CLARIFICATION OF R2T4 GUIDANCE RELATED TO THE COVID-19 NATIONAL EMERGENCY

Last month ED’s Office of Postsecondary Education offered reminders and clarification related to the R2T4 guidance released in May 2020 which required institutions to waive returns under the Return to Title IV requirements for any student who withdrew as a result of COVID-19 during payment periods or periods of enrollment during the national emergency.

Institutions have already had to add the Coronavirus Indicator to any disbursement in the Common Origination and Disbursement (COD) System for affected students, and soon schools will have the ability to report the amount of Title IV funds they did not return via a new lump sum reporting tool expected to be launched on COD later this month. To assist schools in determining when it is appropriate to apply the blanket R2T4 waiver, ED provided the four following examples.

Example 1

An institution offering ground-based instruction during the spring term of 2020 (January 18 to May 15) switched to a 100 percent distance education format on March 20 of that year due to the COVID-19 pandemic. During the spring semester, 30 students withdrew from their respective programs of study. The institution was able to consider all of those students (including those who withdrew at the very beginning of the term) to have withdrawn as the result of circumstances related to the COVID-19 national emergency. The Coronavirus Indicator in the COD System was set for each of the spring term disbursements for these students.

Example 2

The same institution continued offering instruction in a 100 percent distance format during the subsequent summer term. Nine students withdrew during the summer term. However, only three of those students provided written attestations explaining why their withdrawals were the result of the COVID-19 pandemic. The institution set the Coronavirus Indicator for those three students’ summer term disbursements in the COD System. For the remaining six students who withdrew for reasons not related to the Coronavirus pandemic, the institution did not set the Coronavirus Indicator and returned Title IV funds according to the R2T4 calculations performed for those students. Even though instruction continued in a distance education mode, no disruption occurred in the summer term. Accordingly, it would not have been correct for the institution to consider all nine students who withdrew to have done so as the result of a COVID-19 related circumstance.

Example 3

Another institution had been offering instruction in a 100 percent distance education format due to the pandemic but returned to ground-based instruction at the beginning of the fall 2020 term. However, during that term an outbreak of COVID-19 cases on campus caused the institution to return to 100 percent distance education. During the fall semester, 25 students withdrew from their respective programs. The institution was able to consider all 25 withdrawals to be the result of COVID-19 related circumstances and set the Coronavirus Indicator for all 25 students’ fall term disbursements. The institution was able to do this because another disruption occurred in that term.

Example 4

Prior to the pandemic, a different institution offered some programs on campus and some programs solely through distance education. The institution ceased ground-based instruction on March 27, 2020 due to the COVID-19 pandemic and moved all coursework online, but no disruption occurred to programs that were already offered online without any in-person instruction. During the spring semester, 20 students withdrew from a program that had previously been offered on campus and had been moved online due to the pandemic, and 10 withdrew from online programs where no disruption to instruction had occurred. The institution was able to consider all students who withdrew from the previously ground-based programs to have withdrawn due to COVID-19. However, it would not have been correct for the institution to consider the 10 students who had withdrawn from the online programs that had not experienced a disruption to have withdrawn due to COVID-19 without a written attestation from each student to that effect.