Title IV Compliance: Updated COVID-19 Considerations

Thoughtware Alert Published: Apr 17, 2020

On April 3, 2020, the U.S. Department of Education (ED) released updated information that expands on its previously issued March 5, 2020, guidance related to interruptions of study as a result of the SARS-CoV-2 virus and incidence of COVID-19. Subsequent to the previous guidance, the COVID-19 outbreak was declared a national emergency and the declaration is considered by the ED to be equivalent to a federally declared major disaster, as defined in the Robert T. Stafford Disaster Relief and Emergency Assistance Act. Following this declaration, President Trump signed the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). With the declaration of the emergency and signing of the CARES Act, there are emergency flexibilities as well as regulatory relief available for higher education institutions.

The CARES Act and recent ED guidance have generated many questions among higher education institutions. Selected frequently asked questions as well as selected topics from the CARES Act and recent ED guidance are summarized in the downloadable PDF below. Unless otherwise specifically stated, all topics below remain effective until and through June 30, 2020.

As with most topics related to COVID-19, changes are being made rapidly. Please note that this information is current as of the date of publication. Reach out to your BKD Trusted Advisor™ or submit the Contact Us form below if you have questions.


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