

FAS ‘Cares’ , We are in this together!
Important NEW Information About COVID Related Withdrawals
Dear FAS Clients,

ED has amended the May 15 Electronic Announcement with regard to which payment periods are eligible for the R2T4 Refund Waiver. The original guidance indicated that the student had to withdraw from a payment period that began on or included March 13, 2020.
The updated guidance indicates that the waiver applies to all payment periods that either include 3/13/20 or begin between 3/13/20 and the later of 12/31/20 or the last date that the national emergency is in effect.

Please keep in mind that these waivers can only be automatically applied to payment periods in which the student experienced a disruption of instruction. If no disruption of instruction is experienced during the payment period, the student must provide a signed/dated statement clearly indicating how the withdrawal is related to COVID in order for the waiver to be applied.

Feel free to contact the Compliance Team with questions!

Thank you!

June 17, 2020

FAS Times Update for New Award Year 20-21
We’ve Got You!

Interim Final Rule on CARES Act Emergency Grants
**Published June 17, 2020**

Today, June 17, 2020, ED published the interim final rule making eligibility for Higher Education Emergency Relief Fund (HEERF) grants to students only available to those students who “are or could be eligible for programs under Section 484 of the HEA”.

This rule will not be enforced retroactively. If your school awarded and disbursed funds prior to 6/17/20 and included students who do not meet eligibility criteria under Section 484 of the HEA, ED will not initiate any enforcement actions.

Any funds disbursed from today (6/17/20) forward must be disbursed only to students who meet eligibility criteria under Section 484 of the HEA.

Those eligibility criteria include:

Be enrolled or accepted for enrollment in a degree, certificate, or other program leading to a recognized educational credential at an eligible institution Maintaining Satisfactory Academic Progress (SAP)
Not owe a refund on grants
Not be in default on any student loans Sign a Statement of Educational Purpose Provide documentation of SSN
Be a US Citizen or Eligible Non-Citizen
Must not have been convicted on Title IV fraud Cannot be enrolled in an online program

We hope to see additional guidance released from ED shortly with regard to this final rule.

NEW SOFTWARE FOR FAS CLIENTS IS A GAME CHANGER IN VERIFICATION

One of the biggest burdens in the Financial Aid space is getting student files to clear verification timely so funds can be disbursed. From collecting the student’s documents, to comparing the data and resolving conflicting data and getting validated documents into the student file, verification no matter how you do it takes time and effort.

It is our latest software that streamlines electronic document transfer (soon using student mobility to collect documents directly from student’s mobile device,) and live tracking so clients know exactly what stage the verification file is in and simple uploading and sending protocols with guidance on what to place into a verification file.

VERIFICATION UPDATE: Summer Processing Guidelines

Hello FAS Clients!

On behalf of the FAS Verification Team, we do hope you all are staying safe and healthy during these unprecedented times!

As we all embark on the summer months ahead, FAS will see a significant increase in the volume of verification files submitted. Considering this uptick in volume, FAS has added additional staff to manage this increase in volume during these summer months to maintain acceptable turnaround times.

In order to assist our clients, FAS has also provided a list of “tips” that provide our clients with guidance on submitting successful verification files and decrease the likelihood of a rejected file, which lead to extended processing times.

A successful verification submission starts with YOU, the school:

· All Financial Aid staff should have a thorough understanding of the verification process and requirements. FAS is always available for additional training and guidance. CALL US!

· Perform an “Internal Verification” of all files prior to submitting to FAS. Review verification worksheets for completeness and accuracy
Cross check the verification worksheet information to that listed on the ISIR. Resolved conflicting information with the student/parent prior to uploading to FAS.

Confirm you have received ALL required documentation.

RUSH FILES

FAS understands the urgency of completing the verification review and our goal is always to meet your deadlines as quickly as possible, however we also strive to make sure we do not sacrifice the quality of our reviews. As we enter the “summer rush” in verification, rush requests will be processed under the following criteria:

Direct Loan certifications need to be completed due to graduation. Student is approaching graduation.
Student is withdrawing.
Student is crossing into the next academic year
Award Year deadline for verification processing – mid September deadline to be announced.

The FAS Verification Team looks forward to working with you and providing our continued, quality service during these busy months ahead.

Please contact at any time at verification@fasinc.net.

PELL CROSSOVER PAYMENT PERIOD EXPLAINED

Pell Crossover payment periods can be confusing. Pell award years run from July 1st to June 30th of a given award year. Pell is award year specific and if a Pell payment period occurs entirely within one award year it must be paid from that award year. If a Pell payment period falls
/ crosses into two award years (starts prior to July 1 and ends after July 1) this is a “crossover payment period student”. In this scenario you could look at remaining current year Pell eligibility (if any) and next year’s eligibility and assign the crossover payment period to either award years. Keep in mind the award year chosen should be the one that’s most beneficial to the student.

If you have specific scenarios or questions please reach out to the Pell team (pell@fasinc.net)

DIRECT LOAN CLOSEOUT

FAS will be contacting schools that processed loans during the 2018/2019 award year. Schools with pending 18/19 disbursements will need to let us know to either cancel the pending disbursements or provide the anticipated date of disbursement. All disbursements must be cancelled or disbursed no later than 7/15/20 to allow sufficient time to get the school closed out by the 7/31/20 deadline.

Once there are no pending disbursements, schools will be asked to complete the Consent to Close form. On this form, schools will attest to having no further 18/19 disbursements to be paid. Schools will also be required to provide the net total received for 18/19 loans per their internal school management records. To get the net total, schools will  take  the  total disbursements received and subtract the total refunds made to DOE for the award year. This form will be emailed  back to directloans@fasinc.net. Once received, FAS will confirm that the school’s balance reconciles to ours and COD. If it does, we will schedule you for closeout on COD. If it does not, we will contact you to resolve the  issue.

Feel free to contact directloans@fasinc.net with any questions!

RECONCILIATION OF FEDERAL ACCOUNTS FOR DIRECT LOANS and PELL
In order to keep your institution compliant and avoid audit findings, do not get behind in reconciling monthly bank statements and student disbursements. Remember to upload bank statements to FAS and always review your EDGE portal for any outstanding Action Required notices that still need to be resolved. Call FAS if you have any questions.

DIRECT LOAN GENERAL UPDATE FOR 2020-2021

Attn: Term Schools
Are you submitting FASApps with incorrect or missing term dates because you do not see the proper dates listed? Please be sure to send us your new term dates for 20/21 if you have not already done so! Please send to directloans@fasinc.net

Please note: when completing FASApps if there is only one set of dates for a specific budget this will be auto filled and you will not be required to choose the term. Also, if a budget is LHT you will not see term dates as these students are ineligible for loans.

20/21 Award Year
The 20/21 Award Year runs from 07/01/20-06/30/21. You may use this Award Year for any loans with a loan period that falls in this time frame.

Dependency Changes
Do you have students that were Dependent for 19/20 but are now Independent for 20/21? If the students loan period crosses over into the new award year you are able to award the additional Independent level funding from the new year.

Example: students loan period from 05/01/20-10/01/20. Student received $3500 sub and
$2000 unsub from 19/20, you may submit for the additional $4000 unsub from 20/21.

Origination Fees
Direct Loan origination fees change every October 1st. The new fees have not yet been announced therefore please refrain from submitting FASApps for any loan period that starts on or after 10/01/20 as we do not yet have the proper origination fees for these loans

Direct Loan Certifications
Please be sure that you are printing and reviewing all Direct Loan certifications. Check for any comments from FAS regarding changes made to the FASApp request and update the Award Letter as needed.

FASLine Reports

Please be sure to utilize the FASLine reports for students missing MPN’s and students missing Entrance Counseling. You will not see disbursements in FASLine unless FAS has both the MPN and Entrance Counseling on file.

ANTICIPATED DISBURSEMENT LOCK REMINDER
Any disbursements that appear in red on your Anticipated Disbursements List currently have a disbursement lock for a pending C Code, pending Verification or a subsequent ISIR that must be reviewed. Please contact verification@fasinc.net for ALL disbursement lock inquiries. The Direct Loan and Pell Departments do not set or release disbursement locks.

PLUS Loan Overrides
When a parent is approved for a PLUS loan but the school wishes to override this decision this is not a Professional Judgement. If the school chooses to override the PLUS loan credit decision due to exceptional circumstances and the parents inability to repay the loan you just need to have all supporting documents in the file. If the school finds a written statement sufficient that is fine. Whatever the parent can provide that supports the schools decision for the override needs to be kept in the student file. The Department doesn’t have any specific paperwork requirements, you will just want to be sure that anything supporting your decision is kept in the student file. NOTE: FAS does not request documentation of this. Please just be sure to select ‘Yes’ on the FASApp in the ‘Eligible for Additional Unsub’ section.

