CLARIFYING R2T4 TREATMENT FOR COVID-19 DROP STUDENTS – McClintock & Associates

Lately, we have been receiving questions regarding the guidance for when a student withdrawal can be treated as a COVID-19 drop and be eligible for the CARES Act R2T4 relief. While the U.S. Department of Education laid out how to handle coronavirus-related interruptions of study in previous guidance, we want to share this reminder of the key points:

• For institutions that did not undergo changes in delivery or campus operations as a result of COVID-19 national emergency during a term or payment period within the covered period, written attestation (including email or text messages) will be required from the student explaining why their withdrawal was related to circumstances resulting from the emergency.
• Any institution that did undergo changes in delivery or campus operation as a result of the emergency may consider the withdrawal of students enrolled in affected programs to be a result of the emergency. The disruption of study must have occurred during the term or payment period from which the student withdrew.
• Allowable circumstances for a student include, but are not limited to, illness of the student or a family member, need to become a caregiver or first responder, loss of childcare, economic hardship, inability to access wi-fi because of closed facilities, or an increase in work hours because of the emergency.
• The covered periods include those that include March 13, 2020 or begin between that date and December 31, 2020 (or the last date the national emergency is in effect).

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