UPDATED Guidance for interruptions of study related to Coronavirus (COVID-19)

Update 08/24/2020 - Guidance provided by the U.S. Department of Education Friday, August 21st, 2020 has extended the previous flexibilities provided by the Department through the later of 1) December 31st, 2020 or 2) the end of the payment period that includes the end date for the Federally-declared emergency related to COVID-19. This updated guidance includes the EA published on April 3rd, 2020 that detailed flexibilities for V4/V5 verification including:

  • Suspending the notary and in-person requirements for the Statement of Educational Purpose
  • Accepting an expired Government-issued photo ID 
  • Allowing for other documentation in place of a signed statement from a parent for verification of number in household and number in college when no responsible parent can provide the signature


CampusLogic is working on updating StudentForms to allow for the student upload of the Statement of Educational Purpose for all active award years, and making the expiration date on the valid government-issued photo id optional. Look for a release note to identify when these changes are deployed into production. Until then, the school may continue to use the workarounds provided in the original post. 


For the additional documentation instead of the parent signed statement, the school should continue to original workaround.


The full EA may be viewed here.


Update 07/02/2020 - StudentForms has been updated on 07/01/2020 to no longer allow student uploads of the 2019-2020 Statement of Educational Purpose. This is due to the guidance provided on April 3, 2020 was effective through June 30th, 2020.  If the school has a crossover payment period that extends beyond June 30th, 2020 that would allow the student to upload, the school would follow the workaround provided in the original post below.  If additional guidance from the U.S. Department of Education is provided extending the leniency, CampusLogic will review and determine if additional updates are needed.



Update 06/12/2020 - NASFAA has provided an update through AskRegs based on a verbal conversation with ED. The updated guidance provided indicates that the electronic announcement from April 3rd, 2020 was not AY specific and was date specific. Indicating that through June 30th, 2020 the emergency flexibilities for the Statement of Educational Purpose/Identity V4 & V5 and Parent signature may be applied to 2020-2021 verification processing. It is up to the school to determine if these additional flexibilities are for documents received prior to June 30th or if verification needs to be completed by June 30th.  


The full AskRegs article may be viewed here, a pdf version has been attached.


At this time, CampusLogic will not be making additional changes to allow for students to upload the 2020-2021 Statement of Educational Purpose/Identity for V4 & V5 without confirmation in writing from the U.S. Department of Education. If written guidance is provided or the deadline is extended, CampusLogic will review at that time to determine if additional changes will be made.


If a school chooses to allow the additional flexibilities for the 2020-2021 verification processing, they may use the workarounds provided in the original post below.


Update 04/09/2020 - StudentForms has been updated to allow the student to upload their Statement of Educational Purpose. The task instructions have also been updated to reflect the change to allow the student to upload the statement and valid government-issued photo ID. For more information please see the Release Notes provided after the deployment on 04/09/2020.


Original Post

On Friday, April 3 the Department of Education released an electronic announcement that outlines additional guidance about temporary lenience to regulatory and reporting requirements. The EA states:


“Unless otherwise specifically stated in this guidance document, the emergency flexibilities set forth below remain effective until and through June 30, 2020, unless the payment period crossover extends over award years and is attached to the 2019-2020 award year. In that case the effective date is through the end of the crossover payment period.”


In this announcement there were two items that impacted the Federal verification process. CampusLogic is in the process of reviewing these requirements and determining what if any changes will be made to the StudentForms application. A summary of these two items are below.


Statement of Educational Purpose/Identity V4 & V5


Federal Guidance:


For those borrowers in verification groups V4 or V5, the flexibilities listed below apply if the institution is unable to receive the required documents in person or by mail (e.g., qualified staff are not on campus to complete this task or students are not able to mail documents). These flexibilities also apply if the applicant or student is unable to provide the required documents in person or cannot provide notarized documents by mail.


We suspend the in-person submission and notary requirements for V4 and V5 verification. The institution may allow an applicant or student to submit copies of the required verification documents electronically to the institution. This may occur by uploading a photo of the documents (including from a smartphone), PDF, or other similar electronic document through a secure school portal, by email, etc.


We also recognize that forms of identification (such as a driver’s license) may expire with no real and reasonable opportunity for renewal due to social distancing requirements. Institutions may accept a copy of an expired document if it expired after March 1, 2020.


Response:


CampusLogic is evaluating the tasks associated with the V4 & V5 tracking groups to determine what adjustments can be made to allow a student to upload his/her documentation. If you need to take action immediately for a student, the below work around is currently available in the StudentForms application.


At this point in time, the Statement of Educational Purpose can be downloaded by the student and completed. If an institution chose to add the Financial Aid document 1 or Financial Aid Miscellaneous document to an impacted student, the student could download the Statement of Educational Purpose to complete it and upload it into the appropriate information request added by the school. The institution could provide instructions to the student about this within the additional information request. The institution would then need to waive the Statement of Educational Purpose task and the file could be submitted for review.


Parent Signature


Federal Guidance:


The Department waives the requirements under § 668.57(b) and (c) that a dependent student submits a statement signed by one of the student’s parents when no responsible parent can provide the required signature. In such a situation, the institution must note and retain an explanation of why neither of the student’s parents was available to provide such a statement.


Response:


In the rare instance that a parent is not available to sign documentation for a dependent student under § 668.57(b) and (c) (verification of household size and number in college), the following steps should be taken:


  • The institution should add a signed statement to the students verification transaction with instructions for the student to explain why neither of the student's parents are available to provide such a statement
  • The institution should instruct the student to opt out of e-signature on the verification worksheet.
  • The student should wet sign the form and upload it into StudentForms
  • During the review process, the institution is responsible for ensuring that all signatures are present on the form or that documentation is adequate to waive a parent signature requirement.


CampusLogic continues to monitor evolving and new guidance from the Department and is working diligently to provide necessary adjustments as quickly and effectively as possible. Additional information and updates will be made available through normal channels to include the known Issues forum in the support portal and through your Customer Success Manager.


This communication is not meant as regulatory guidance or advice to a school. It is the responsibility of the institution to ensure that the implementation, configuration, updates to, and utilization of the tool set purchased from CampusLogic are meeting Federal and State regulatory requirements/sub regulatory guidance, institutional polices, and accrediting body standards and requirements.


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