2020-2021 Federal Student Loan Rates Drop To Record Lows!
Interest Rates for Direct Subsidized Loans, Direct Unsubsidized Loans, and Direct PLUS Loans first disbursed on or after July 1, 2020, and before July 1, 2021.
Undergraduate Direct Loans: 2.75% Graduate Direct Loans: 4.30%
Graduate and Parent PLUS Loans: 5.30%

GENESIS ONLINE
For 20 years Genesis School Management Software has tracked all student data during the student’s life cycle from student leads to enrollment to program scheduling and grades, to billing and financial aid disbursements to clinics, services and live time tracking, POS, to graduation and more! Genesis has provided schools with easy and compliant reporting to all agencies including Accrediting, Department of Education and State and even the IRS for 1098 T. Genesis then provided student mobility access and texting features. Now Genesis offers its latest ONLINE version.

Do you have multiple campuses? Do you need access remotely to your student data? Ask about the power and capabilities of Genesis ONLINE!
Call us at 800-432-7462 or email Ronda@fasinc.net.

FAS is still working while staying safe at home.

We give you a peak into our home offices with our message to you in our latest FAS Working Remotely Video. We are Here for YOU!

 

 June 12, 2020

FAS ‘Cares’ , We are in this together!
 
CARES Act Update
 
Thank you to all who attended our CARES Act and Higher Education Emergency Relief Fund Webinar, yesterday.
 
For those that missed this very important webinar, don’t worry. We have made the webinar and materials available for you to review at your leisure. Don’t wait too long to review. The Webinar and Power Point contain some very important and timely information you need to be aware of.
 
Please log into FASLine to download both the Power Point presentation and the Questions and Answers. See diagram below:
 
For the webinar portion, please visit our website under Covid-19 Resources or click below to watch the webinar on YouTube.
 
If you have any questions, please do not hesitate to reach out to the Compliance Team:
 
We’ve got you!

We’ve got you!

 
 
 
 
 

June 10, 2020

CARES Act Update

COVID-19 Verification Flexibilities Extended to include the
2020-21 Award Year.
This notification has been updated to reflect the U.S. Department of
Education’s (ED’s) latest interpretation of the verification flexibility
timeframes provided in the April 3, 2020 Electronic Announcement.
The verification flexibilities (waivers) in the April 3 announcement can
apply to the 2020-21 award year. According to verbal guidance received
from ED, the deadline for the verification flexibilities in the April 3rd
announcement is date-specific, not award-year-specific. This allows the
flexibilities to apply more broadly to both the 2019-20 and 2020-21 award
years. Even then, ED has not yet specified (and apparently won’t specify)
whether the deadline is for receipt of documents or completion of
verification before the deadline.
The April 3rd Electronic Announcement extends verification flexibilities
related only to identity and Statement of Educational Purpose, as well as
to parent signature requirements for household size and number in
college. As for deadlines, the announcement states:
“Unless otherwise specifically stated in this guidance document, the
emergency flexibilities…remain effective until and through June 30, 2020,
unless the payment period crossover extends over award years and is
attached to the 2019-2020 award year. In that case the effective date is
through the end of the crossover payment period."
Since ED has not yet specified whether the deadline is for receipt of
documents or completion of verification before either June 30, 2020 or
the end of the 2019-20 crossover payment period (if there is one), it is
the school’s decision to make. Lacking any further guidance from ED,
make your decision and apply it consistently. For example, if you don’t
have summer 2020 classes or if your summer crossover payment period
is not assigned to the 2019-20 award year, your deadline can be June
30, 2020 for students to submit 2020-21 verification documents using the
flexibilities for identity and Statement of Educational Purpose, as well as
for household size and number in college. Or, your deadline can be that
2020-21 verification of those four data elements must be completed on or
before June 30, 2020 using the flexibilities. On the other hand, if you
have a summer crossover payment period that is assigned to the 2019-
20 award year, you can change your deadline date to be the end of that
crossover payment period (instead of using June 30th).
Note: The above guidance does not apply to verification of high school
completion.
**Source: NASFAA

May 18, 2020

FAS ‘Cares’ , We are in this together!
CARES Act Update

On Friday, May 15, 2020, ED released updated guidance regarding the CARES Act:

Distance Education
– ED is extending the broad approval for the use of distance education through December 31, 2020.
– Accreditation requirements: ED is waiving its requirement that programs offered via distance education be accredited by an agency that has distance education in the scope of its recognition by the secretary. This requirement is being waived under the Higher Education Relief Opportunities for Students (HEROES) Act for payment periods that begin on or before December 31, 2020.

Return of Title IV Funds Requirements
Regulation: Schools may waive the requirement to refund unearned funds for students who withdraw as a result of COVID-19 related circumstances. This waiver applies to any student who begins attendance in a payment period that begins on or includes March 13, 2020, and subsequently withdraws from the payment period.
Clarifications:
– Any institution that moved from ground-based instruction to distance education, closed campus housing or other campus facilities, or experienced other interruptions in instructions may consider all withdrawals from students enrolled in ground-based instruction during the covered period to have been the result of circumstances related to COVID-19.
– Schools with existing online programs must be able to document via written attestations from the student that their withdrawal was due to circumstances related to COVID-19 if a student was enrolled in a solely online course.
– Schools that have previously refunded unearned funds that could have been waived may re-disburse them. Please email the compliance team if you need to re-disburse funds.
– Please continue to submit R2T4s as normal and notate “COVID-19” if you intend to waive the refunds.
Reporting Requirements:
– ED will require schools to report students that have withdrawn as a result of circumstances related to COVID-19. For these students, ED will:
o Cancel the entire amount of any loan disbursements borrowed by the student or his/her parent for the payment period
o Exclude from SULA usage and Pell LEU any payment period that the student is unable to complete due to a qualifying emergency
– Retain the following information for all waived refunds: (additional guidance on how to report is still pending)
o Identifying information for student
o The payment period begin and end date for the period the student did not complete
o The amount of Title IV grant or loan assistance that the student received for the payment period in which he/she withdrew
o The total amount of Title IV grant or loan assistance that each institution has not returned to ED as a result of CARES Act provisions.

Financial Statement and Compliance Audits
– Under the HEROES Act, ED is extending the audit deadlines by 6 months.

Verification of High School (or Equivalent) Completion Status
– For applicants in verification groups V4 and V5, institutions should use documentation of an applicant’s high school completion status that it may have already obtained for other purposes. If an applicant is unable to obtain this documentation, the institution may accept a signed/dated statement from the student in which he/she truthfully attests to his/ her secondary school completion or equivalent. The statement must indicate:
o Whether a high school diploma or the equivalent was obtained
o Date of Completion (or approximate date)
– This guidance applies until December 31, 2020 for the 19/20 and 20/21 award years.
– Schools with policies requiring an official transcript to verify a student’s Title IV eligibility, may accept the same written statement to satisfy the requirements of their policy.
– Schools must verify the requirements of its accrediting and state agency for purposes of enrollment, however, ED is granting authority to accrediting agencies to implement temporary changes to its policies regarding verification of high school completion through December 31, 2020.

Campus Based Waivers/Reallocation and SEOG Emergency Grant Aid
– Section 3503 of the CARES Act waives the institutional share requirement associated with FWS and SEOG for the 19/20 and 20/21 award years.
o An institution may reimburse itself from the FWS allocation for the non federal portion of wages paid to students on/after March 13, 2020.
o An institution may reimburse itself from the SEOG allocation for the non federal portion of SEOG awards made thought a fund-specific match, for any disbursements made on/after March 13, 2020.
– Schools may use any portion of its SEOG funds to provide emergency financial aid grants to assist graduate and undergraduate students with unexpected expenses and unmet financial need as the result of COVID-19.
o SEOG awarding rules are waived for purposes of making SEOG Emergency Aid Grants. SEOG Emergency Aid Grants are not considered EFA.

Tax ability of HEERF Funds
– The IRS has confirmed that funds received under the CARES Act will not be included in gross income.

Accrediting Agency Virtual Evaluation Visits
– The guidance permitting accrediting agencies to conduct virtual site visits have been extended through December 31, 2020.
– Accrediting agencies are required to perform and on-site visit following the virtual site visit within a reasonable time frame. This visit does not need to repeat the full review.

Change of Ownership
– ED is granting schools and additional 6 months (after change of ownership is reported) to provide the accrediting agency and state approvals as well as the same day balance sheet.

Paycheck Protection Program and Composite Scores
– Schools must report the expected or actual amount of loan forgiveness with their audited financial statements. This must be attested by the institution’s auditor. This forgiven amount of the PPP will be excluded from total liabilities and increase the institution’s equity or net assets by that amount in calculating the school’s composite score.

MCAT Testing
– The HEROES Act allows foreign graduate medical school admissions for students without the MCAT requirement for any admissions year in which the MCAT was unavailable to students for some period of time during that year due to COVID-19 related interruptions

May 6, 2020

FAS 'Cares' , We are in this together!
Interim Reporting Guidance for Student Portion
Higher Education Emergency Relief Fund (HEERF)
On May 6, 2020, ED released the following interim reporting guidance for the Student Portion of HEERF.

The Department will provide instructions for providing the required information to the Secretary in the near future. In the meantime, each HEERF participating institution must post the information listed below on the institution’s primary website.

The following information must appear in a format and location that is easily accessible to the public 30 days after the date when the institution received its allocation under 18004(a)(1) and updated every 45 days thereafter.

1. An acknowledgement that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students.

2. The total amount of the funds that the institution will receive or has received from the Department pursuant to the institution’s Certification and Agreement for Emergency Financial Aid Grants to Students (this includes the student portion only).

3. The total amount of the Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30 day report and every 45 days thereafter).

4. The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act.

5. The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act.

6. The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act.

7. Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants.

May 1, 2020

FAS 'Cares' , We are in this together!
Pell Grant & Direct Loan Disbursements

Hello FAS Clients!

We hope you are doing well and are able to function smoothly and stay afloat during these pandemic challenges.

We wanted you to be aware that when requesting your “FIRST” PELL and/or Direct Loan disbursement for your students for the 2020/2021 Award year, the disbursements will be delayed one business day compared to usual cycle in depositing into your Federal Account.
Why the delay?

The Department of Education’s G5 payment system must create this new Award Year once they receive the electronic COD Accepted disbursement records that FAS submits the night before. Please communicate this to any involved departments or staff at your school who work with these incoming disbursements.

Thank you.
Be well and be safe.

Sincerely,

The FAS Pell & Direct Loan Departments

April 28, 2020

FAS 'Cares' , We are in this together!
Enrollment Reporting Update
New CIP codes going into effect for 2020-21 Award Year and Impact on ERR Reporting and NSLDS.

As a courtesy to our clients, FAS would like to remind Institutions that the U.S. Department of Education’s National Center for Education Statistics (NCES) has updated the Classification of Instructional Programs (CIP) codes for 2020. The 2020 CIP codes list of eligible majors and their corresponding CIP code values is available on the NCES website at nces.ed.gov/ipeds/cipcode.

In late April 2020, NSLDS enrollment reporting will be updated to allow the reporting of 2020 CIP codes via batch, the NSLDS Enrollment Spreadsheet Submittal process, and the Enrollment Maintenance page of the NSLDS Professional Access website.

A school may continue to report 2010 CIP codes to NSLDS until the school is prepared to report 2020 CIP codes. When the school is ready, the school will update the CIP Year to 2020. However, once the school has certified a program with 2020 CIP on NSLDS, a new error will be produced if the school reports a 2010 CIP code for the same program.

NSLDS will be enhanced so that when a school reports a program with a 2020 CIP Year and the same school-reported 2010 CIP Year program already exists in the database (all program identifiers except CIP Year are identical), the active enrollment history from the 2010 CIP program will be transferred to the 2020 CIP program.

IMPORTANT CHANGE IN FASLINE!

FAS will be rolling out an updated version of the Enrollment Report in FASLINE with the following changes allowing an institution to update the program CIP code for the 2021 award year.
Please note, NOT ALL programs will have an updated CIP code. Please review your specific program for possible updated CIP Codes. FAS has also updated its list of most common CIP codes in the FASLINE ERR report.

For questions, please feel free to contact the ERR Department at ERR@fasinc.net.

April 22, 2020
FAS 'Cares' , We are in this together!
COVID-19 Relief and CARES ACT Update Part IV

Important Update from FAS
ED released new Q&A to provide clarification related to the STUDENT portion of the HEERF Funds.
Please find full Q&A here: FAQ document

Below are some highlights:

Students must be Title IV eligible to receive these grants. This includes:
-Students who have filled out FAFSA forms
-For students who have not filled out FAFSA forms:
Must be US Citizen or Eligible Non-Citizen
Must have a valid SSN
Must be registered with Selective Service, if applicable
Must have a HS Diploma or recognized equivalent
-Students who were enrolled solely in online education as of March 13, 2020 are NOT eligible for grant funds
-These grant funds WILL NOT be counted as revenue for purposes of 90/10 calculations
-These funds CANNOT, under any circumstances, be used to pay outstanding balances due to the school.
-If a school had paid institutionally-funded emergency grants to students that are eligible under the HEERF program, schools can reimburse themselves for all or a portion of what they paid to a student dependent upon the schools awarding policy.
-Schools cannot reimburse themselves for refunds of room and board, tuition or any other fees.
-Schools cannot reimburse themselves for any information technology hardware (laptops, hotspots, etc) or other related equipment provided to students.

FAS Postpones Spring Seminar to March 18-19, 2021
After watching this pandemic become a much longer event. FAS has decided to move our Financial Aid Seminar and Workshop to March 18-19, 2021.

Please cancel your flights if you have not already done so. Also cancel any room reservations if you already booked!

The Low Down Hoe Down on Financial Aid Seminar will be at the same place, The Gaylord Resort in Nashville, TN and have the same format and updated topics most likely with an added amount of important data based on this historic pandemic.

FAS is certain that this was the right move since many clients and attendees have expressed continued concern for travel and exposure at large events in the coming months. We will honor all registrants who already registered and welcome new registrants for new date with same room block. We are in the process of updating our website and Registration. More info to follow.

COD Outage Alert 4/24/20-4/26/20
Please note outage alert dates.
This may delay your student disbursements during this time.

Any Direct Loan or Pell disbursements released (submitted) in FASLine after 4pm ET on Thursday (4/23/20) and on Friday (4/24/20) will not appear on a voucher until Tuesday, 4/28/20.
Institutional Share of Higher Education Emergency Relief Funds Now Available!
Secretary DeVos announced, yesterday, that the funds for the Institutional Share of the HEERF are now available. Please note that the school must have already applied for the Student Share in order to submit the application for the Institutional Share.

Below are links to the associated documents:

Letter from the Secretary (Announcement of Award)
CARES Act grant funding cover letter: PDF (156K)
A Certificate of Agreement (This must be signed and uploaded to www.grants.gov)
CARES HEERF Certification and Agreement: PDF (891K)
Formula allocations
Allocations for Section 18004(a)(1) of CARES Act: PDF (2.01M) (Please see this sheet for your allocation amount to be used on the certification form and the application form in grants.gov. This is in order by state and then institution name)
Methodology for Calculating Allocations: PDF (138K)

Application Process:
-Print and sign the certification form
-Log into your grants.gov account
-Search for Award: ED-GRANTS-042120-004
-Click Apply
-Submit any required forms
-Upload certification form

If you experience any issues with application and uploading process within grants.gov, please reach out to their Customer Support at 1-800-518-4726.

Please email complianceteam@fasinc.net once your application has been submitted and we will monitor G5 for the funds to become available for draw down.

What are the Requirements for Using Electronic Signatures on Verification Documents?
As we all navigate through these interesting times, the FAS Verification Team has received several inquiries on the topic of electronic signatures. With today’s technology, we are presented with many “digital options” to sign a document, however, the Department has provided very clear guidance pertaining to the use of digital signatures for Federal Verification Forms.

At this time, no further guidance has been made by ED pertaining to any type of relief from these regulations, therefore the FAS verification team will only process forms with electronic signatures based on the following guidance from ED:

In general, any document which a school collects electronically, including tax returns and other verification documents, may be signed electronically as long as the school is in compliance with guidance provided by the U.S. Department of Education (ED) in GEN-01-06, “Standards for Electronic Signatures in Electronic Student Loan Transactions (Standards)," for implementation of the Electronic Signatures in Global and National Commerce Act (E-Sign). Please see Volume 2, Chapter 7 of the FSA Handbook. When considering implementation of electronic signatures for Title IV and/or other purposes, ED recommends schools consult with their information technology (IT) staff and/or legal counsel to ensure there is no violation of the E-Sign Act or with state law related to the electronic signature.

To assist our clients with implementing methods that follow the above guidelines, we have created a video for your convenience providing instructions on setting up an acceptable electronic signature that is approved for Federal Verification Documents through Adobe certificates. Also, electronic signatures through Docu-sign are also acceptable.

