Guidance for Reporting Enrollment Data Impacted by the Coronavirus (COVID-19)

On March 5, Federal Student Aid (FSA) released an Electronic Announcement providing comprehensive guidance on how to address the impact of the Coronavirus (COVID-19) on postsecondary institutions and their students. The Clearinghouse has consolidated the guidance below, as it relates to your Clearinghouse enrollment and compliance reporting. Please note that the below information does not include FSA’s full announcement. It only provides the key highlights related to your Clearinghouse Enrollment Reporting. For additional information, please see FSA’s full announcement.

FSA addresses five scenarios in its announcement:

  1. A student was enrolled in or supposed to begin a travel-abroad experience and was either called back to the U.S. or unable to begin the travel abroad experience.
  2. A student was enrolled in a program and met the requirements for full-time enrollment. However, due to COVID-19, one or more classes — such as an internship, clinical rotation, student teaching, or fieldwork — have been cancelled. As a result, the student has fallen below the 12 credit hour minimum and is no longer considered to be full-time.
  3. A student is quarantined and misses class or is incapacitated due to COVID-19 illness.
  4. A campus temporarily stops offering ground-based classes in order to prevent the spread of COVID-19.
  5. A foreign school that serves U.S. students who participate in Title IV programs suspends operations temporarily due to COVID-19.

FSA provides several options to address the above scenarios:

  1. Help Students Whose Enrollment Was Disrupted by the Coronavirus Continue Their Education.
    1. If a student is enrolled in a study-abroad program at a foreign campus that must close temporarily, the institution can consider reenrolling the student in classes offered by the home campus.
    2. The Department of Education (ED) is providing broad approval for institutions to offer distance education as a viable alternative for students impacted by the virus. Institutions have also been given the discretion to exercise broad flexibility over how distance education is provided and the use of technology to communicate with students (e.g., student discussions via conference calls, email check-ins, electronic chat, and electronic distribution of course materials). Distance education can be used to complete a course that began at a brick and mortar institution. Please note that this flexibility in the use or expansion of distance education only applies to a payment period that overlaps the date of ED’s announcement or the following payment period.
    3. Institutions can enter into temporary consortium agreements with other institutions to allow students to complete and transfer in coursework from another institution, but be awarded credit at their home institution.
    4. ED will allow students to leverage the Approved Leave of Absence (“A”) status even if the student notifies the institution after the Approved Leave of Absence status has begun. Please note that if the student does not return in 180 days, the school should process the student’s withdrawal and backdate it to the begin date of the “A” status in addition to performing the necessary Return of Title IV Funds.
    5. ED is also offering course scheduling flexibility for students recalled from study-abroad programs. Students can be offered courses that would otherwise be considered occurring during a non-standard term, if it allows the student to complete the impacted term.
  2. Shorten the Academic Year.

    ED is authorized under 34 CFR § 668.3 to approve a reduced academic year. If at any point an institution determines it will close as the result of a campus health emergency, it can contact its School Participation Team to request a temporary reduction in the length of its academic year.

  3. Enrollment Status Changes.

    FSA does not have the authority to waive the requirement to award or disburse Title IV funds based on a student’s actual enrollment status. For example, if an institution defines full-time enrollment as 12 credit hours, when a full-time student enrolled for 12 credit hours drops or withdraws from three credits, then the student is now enrolled at three-quarter time status.

  4. Definition of Withdrawal Date.
    1. If an institution ceases operation during a payment period and fails to reopen by the end of the payment period, its students are considered to no longer be in attendance. The students must be considered withdrawn for that payment or enrollment period and are subject to Return of Title IV funds requirements.
    2. Similarly, if an institution closes and subsequently reopens during a payment period, any students who began attendance during that payment period but failed to return when the institution reopens must be considered withdrawn for that payment period.
      1. If the institution is required to take attendance, the withdrawal date is the last day of documented attendance prior to the closure.
      2. If the institution is not required to take attendance, the institution can use any applicable option under 34 CFR § 668.22(c), including the midpoint of the payment period or period of enrollment under 34 CFR § 668.2(c)(1)(iii) or, because the closure was a circumstance that the student could not control under 34 CFR § 668.22(c)(1)(iv), the date that the institution ceased operation.
  5. Date of Determination.

    Normally, if a student does not provide notification to an institution of his/her withdrawal, the date of determination that the student has withdrawn is the date that the institution becomes aware that the student ceased attendance. When an institution closes for reasons beyond its control, in most cases, it is the date of the closure.

  6. NSLDS Enrollment Reporting.
    1. In general, when a student withdraws during a payment period, the effective date for the withdrawn status (“W”) for enrollment reporting purposes is the withdrawal date used by the institution, in accordance with 34 CFR § 668.22(b) or (c).
    2. NSLDS also permits an institution to defer reporting an affected student’s enrollment status as “withdrawn” in circumstances when the institution has a reasonable expectation that:
      1. The institution will reopen at the start of a payment period that begins no later than 90 days following the closure; and
      2. The student will resume attendance when the institution reopens.
    3. In these cases, the institution should continue reporting the most recent enrollment status that it reported for the affected student prior to the closure.
      1. 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.

If you have questions about the above guidance, we strongly encourage you to review FSA’s full announcement on interruptions related to the Coronavirus. We also suggest you monitor ED’s COVID-19 web page, which includes resources and information related to the virus.

We will continue to keep you updated as the Clearinghouse monitors the progress of the virus, it’s impact on the education community and how we are supporting our school clients with their enrollment and compliance reporting needs. If you haven’t already, we encourage you to subscribe to our Compliance Central blog so you can receive updates as soon as they become available.

If you have questions or concerns related to your enrollment and compliance reporting, please contact us at schoolops@studentclearinghouse.org or 703.742.4200 (select options #7, #2).

You can read how the Clearinghouse is addressing the impact of the Coronavirus on our other services here.

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