COVID-19 and Federal Work Study

COVID-19 has caused disruption in higher education institutions, which many believe will continue through the summer and fall semesters. During a recent conversation with an institution, DHG asked how the institution was handling students awarded Federal Work Study (FWS) funds. The institution responded, “We ended our FWS program in March when we closed the campus due to the coronavirus outbreak.” Higher education institutions are working to provide as much assistance to their students as possible and many are unaware that FWS can continue to be a source of student support.

Institutions need to explore their options if they will have unexpended FWS funds at the end of the award period. The Federal Student Aid Code of Regulations 34 CFR 675.18 allows institutions the following options:

  1. Carryforward up to 10 percent of the current award year funds into the next award year.
  2. Carryback up to 10 percent of the current award year funds and expended in the previous award year.
  3. Transfer up to 25 percent of FWS to the Federal Supplemental Education Opportunity Grant (FSEOG) program.
  4. FWS funds can be expended as summer awards but must be expended prior to the end of the current award year (June 30). Institutions must report the transfer of funds on the Fiscal Operations Report (FISAP).1

Due to COVID-19, the Department of Education waived the seven percent requirement to pay wages to students employed in community service jobs for the 2019-20 award year. The Department of Education has also provided regulatory guidance OPE Announcement 2020-04-03 regarding FWS payments due to the COVID-19 interruptions. For students enrolled and performing FWS at a campus that must temporarily or permanently close as a result of COVID-19, or students who are quarantined and unable to travel to campus or jobsite, the institution may continue paying the student FWS wages during that cessation.

An institution may pay a student enrolled at an eligible institution who:

  • Received an FWS award for the award period during which a COVID-19 related interruption occurred on the campus or job site.
  • Earned FWS wages from the institution for that award period.
  • Was prevented from fulfilling their FWS obligation for all or part of the award period due to a COVID-19 related interruption.2

Institutions should be mindful that unspent FWS funds could result in the reduction of FWS funds in the subsequent award years. For questions or more information, please contact nonprofit@dhg.com.

Sources

  1. Federal Student Aid Code of Regulations Federal Student Aid Code of Regulations.
  2. Office of Postsecondary Education, iLibrary - Electronic Announcements.

CONTRIBUTORS

Mark Nicolas
Managing Partner, Non-profit, Education & Government
Mark.Nicolas@dhg.com

Michael Whitfield
Senior Associate
DHG Education

nonprofit@dhg.com

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