The FAS Verification Team will continue to monitor all Federal Updates provided by ED for additional verification relief during the Covid-19 Pandemic.
Further questions or guidance can be emailed to verification@fasinc.net.

April 10, 2020
FAS 'Cares' , We are in this together!
COVID-19 Relief and CARES ACT Update Part III
Important Update from FAS
Department of Education Releases Update Regarding CARES Act Funding:

“We are currently experiencing technical challenges with grants.gov, and we will post an updated notice on this web page when the issue has been corrected. If you have any questions, please don’t hesitate to contact Chris McCaghren, deputy assistant secretary for higher education programs, at 202-453-7337 or christopher.mccaghren@ed.gov."

April 8, 2020
FAS 'Cares' , We are in this together!
COVID-19 Relief and CARES ACT Update Part II
Questions Answered on CARES Act from our Partner McClintock & Associates
BY MICHAEL T. WHERRY, CPA
MCCLINTOCK AND ASSOCIATES

Based upon the electronic announcements issued by the U.S. Department of Education (ED) and the relief provisions in the CARES Act, we have been receiving numerous questions from institutions on implementing and interpreting this guidance. As a result, we have compiled this Questions and Answer for institutions to utilize as we await future guidance from ED. While, ED has not issued any guidance related to provisions in the CARES Act, we anticipate this is forthcoming at some point.

General Notes

1. ED has provided guidance for interruptions of study related to the Coronavirus.
ED’s March 20, 2020 Guidance related to COVID-19
ED’s April 3, 2020 Updated Guidance related to COVID-19

2. To date, ED hasn’t waived any of the Cash Management provisions in the Q&As which it has issued (March 5, 2020 and March 20, 2020) nor the CARES Act. Thus, all aspects of cash management including drawdowns under HCM1 and the requirements surrounding student Title IV credit balances still in place. However, in its 4/3/2020 electronic announcement, ED indicates that exceptions could be made if an institution is unable to comply due to COVID-19 disruptions. Where an institution is unable to comply, it should document the reason(s) for instances where it is unable to comply and retain the documentation in its records.

M&A recommends attempting to obtain authorizations and the student’s intent via email or phone calls.
Delays which arise due to institutional personnel being available to work or access to the appropriate information should be documented.
Ensure you document why a decision made was in the best interest of the student.

3. On March 27, 2020, ED waived the requirement to implement the Annual Student Loan Acknowledgment previously known as the Informed Borrower Confirmation process. ED is delaying the requirement that borrowers complete the Annual Student Loan Acknowledgment prior to the 2020/21 award year. The process will be delayed one year and implemented before a borrower receives the 1st disbursement of the 1st loan the borrower receives starting with loans associated with the 2021/22 award year.

4. In the CARES Act Congress did not grant broad powers to the Secretary to provide for statute and regulatory relief. As such, the audit deadlines have not been delayed.

5. ED reminds institutions to document in their records, as contemporaneously as possible, any actions taken as a result of COVD-19. M&A reinforces this position as timely and thorough documentation provides significantly more support for the judgments and basis for decisions made by management. Situations which are well documented provide enhanced support to federal or non-federal auditors.

6. Unless otherwise specifically stated in ED’s guidance, the emergency flexibilities remain in effect from March 5, 2020 through June 30, 2020 unless the crossover period extends over award years and is attached to the 2019-2020 award year and, in that case, is effective through the end of the crossover payment period.

CARES Act

Section 3503

Question – This section waives the non-federal share matching requirements for both SEOG and FWS for both 2019-20 and 2020-21. In addition, an institution can move up to 100% of unexpended FWS to SEOG, but not the other way around. Does this mean we can pay 100% of 2019-20 FWS with Federal Funds? If so, this could potentially put schools in a position where they overspent their federal allocation. Currently (July 1, 2019-present), the institution had initially planned for a 75/25 split for SEOG.

Answer – M&A agrees in that the non-federal share is waived so potentially the entire amount of FWS paid and SEOG granted is from federal funds. The exception is section 443(c)(3) which relates to FWS employed in the private section (for-profit non-school businesses) as the matching requirement for these entities has not been waived. As institutions await guidance from ED, they should consider leaving any 2019/20 match which has been made. If you decide to award SEOG solely using federal dollars, this does decrease the total funds an institution will have to award. If you just use federal dollars, the funds will run out sooner.

Section 3504
Question – This section provides the ability to move unexpended FWS to SEOG. Any funds moved into SEOG can be awarded on an ad-hoc basis, and not follow an institution’s normal awarding guidelines for the initial SEOG allocations. These funds can be awarded to a student up to the maximum PELL award. Is this each student’s maximum fulltime Pell award or the maximum fulltime Pell award for the award year?

Answer – M&A concurs that the need calculation is waived for providing the emergency grant. However, we believe the emergency grant can be up to the maximum Federal Pell Grant for the applicable award year not the student’s individual limitation. In addition, the SEOG Emergency Awards can be made from any portion of the school’s SEOG allocation, not just the amount transferred from FWS.

These grants should be for students who have unexpected expenses and unmet financial need as a result of a qualifying emergency, and that your determination of need should be documented in the student’s file. Institutions should develop a specific form to document and support the awarding of these emergency grants.

These emergency grants can be for undergraduate and graduate students. Thus, M&A believes the students who receive the emergency grants do not have to be Pell eligible.

Sections 3506 & 3507
Question – For students who withdraw due to COVID-19, any loans or PELL received for that semester/term will be eliminated from both SULA and Pell LEU. How will this be calculated by COD and NSLDS as they do not know why students withdraw.

Answer – M&A agrees that these disbursements will not impact the student’s SULA or Pell LEU limitations. However, ho guidance has been issued by ED as to how this will be reported in COD & NSLDS. We expect this will be part of future ED guidance.

Section 3508
Question – Does a qualifying emergency pertain to all students that withdraw during the period of the National Emergency?

Answer – No. See section 3508 of the Act clearly indicates that the student withdrawal is a result of a qualifying emergency. In our opinion, an institution can’t make a blanket assumption that every student withdrawal is due to the qualifying emergency without attempting to contact a student. For students who withdraw without contacting the institution, the student’s past attendance history may provide useful documentation. For a student who had excellent attendance prior to the qualifying emergency, an institution may have justification for deeming the withdrawal due to the qualifying emergency. For a student whose attendance was more haphazard or running close to the 14-day of nonattendance (for an attendance taking institution), the institution may be prudent to treat the withdrawal as not due to the qualifying emergency. Institutions may want to consider creating a new code in their student information system to track students who withdraw specifically due to this qualifying emergency.

Question – Does the student that withdrawals need to provide the College written notification they are withdrawing due to the Coronavirus?

Answer – Currently, no guidance has been provided by ED. M&A recommends obtaining the reason via email or phone, if possible, and to maintain this documentation. An institution should document its decision and any judgments which we made as we await further guidance.

Question – If the refund calculation states to refund the portion of the unearned Pell Grant or Direct Loan disbursements, does the College retain those funds and document that the student withdrew as a result of a qualifying emergency?

Answer – Yes. M&A recommends completing all aspects of the refund process until the point of making the actual refund. This would include completion of the student status form, Pell recalculation, R2T4 calculation, and any state or institutional refund policy. We recommend that the student’s account card / ledger card is updated for these transactions. Institutions can then make entries to reverse the refund from the student’s account card / ledger card If an institution doesn’t post the refund to the student’s account, ensure a tracking system exists to enable all students who don’t have refunds made are captured for the required future ED reporting.

In addition, if students withdraw who owe the institution a balance, institutions may want to consider what collection efforts, if any, will be pursued during this period of time.

This provision raises a question which is not considered in the statute. If an institution applies their institutional refund policy and this creates an additional refund, then to whom are these funds sent? We would be surprised if the intent of Congress was to enable an institution to maintain funding in excess of the actual earned institutional charges. In the absence of further ED guidance, this additional refund would appear to be a credit balance due to the student. As noted above, since the cash management regulations have not been waived, we believe it would need to be sent to the student within 14 days.

Question – The refund calculation in our system will not match since no funds will be refunded. Does this present an issue?

Answer – It does not. However, institutions will have to report the number of such recipients, amount of grant or loan assistance associated with each recipient, and the total amount of grant or loan assistance for which each institution has not returned. We suggest creating this listing as each withdrawal occurs to ensure a fully documented “paper trail” exists for reporting and for future federal and non-federal audits. In conjunction with #6, the institution should have appropriate documentation and the records well organized.

Question – The institution assumes refunds do not get sent to COD, correct?

