Hot Topic Highlights in Financial Aid: Eligibility, HEERF & R2T4

FSA highlights on hot-topic issues in financial aid include institutional eligibility, HEERF spending and new Return to Title IV regulations

Reminders and updates for financial aid administrators to take into the new year

We enjoyed joining the FSA virtual conference at the end of last year and sharing key takeaways for financial aid administrators who were unable to attend. Here’s a wrap up of conference news and highlights on some of the biggest topics being discussed in financial aid as we head into a new year.

By Rick Cox

Reminders and News on Maintaining Your Institutional Eligibility: Maintaining eligibility has become a hot topic lately because of updates to E-App and ECAR, the application and approval required to participate in Federal Student Aid programs.

As a reminder, some E-App updates are required to be reported to the U.S. Department of Education within 10 days. The only additional locations that must be listed on the ECAR are those that provide more than 50 percent of the student’s program.

E-App, or the Electronic Application, is used to apply for recertification and report all types of changes related to the institution’s eligibility, which would include additional locations, educational program updates or a change in the institution’s officials. The Program Participation Agreement (PPA) is required for certified/participating institutions. The institution should maintain a copy of these documents.

There are two types of eligibility and certification:
Full Certified – up to 6 years; and
Provisional Certification – 1 to 3 years, with specific conditional provisions

How to avoid the most common mistakes on completion of the E-App:
· When reporting more than one update, check the box for each applicable purpose on the updates.
· If updating items on a recertification application, the only purpose to be selected is Recertification.
· Do not type over names of school officials in Section A. To replace an official, check the radio button and then enter the name.
· Do not type over Board of Directors’ names. To change, enter an end date next to the person leaving and then add the replacement name on the new line.
· Ensure all numbers provided are direct lines, not a general institution number
· The emergency contact for your institution should be provided in Section K – Question No. 69.
· And remember to click Submit.

When you’re nearing the recertification application date, the Department of Education will send a reminder to the institution. Recertification should be completed and submitted no later than the reapplication date. Institutions should mark the expiration and reapplication dates on their calendar.

The department will upload the UEI (replacing the DUNS number) for all institutions. UEI will be added to the E-App later next year for new schools applying for participation.

It’s important that institutional leaders all work together regarding changes, and it’s important that all affected departments are aware of the changes.

For any questions or concerns, always contact your School Participation Division. In addition, the School Eligibility and Oversight Service Group can be reached at (202) 377-3173 or

HEERF relief money assisted students through pandemic-related hardships.
HEERF money was used by higher education institutions to help students through pandemic-related hardships. Colleges also used HEERF funds for health-related needs for students, to provide services that helped students continue their education and to keep staff employed.

HEERF Change: The Department of Education will allow up to 120 days for liquidation of awards.

The timeframe changed from 90 days to 120 days in November 2020, and the department made the decision to apply this change to all HEERF awards.

After awards are expended or you reach the end of your performance period, your college must liquidate and close out the award. To start this process, you will need to reach out to the Department of Education program contact listed on your Grant Award Notification.

For proprietary institutions, the HEERF audit is due at the same time as the Title IV audit. These are submitted together through eZ-audit.

In other HEERF-related news, HEERF funding was used in these ways:
93% – used by colleges to assist students through pandemic-related hardships.
88% – used for COVID tests and/or other health-related needs for students.
80% – used to provide electronic equipment or internet services for students to continue their education.
70% – used to keep staff employed.
18% – used to keep the institution open.

New Regulations for Return to Title IV: The Department of Education has updated the Q&A on the Program Integrity page for Return to Title IV.

· The order of returns for R2T4 was changed: IASG was added (No. 5 slot), preceding FSEOG and following Pell.

· Minor changes to the definition of academic activity were also made for the purpose of documenting attendance.

New R2T4 regulations:
· Include requirements related to subscription-based programs.

· Provide a change to the determination of a withdrawal. The student does not have to be considered a withdrawal if the student completes hours equal or exceeding the number of credits required for half-time enrollment status. Additionally, the student does not have to be considered as a withdrawal if the student successfully completes a module or module that represents 49 percent or more of the payment period. The 49 percent may not be rounded up.  For example, 48.7 percent could not be rounded to 49 percent for this purpose and the student would not meet the exemption.

· Change how the days in the denominator are determined for programs with modules.

· If a student meets one of the withdrawal exemptions, the student is not a withdrawal for the current payment period. This impacts enrollment reporting to NSLDS. If a student meets the exemption, the student is considered to have completed the term. If they don’t return for the next term, the student is reported as a withdrawal and the college would use the last day of the term in which the student was enrolled (this can be the term in which the student meets the exemption). If a student graduates early in the term, the college would report the student using the date the school assigns to the completion/ graduation. The guidance on institutional charges to use in R2T4 remains the same. Use the charges initially assessed for the entire payment period and only use adjustments for changes that occurred before the withdrawal.

The Future for FSA’s Annual Conference: The Department of Education plans to keep the FSA Training Conference virtual and will host a quarterly webinar for federal updates. In his keynote address at FSA in November, U.S. Secretary of Education Miguel Cordona extended his appreciation to the financial aid community for work over the last several years assisting students during difficult times. He said all sources, including federal, state and college, must invest in the future of colleges and students, with a focus on diversity and equity, as well as protecting student borrowers, decreasing loan debt and providing support to students’ physical and mental health in the new year.

Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance.