The Department of Education announced that it updated the Return to Title IV (R2T4) portion of its COVID-19-related Frequently Asked Questions webpage.  Specifically, the Department added the following question:

• Is the R2T4 waiver under the CARES Act mandatory, or may an institution opt to continue returning funds to the Title IV programs even for those students whose withdrawals are the result of circumstances related to the COVID-19 emergency?

The CARES Act provided a number of flexibilities related to programmatic requirements and processes for institutions regarding campus-based aid program waivers, the ability to use the Federal Supplemental Educational Opportunity grant program for emergency grant aid to students, and the ability to issue Federal Work-Study payments to students who are unable to work due to COVID-19.
 
Among the flexibilities granted by the CARES Act is that an institution is not mandated to calculate the amount of grant or loan assistance it must return to the Secretary of Education in the case of students who withdrew from a program as a result of COVID-19.
 
The new FAQ clarifies that if an institution would like to apply the remaining amount of Title IV funds that would be applied to a student’s credit balance (after all charges on the student’s account are paid) to reduce a student’s prior Direct Loan disbursement, this action is allowable with the written consent of the student. Any remaining amount must be returned to the student.

The updated FAQs also deal with what an institution can do if it believes students are not telling the truth regarding their need to withdraw due to COVID-19. The FAQs indicate that in such cases, the institution may request any additional documentation reasonably necessary to determine the accuracy of the attestation.