Answer – We agree and see above. We believe that all refunds (Pell, SEOG, and FDL) are not required to be made.

Question – Due to externships closing down, we may have to withdraw an entire class. Do you see any problem with that?

Answer – An institution may provide an approved leave of absence that does not require the student to return at the same point in academic program that the student began the leave of absence if the student returns with the same semester (or the equivalent). M&A would interpret this to be the same payment period for a nonterm institution.

In ED’s March 5, 2020 guidance (updated March 20, 2020 and April 3, 2020), a clock hour institution can put a student on an approved leave of absence if the coursework is interrupted as a result of Covid-19. This guidance applies if there is a reasonable expectation that institution will be able to resume the coursework and find a placement for this student within 180 days. If this criterion can’t be met, then the student must be considered withdrawn and an R2T4 calculation performed. (See above for the CARES Act impact on R2T4 calculation refunds). While not specifically indicated in the CARES Act, M&A believes that this guidance would extend to a credit hour institution based upon the previous paragraph.

ED Relief and Other Questions

Question – For our fully online programs and students, are they exempt from everything regardless if they are having challenges due to this emergency (stimulus money, refunds for R2T4, SEOG usage, etc.)?

Answer – We feel they qualify for all of the exemptions which have been granted and the emergency relief funding. The online students are being excluded from the Higher Education Emergency Relief Funding calculations as, in theory, the school didn’t incur any transition costs for these students. Otherwise, online students are being affected just like on-ground students as a result of the pandemic.

Question – If our current term ends May 8, how would you see being able to put a term-based student on LOA? Assumptions:

We cannot shorten the terms because it would take us under 30 instructional weeks. We can extend the term if we were forced to add periods of non-enrollment due to clinical and or lab unavailability.
We can overlap terms in this current situation if it makes sense to do so or we cannot overlap terms due to term-based rules. For example, if our May term was extended to June 15, but our June term still starts June 5. Is this doable? Would it be better to have them return and get an “I” grade that strings out into the next term and start the next term?

Answer – An institution may actually be able to have an academic year that is less than 30 weeks, if it can obtain ED approval, per ED’s March 5, 2020 electronic announcement.

It is our understanding that some institutions have submitted requests to shorten the academic year but have not heard back from ED as of yet (open request pending since March 10, 2020). However, further guidance was provided in the April 3, 2020 update that may help to expedite these requests.
See ED guidance below from the 3/5/20 ED electronic announcement as we believe they are allowing schools the flexibility to extend terms and to have them overlap as a result of the coronavirus.

Question – The March 5, 2020 Electronic Announcement indicates that, in response to COVID-19, we can offer courses to students on a schedule that would otherwise be considered a non-standard term while continuing to offer Title IV aid using a standard term academic calendar. Can those courses also overlap courses in our summer term without causing our programs to be treated as nonterm programs?

Answer -Yes, the Department is extending the flexibility described in that electronic announcement to schedules that would otherwise be nonterm as well; for example, an extended spring term that will overlap with a summer term. If an institution extends the length of a term to respond to COVID-19, causing the term to overlap a subsequent term, in this limited circumstance, the institution may continue to consider its terms to be standard terms, allowing both the use of a scheduled academic year (SAY) for Direct Loan funds and Pell Grant Formula 1. Use your professional judgment and document your decisions, citing specific regulatory guidance whenever possible.

Question – How does a student complete the Statement of Educational Purpose if they can’t visit a notary or be on-campus?

Answer – The Department has suspended the in-person submission and notary requirements for V4 and V5 verification (see April 3, 2020 update to ED’s electronic announcement). However, ED indicated documents should be submitted to the institution. If possible, M&A recommends using a video call to assist in documenting these steps. Institutions could develop a form which documents the required student ID information, that the student was viewed over a video cam, and a picture of the student’s ID was emailed to the institution.

Question – Any changes in professional judgement due to the projected unemployment in 2020 and the resulting loss of income?

Answer – No change in ED’s guidance has occurred and the existing regulations should provide the applicable guidance. ED encourages institutions to use professional judgment to reflect more accurately the financial need of students and families affected by the Covid-19 pandemic. ED also reminded institutions in its April 3, 2020 announcement that professional judgments must be made on a case-by-case basis. From an audit perspective, ensure this documentation is thorough and complete, and supporting information is obtained. Document the situation via phone if necessary, especially if supporting documents (i.e. proof of unemployment wages) can’t currently be obtained securely.

Question – Can a student email verification documents to the institution?

Answer – ED has reminded institutions that FERPA rules are still in place and verification documents can only be emailed if encrypted and secure. If an institution wants to pursue this process, then we recommend that regulatory counsel and the institution’s information technology department discuss the necessary requirements to ensure the system secure. In our opinion, ED is unlikely to provide relief or accommodations to an institution upon an audit for violations of FERPA or GLBA. While institutions are operating 100% remotely, FERPA and GLBA are even more important and, if anything, ED may be more stringent in their oversight.

Question – Does the March 5, 2020 guidance from Ed allowed institution to start new students in distance learning?

Answer – Yes – Because of the COVID-19 national emergency, and as an emergency measure to accommodate students, the Department provides broad approval to institutions to use distance learning modalities without going through the standard Department approval process, even if the institution would normally be required to seek Departmental approval for the use or expansion of distance learning programs. At this time, this flexibility applies only to payment periods that overlap with the Department’s March 5, 2020, guidance or that begin on or between March 5,2020 and June 1, 2020. If an institution chooses to continue offering a new program or using distance education in a manner requiring the Department’s approval after that point, it may be required to obtain approval under the Department’s and its accrediting agency’s applicable policies and procedures.

Reminder that ED reinforced in its April 3, 2020 guidance that the distance education flexibility is not available for clock-hour programs that lead to licensure if the licensing body will not accept the distance education courses.

To Review the Latest Updates from the
Department of Education related to COVID-19

https://www.ed.gov/coronavirus
https://www.nasfaa.org/covid19

April 6, 2020

FAS 'Cares' , We are in this together!
See RELIEF FROM FAS at end of this Update.
COVID-19 Relief and CARES ACT Update

Is your institution aware of the CARES ACT and the possible benefits available to your institute?

The Stimulus package ensures that:

-Students receive additional grant aid to encourage them to complete their programs
-Provides schools with funds to replace lost revenue
-Provides schools with funds to use to enhance online learning processes

The federal assistance under the CARES Act does not need to be applied for. This will be a direct payment from the US Government to the schools. However, we have yet to hear when these payments will be made. It is our understanding that they will be made through the G5 system so they will be directly deposited to your federal funds account. Information and guidance continues to come in on this.

Please see the summaries below of what you can expect out of this relief.
Summary of COVID-19 CARES ACT
On March 27,President Trump Signed a $2 Trillion COVID-19 Relief Package
The $2 trillion dollar bill — dubbed the Coronavirus Aid, Relief, and Economic Security (CARES) Act — The Act makes emergency supplemental appropriations and other changes to law to help the Nation respond to the coronavirus outbreak.

The bill addresses the economic impacts of, and otherwise responds to, the COVID-19 (coronavirus) outbreak.

With respect to funding assistance, the bill:
Provides approximately $14 Billion through the Higher Education Relief Fund directly to institutions from the Secretary
Provides approximately $3 Billion to states through the Governor’s Emergency Education Relief Fund, some of which is authorized to go to institutions of higher education.
With respect to small businesses, the bill:
establishes, and provides funding for, forgivable bridge loans
provides additional funding for grants and technical assistance.

The bill also provides funding for $1,200 tax rebates to individuals, with an additional $500 payments per qualifying child. The rebate begins phasing out when incomes exceed $75,000 individually (or $150,000 for joint filers).

The bill establishes limits on requirements for employers to provide paid leave.

With respect to taxes, the bill:
establishes special rules for certain tax-favored withdrawals from retirement plans;
delays due dates for employer payroll taxes and estimated tax payments for corporations; and,
revises other provisions, including those related to losses, charitable deductions, and business interest

With respect to education, the bill provides regulatory flexibility and relief:
temporarily suspends payments for federal student loans
otherwise revises provisions related to campus-based aid, supplemental educational-opportunity grants, federal work-study, subsidized loans, Pell grants, and foreign institutions.

Higher Education Relief Fund
What this relief does:
Provides approximately $14 Billion in funding directly from the Secretary to institutions of higher education based on the following allocation:

CLICK ON LINK FOR:
ACE PRELIMINARY STIMULUS FUNDING BREAKDOWN BY INSTITUTION

90% (approximately $12.5 Billion), 75% of which would be apportioned “according to the relative share of full-time equivalent enrollment of Federal Pell Grant recipients who are not exclusively enrolled in distance education” and 25% “according to the relative share of full-time equivalent enrollment of students who were not Federal Pell Grant recipients.”

