Recognizing that the COVID-19 emergency will continue to impact colleges and universities for months to come, the Department of Education updated two of its earlier guidance documents on interruptions of study on June 16.

Standard Term Programs. An Electronic Announcement, originally dated March 5 (and updated several times previously), was revised to expand flexibilities for standard term programs. Through the end of the academic year that includes December 31, 2020, or until the federal COVID-19 emergency ends, whichever is later:

  • Standard terms may overlap with an adjacent term without the program being considered non-term.
  • Standard terms may be shorter than usual without being considered non-standard. A semester or trimester may have as few as 13 weeks of instructional time. A quarter will need only 9 weeks.

As noted in earlier guidance, schools must seek approval from their School Participation Division case management team for any reduction in length of their academic year to less than 30 weeks of instructional time.

Return of Title IV Funds (R2T4). The waiver of the requirement for institutions to return unearned Title IV funds to ED when students withdraw related to the coronavirus emergency will now apply to payment periods or periods of enrollment that include March 13, 2020, and to those that begin between March 13 and December 31, 2020, or the last date that the national emergency is in effect. (Under earlier guidance, the waiver only applied to the period including March 13.) This is an update to an Electronic Announcement issued on May 15.

The waiver may only be applied broadly in periods in which the school faced significant disruptions due to the pandemic, such as changing instructional modalities or closing campus housing or other facilities. If that is not the case, the waiver must be applied on a case-by-case basis to students who confirm in writing that their withdrawal was due to the COVID-19 emergency.