The remaining 10% is allocated to Hispanic serving, HBCU, Native and other special category institutions. All funds are to be made available directly from the Secretary to the institution via the existing Title IV fund distribution system.

Institutions must allocate at least 50% of the funds for emergency financial aid grants to students and may use remaining funds “to cover any costs associated with significant changes to the delivery of instruction due to the coronavirus, so long as such costs do not include payment to contractors for the provision of pre-enrollment recruitment activities; endowments; or capital outlays associated with facilities related to athletics, sectarian instruction, or religious worship.”

Institutions will be required to submit reports to the Secretary regarding the expenditure of all funds, and careful accounting records should be maintained regarding the expenditure of all such funds.

ED will distribute this Funding to the institution via the existing Title IV fund distribution system (G-5).

Please Note: The federal assistance under the CARES Act does not need to be applied for. This will be a direct payment from the US Government to the schools. We have yet to hear when these payments will be made. It is our understanding that they will be made through the G5 system so they will be directly deposited to your federal funds account. When we have more information, we will share it with clients. Also, please be aware that these amounts are strictly estimates. The amount that you actually receive may not be same.

There is also funding being sent to state governments for dissemination as they see fit. You may have to apply with your state for those funds. It is our understanding that states will be releasing information directly to schools on this.

Continued Payment to Employees
The Act requires any entity receiving funds to continue to pay its employees and contractors during any disruption related to COVID-19 “to the greatest extent practicable”

Exclusion from Federal Pell Grant Duration Limit (LEU’s)
Exclude from a student’s Pell Grant duration limit the semester (or equivalent payment period) that the student does not complete due to the qualifying emergency.
This essentially re-sets the Pell Grant duration availability to hold the student harmless from withdrawal due to a qualifying emergency.

Campus Based Provisions
The non-federal share requirements for Federal Work Study (FWS) and FSEOG will be waived for 2019-2020 and 2020/2021 award years in cases that are paid by the Schools.
Allows Schools to transfer up to 100% of FWS over to FSEOG during a period of a qualifying emergency.
Allows Schools to use FSEOG funds for emergency scholarships to student including graduate students for unexpected expenses and unmet financial need as the result of a qualifying emergency.
Standard FSEOG rules would be waived, and schools would determine eligibility for this new emergency provision.
Maximum amount for the “emergency FSEOG” would be the maximum PELL grant for the award year (for example $6195 for 2019-2020 AY).
Emergency FSEOG award for this provision will not be treated as estimated financial assistance (EFA).
Allowing FWS students that are unable to work to continue to be paid during a qualifying emergency, not to exceed one academic year, either in installments or a lump sum payment.

Direct Loans Provisions
Subsidized Usage Limitation (SULA)
If a student is unable to complete a payment period due to COVID-19, any subsidized usage incurred will not be included in the Sum of Current Usage. Responsibility will fall on ED to make the appropriate updates to COD records.

Loan Repayment
Loan payments and interest accrual on loans currently in active repayment, forbearance and default will be suspended through Sept 30, 2020. Each month of suspended payments counts as a payment made for purposes Public Service Loan Forgiveness and loan rehabilitation programs.

Involuntary collections (garnishment of wages, tax returns, etc) will be suspended through Sept 30, 2020.

Leave of Absence Provision
Provides authority for institutions of higher education to provide a student with an approved Leave of Absence (LOA) that does not require the student to return to the same point in the program at which the student began the leave of absence if the student returns within the same semester (or equivalent).
This provision provides flexibility as to resumption of course work for students whose attendance is impacted by COVID-19.
Institutions must have a formal written policy regarding leaves of absence requiring that all requests for LOA be submitted in writing. Institutions should carefully document LOA circumstances for each impacted student for purposes of annual Title IV compliance audits or program review
LOA’s can be requested after the leave began.

Satisfactory Academic Progress Provision
Permits institutions to exclude from the quantitative (attendance) component of the Title IV Satisfactory Academic Progress (SAP) student eligibility requirement any attempted but not completed credits, without requiring an appeal, for students whose attendance is impacted by COVID-19.
This provision ensures that students whose attendance is impacted by COVID-19 are not put at risk of losing Title IV eligibility based on interrupted attendance due to COVID-19

Return to Title IV Provisions
R2T4 Calculations are still required!

Institutional Refunds and Federal Student Loan Flexibility
This provision directs the Secretary to waive Return to Title IV (R2T4) institutional refund requirements for Title IV loans and grants for students who withdraw during the payment period or period of enrollment as a result of the qualifying emergency.
The provision also relieves students of any obligation to return unrefunded Pell or grant amounts that are subject to the R2T4 waiver.
Schools will be required to report to the Secretary the number of Title IV recipients subject to the waiver, the amount of grant or loan assistance, and the amount not returned via an R2T4 calculation.
Institutions should be aware that state, accreditor or institutional refund policies may still apply, as this applies only to Title IV funds returns.

When completing R2T4 Worksheets in Fasline please be sure to notate under Comments if the students withdrawal was directly related to Covid-19.

FAS will be entering any refund amounts into our system for later tracking purposes as the DOE releases further guidance.

ED Releasing Updated COVID-19 on Verification
The Department of Education (ED) late on Friday released an updated COVID-19 Electronic Announcement (EA), providing new guidance and flexibilities on verification.

Effective Date
Previous guidance from ED applied to students enrolled in payment periods that begin on or before June 1, 2020.

Unless otherwise specifically stated, the most recent EA is effective through June 30, 2020, or the end of a crossover payment period assigned to the 2019-20 award year. Note that the most recent EA includes some flexibilities that were previously authorized in earlier guidance, thus extending their authorized effective period from June 1 to June 30.

Verification
The April 3 guidance allows for some relief for the completion of verification for students and institutions.

For students whose applications are flagged with the V4 and V5 verification codes — those who are required to provide to the financial aid office, in person or via notarized documents, identity and statement of educational purpose — ED has suspended the in-person submission or notarized document requirement. While the documents will still be required, they may instead be submitted in person or electronically, via email, through uploading photos, or through the school’s portal. Requirements to ensure encryption/security of electronically-submitted documents still apply in this situation.

The EA also allows schools to accept expired forms of identification — such as a driver’s license, if the ID expired after March 1, 2020 — and also waives the requirement for the school to collect a parent’s signature to verify the number in the household and the number enrolled in college if the dependent student’s parents are unavailable.

NSLDS / Enrollment Reporting
For Schools WITH and Approved Leave of Absence Policy
In general, when a student withdraws during a payment period, the effective date for the withdrawn (‘W’) status for enrollment reporting purposes is the withdrawal date used by the institution in accordance with 34 CFR § 668.22(b) or (c). However, notwithstanding the requirement that the institution perform a Return of Title IV funds calculation for students when an institution unexpectedly ceases operation during a payment period and fails to reopen during that payment period, we permit an institution to defer reporting an affected student’s enrollment status as “withdrawn” in these circumstances when the institution has a reasonable expectation that—

The institution will reopen at the start of a payment period that begins no later than 90 days following the closure; and
The student will resume attendance when the institution reopens.

In these cases, the institution should continue reporting the most recent enrollment status that it reported for the affected student prior to the closure. If the student does not resume attendance as expected, the institution must change the student’s enrollment status to “withdrawn” using the student’s actual withdrawal date as the enrollment status effective date."

For Schools WITHOUT an Approved Leave of Absence Policy:
The March 5, 2020 Electronic Announcement guidance regarding a leave of absence (LOA), only applies to Title IV-approved leaves of absence defined in 34 CFR 668.22(d). If your school does not have a Title IV-approved LOA, the student is a withdrawal if the school closes and/or does not move classes online, or if the school closes and reopens and the student later withdraws during the same payment period or period of enrollment.

Small Business Assistance

Paycheck protection program
The Senate has instructed that $349 billion be made available under this program. A single loan can be an amount of up to $10 million.
Eligible entities include: A small business (1) fewer than 500 employees or (2) if applicable, the size standard in number of employees established by the administration for the industry in which the business concern operates. A business with fewer than 500 employees that has more than one location, including franchise businesses.
Borrower requirements: In making the determination of a borrower’s eligibility for a loan, the borrower has to have been in business since at least February 15, 2020, and have had employees for which it was paying salaries or payroll taxes, or paid independent contractors.
Eligible recipients do not have to demonstrate that they are unable to obtain credit elsewhere. The loans will be nonrecourse and will not require collateral. Covered loan period begins on February 15, 2020, and ends on June 30, 2020. The application must be submitted during this period. Lenders decide eligibility, not the SBA. Lenders must waive borrower and lender fees.
Loans can be used for payroll costs, costs related to the continuation of group healthcare benefits and insurance premiums, employee salaries (not in excess of $100,000 annually per employee), payment of interest on any mortgage obligations, rent, utilities and interest on any other debt obligations. Principal on loans cannot be paid or prepaid with the loan proceeds.
Eligible payroll costs for an independent contractor or a sole proprietor include the sum of payments of any compensation received that is a wage, commission, income, net earnings or similar compensation that is not more than $100,000 in one year (prorated for the covered period).
Maturity: The covered loan will have a maximum of 10 years to maturity. However, there is a provision for reduction of the amount due (see loan forgiveness below).
Interest Rate: The interest rate cannot exceed 4%.

EIDL Grant:
Eligible entities may request a $10k grant that is to be paid out within 3 days of application. Must be done in conjunction with SBA loan.
Do not have to pay back this $10k amount whether they are approved for a loan or not.

Note: The U.S. Department of Education (ED) has not issued any guidance related to provisions in the CARES Act. We anticipate ED will issue further guidance. This summary is for general guidance and informational purposes only, and should not be relied upon for regulatory compliance. Situations specific for your institution should be discussed with your regulatory counsel and professional advisors.

To Review the Latest Updates from the
Department of Education related to COVID-19

https://www.ed.gov/coronavirus
https://www.nasfaa.org/covid19

Is your school closing temporarily or are you offering distance learning during COVID-19?
We hope you don't have to close, but if you do, please notify FAS by letting us know your school names and campuses, date of closure, and date you hope to reopen. Also let us know if you plan to offer or are offering distance learning during ordered social distancing. Please EMAIL CHELSIE this information. {chelsie@fasinc.net}

Schools want to know if they close for a period of time due to COVID-19, do they still pay FAS and does FAS still work for them during that time? What kind of processing will be done?
ANSWER
When the school makes the tough decision to close, it should notify FAS immediately of the closure dates and the projected reopen dates (or if school is closing indefinitely). The School should also let FAS know if it would like disbursements to be FROZEN. This means FAS will not create disbursement vouchers for any of the Title IV programs or return funds on behalf of school. (FAS will not request Direct Loan Funds, Pell Funds, FSEOG funds or FWS funds from the department of education for that school.)

School must be sure to notify FAS when it reopens.

However please note that FAS is a vital piece of the school’s financial aid operations and performs many other ongoing duties on behalf of the school that will continue to keep the school compliant during temporary closure, including but not limited to monthly reconciliations, ERR reporting, COD reporting and reconciling, Verification, Auditing for Student Eligibility or Student Eligibility Reviews, Return to Title IV reviews, loan adjustments and delinquent reporting, CDR reporting, COA Budgets Maintenance, Student Surveys, researching and studying all new guidance and consulting and notifying client schools of all updates and changes and relief processes and processing that new relief.

Also to note, at the point that a student enrolls at the school, FAS begins processing that student's financial aid and all associated reporting, auditing and reconciliation for that student continues throughout the award year. That is why a school contracts with FAS for an annual contract and not a monthly contract. FAS has work to do for each student enrolled throughout the student’s life cycle at the school which typically will be an award year for the financial aid. We are not able to- or compliantly allowed to – just stop everything, because a school has closed temporarily.

Therefore, The school closing for a period of time because of COVID-19 does not automatically mean FAS will cease ALL processing, reporting, auditing, reconciling. In fact, it is more important than ever that FAS continues to carry these responsibilities out per our annual contract and to abide by Federal Regulations and keep the school in compliance and fulfill FAS fiduciary responsibilities. FAS workers are considered essential, because we are continuing the processing AND compliant maintenance of all enrolled students who are in the aid cycle to be sure aid is funded and maintained. We also are educating and preparing for new administrative duties per the relief package that was just put forth.

FAS DOES NOT PROCESS OR OFFER SERVICES MONTH TO MONTH. WE DO NOT PRORATE MONTHLY PAYMENTS GOING TOWARD AN AGREED ANNUAL CONTRACT PRICE BASED ON NUMBER OF STUDENTS PROCESSED.
*When a school signs a service agreement with FAS, the school is contracting FAS for an annual service consisting of an entire award year cycle. The service agreement is therefore an annual contract. The school can choose to pay the annual fee all up front at the beginning of the year OR the school can choose to pay the annual contract out in monthly interest free payments. Most schools choose this payout monthly option and FAS provides an invoice for that interest free payment each month. Therefore, a school cannot choose to turn off service for any month and not pay the monthly invoice.

FAS and Genesis to Remain Operational During Pandemic “We are here for you!"
While following federal guidelines to work from home whenever possible for the next 30 days, FAS/Genesis has had contingency plans in place for some time to maintain operations through an organized telecommuting program.

At this time, we expect to be able to maintain current operations with minimal disruptions, but your patience is appreciated as we triage priorities and issues in the face of this unprecedented pandemic.

FAS encourages you to email if you can, versus calling. We have an operational phone system. However, the number of open lines are reduced when working offsite with our system. Therefore we are asking clients to email your questions when possible.

NEED AN EMAIL ADDRESS? Please refer to the Team Directory to email the correct department/staff member with your questions.

We appreciate your cooperation and patience! Be well and God Bless.

RELIEF FROM FAS
Relief from FAS During Coronavirus

So, how can a school find temporary relief from its FAS annual contract payout?
FAS is working with client schools during the Coronavirus challenges in a number of ways.

If a school projects that the original student count it contracted for will not be met due to the challenges and hardships the virus has created, it should contact FAS to discuss a reduction in counts listed on the contract and thus a reduction in fees Reducing final student count will create a lesser monthly payout meaning we will not be processing for as many students as projected.

In the event of a temporary school closure, a school may delay its monthly payment by 30 days without penalty. (FAS usually charges interest and fees for late payments) However, this delayed monthly payment must be made promptly after the 30 days has expired along with the next monthly payment due to avoid penalties and fee. Please notify FAS if you are unable to make the April month payment and need to pay it with May payment. (This may also apply to a Genesis Payment -please contact FAS/Genesis.)

More Relief…
FAS had notified client schools back in February of an upcoming price increase with the new award year. FAS has kept its annual pricing stable for over 7 years. FAS will NOT be putting in the price increase as scheduled and will look to cut costs in other areas in order to avoid making things more challenging for struggling schools.

FAS will also consult with the school regarding online assistance and what school can expect for additional services if it must reduce its workforce. Please contact us to see how we can help.

Help us Help YOU! Please call and ask for any assistance you can think of and we will discuss openly.

March 23, 2020

Coronavirus related Update in Financial Aid
If you have not done so yet, Please Notify FAS if YOUR SCHOOL is Closing
We hope you don't have to close, but if you do, please notify FAS by letting us know your school names and campuses, date of closure, and date you hope to reopen. Also let us know if you plan to offer distance learning during this time.

Please EMAIL CHELSIE this information. {chelsie@fasinc.net}

QUESTION

We need to close our school for a period of time.
How does this work with FAS (financial aid processing) and payment to FAS invoices?

ANSWER
When the school makes the tough decision to close, it should notify FAS immediately of the closure dates and the projected reopen dates (or if school is closing indefinitely). The School should also let FAS know if it would like all processing to be FROZEN. If school would like FAS to halt servicing and processing during closure, FAS will not create disbursement vouchers or return funds on behalf of school.
School must be sure to notify FAS when it reopens.

However please note that FAS performs many other ongoing duties on behalf of the school that will continue to keep the school compliant during temporary closure, including but not limited to monthly reconciliations, ERR reporting, COD reporting and reconciling, Verification, Student Eligibility Reviews loan adjustments and delinquent reporting, CDR reporting.

Also to note, once a student enrolls at the school, FAS begins processing that student's financial aid and all associated reporting and reconciliation for that student continues throughout the award year. Each student enrolled is assessed a fee under the annual contract and the school projects the number of students who will receive aid in each program to calculate the annual contract’s overall charge. FAS does not base its servicing on whether the school is open or closed for a period of time. In fact when the school closes for vacations, summer, or even for safety, FAS continues processing for the students who are still enrolled or were enrolled during the current award year! That is a huge benefit to the schools who cannot keep their physical building open and faculty in place. FAS will keep functioning on behalf of the school to maintain compliant student reporting and eligibility.

*When a school signs a service agreement with FAS, the school is contracting FAS for an annual service consisting of an entire award year cycle. The service agreement is therefore an annual contract. The school can choose to pay the annual fee all up front at the beginning of the year OR the school can choose to pay the annual contract out in monthly interest free payments. Most schools choose this payout monthly option and FAS provides an invoice for that interest free payment each month. THIS SHOULD NOT BE CONFUSED WITH A MONTH-TO-MONTH SERVICE. Therefore, a school cannot choose to turn off service for any month and not pay the monthly invoice.

Relief During Coronavirus

FAS will work with client schools during the Coronavirus challenges. If a school projects that the original student count it contracted for will not be met due to the challenges and hardships the virus has created, it should contact FAS to discuss a reduction in counts and thus a reduction in fees.

In the event of a school closure, a school may delay its monthly payment by 30 days without penalty. (FAS usually charges interest and fees for late payments) However, this delayed monthly payment must be made promptly after the 30 days has expired along with the next monthly payment due to avoid penalties and fee

FAS will also consult with the school regarding online assistance and what school can expect for additional services if it must reduce its workforce. Keep in mind that FAS’ entire expert team does not cost the same amount in overhead expenses as physical onsite staff. FAS staff will keep working even if the school facilities must be closed. We are already remotely working for you during this pandemic with stay at home orders looming.

Help us Help YOU! Please call and ask for any assistance you can think of and we will discuss openly.

The Latest Update from the Department of Education

Department of ED Guidance Related to COVID-19

The DOE’s blanket approval for utilizing Distance Education has been extended to include new starts through 6/1/20.

Clock Hour Schools Offering Distance Education

School must have approval from accreditor and state licensing board
In order to give a student credit for 1 hour of attendance, the instructor must acknowledge that the student was “academically engaged” for at least 50 out of 60 minutes.
Schools must keep careful documentation of hours awarded. Electronic documentation, if available through your online platform, is encouraged.
Students who are unable to complete externships maybe placed on LOA assuming there is a reasonable expectation that they will be able to be placed in a new externship within 180 days.

Credit Hour School Guidance

R2T4s for Term Programs:
Closure days should be deducted from the days in the term if the R2T4 is done after the change to the term is made. Please be sure to include these days on the R2T4 Worksheet. You may add breaks in the Comments section if you have more than one break.
R2T4s done prior to the change being made do not have to be redone if the length of your term changes.
R2T4s for Non-Term Credit Programs:
Payment Periods should be extended out by the length of any closures and the closures should be included as scheduled breaks.
Term Schools Only – any changes to the length of your academic year must be approved by your Regional School Participation Team at DOE.

General Guidance

Student who choose not to participate in distance education may be placed on LOA.
There has been no change to Credit Balance regulations. If a student qualifies for a Title IV credit balance, this must be paid out within 14 days of the disbursement date unless the school has an Authorization to Hold. Regardless of any authorization, credit balances must be paid out prior to the end of the academic year in which they are created.

Helpful Links:

https://www.ed.gov/coronavirus
https://www.nasfaa.org/covid19

FAS and Genesis to Maintain Operational During Pandemic
While following federal guidelines to work from home whenever possible for the next 15 plus days, FAS/Genesis has had contingency plans in place for some time to maintain operations through an organized telecommuting program.

At this time, we expect to be able to maintain current operations with minimal disruptions, but your patience is appreciated as we triage priorities and issues in the face of this unprecedented pandemic.

FAS encourages you to email if you can, versus calling. We have an operational phone system. However, the number of open lines are reduced when working offsite with our system. Therefore we are asking clients to email your questions when possible.

NEED AN EMAIL ADDRESS? Please refer to the Team Directory to email the correct department/staff member with your questions.

We appreciate your cooperation and patience! Be well and God Bless.

May 18, 2020

FAS 'Cares' , We are in this together!
CARES Act Update

On Friday, May 15, 2020, ED released updated guidance regarding the CARES Act:

Distance Education
– ED is extending the broad approval for the use of distance education through December 31, 2020.
– Accreditation requirements: ED is waiving its requirement that programs offered via distance education be accredited by an agency that has distance education in the scope of its recognition by the secretary. This requirement is being waived under the Higher Education Relief Opportunities for Students (HEROES) Act for payment periods that begin on or before December 31, 2020.

Return of Title IV Funds Requirements
Regulation: Schools may waive the requirement to refund unearned funds for students who withdraw as a result of COVID-19 related circumstances. This waiver applies to any student who begins attendance in a payment period that begins on or includes March 13, 2020, and subsequently withdraws from the payment period.
Clarifications:
– Any institution that moved from ground-based instruction to distance education, closed campus housing or other campus facilities, or experienced other interruptions in instructions may consider all withdrawals from students enrolled in ground-based instruction during the covered period to have been the result of circumstances related to COVID-19.
– Schools with existing online programs must be able to document via written attestations from the student that their withdrawal was due to circumstances related to COVID-19 if a student was enrolled in a solely online course.
– Schools that have previously refunded unearned funds that could have been waived may re-disburse them. Please email the compliance team if you need to re-disburse funds.
– Please continue to submit R2T4s as normal and notate “COVID-19” if you intend to waive the refunds.
Reporting Requirements:
– ED will require schools to report students that have withdrawn as a result of circumstances related to COVID-19. For these students, ED will:
o Cancel the entire amount of any loan disbursements borrowed by the student or his/her parent for the payment period
o Exclude from SULA usage and Pell LEU any payment period that the student is unable to complete due to a qualifying emergency
– Retain the following information for all waived refunds: (additional guidance on how to report is still pending)
o Identifying information for student
o The payment period begin and end date for the period the student did not complete
o The amount of Title IV grant or loan assistance that the student received for the payment period in which he/she withdrew
o The total amount of Title IV grant or loan assistance that each institution has not returned to ED as a result of CARES Act provisions.

Financial Statement and Compliance Audits
– Under the HEROES Act, ED is extending the audit deadlines by 6 months.

Verification of High School (or Equivalent) Completion Status
– For applicants in verification groups V4 and V5, institutions should use documentation of an applicant’s high school completion status that it may have already obtained for other purposes. If an applicant is unable to obtain this documentation, the institution may accept a signed/dated statement from the student in which he/she truthfully attests to his/ her secondary school completion or equivalent. The statement must indicate:
o Whether a high school diploma or the equivalent was obtained
o Date of Completion (or approximate date)
– This guidance applies until December 31, 2020 for the 19/20 and 20/21 award years.
– Schools with policies requiring an official transcript to verify a student’s Title IV eligibility, may accept the same written statement to satisfy the requirements of their policy.
– Schools must verify the requirements of its accrediting and state agency for purposes of enrollment, however, ED is granting authority to accrediting agencies to implement temporary changes to its policies regarding verification of high school completion through December 31, 2020.

Campus Based Waivers/Reallocation and SEOG Emergency Grant Aid
– Section 3503 of the CARES Act waives the institutional share requirement associated with FWS and SEOG for the 19/20 and 20/21 award years.
o An institution may reimburse itself from the FWS allocation for the non federal portion of wages paid to students on/after March 13, 2020.
o An institution may reimburse itself from the SEOG allocation for the non federal portion of SEOG awards made thought a fund-specific match, for any disbursements made on/after March 13, 2020.
– Schools may use any portion of its SEOG funds to provide emergency financial aid grants to assist graduate and undergraduate students with unexpected expenses and unmet financial need as the result of COVID-19.
o SEOG awarding rules are waived for purposes of making SEOG Emergency Aid Grants. SEOG Emergency Aid Grants are not considered EFA.

Tax ability of HEERF Funds
– The IRS has confirmed that funds received under the CARES Act will not be included in gross income.

Accrediting Agency Virtual Evaluation Visits
– The guidance permitting accrediting agencies to conduct virtual site visits have been extended through December 31, 2020.
– Accrediting agencies are required to perform and on-site visit following the virtual site visit within a reasonable time frame. This visit does not need to repeat the full review.

Change of Ownership
– ED is granting schools and additional 6 months (after change of ownership is reported) to provide the accrediting agency and state approvals as well as the same day balance sheet.

Paycheck Protection Program and Composite Scores
– Schools must report the expected or actual amount of loan forgiveness with their audited financial statements. This must be attested by the institution’s auditor. This forgiven amount of the PPP will be excluded from total liabilities and increase the institution’s equity or net assets by that amount in calculating the school’s composite score.

MCAT Testing
– The HEROES Act allows foreign graduate medical school admissions for students without the MCAT requirement for any admissions year in which the MCAT was unavailable to students for some period of time during that year due to COVID-19 related interruptions

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Resources

Tutorials/Webinars:

    • CARES Act & Higher Education Emergency Relief Fund
  • E-Signature: Adding an Adobe Watermark