McClintock & Associates

Michael T. Wherry, CPA

July 6, 2020

Based upon the electronic announcements issued by the U.S. Department of Education (ED) and the relief provisions in the CARES Act, we have been receiving numerous questions from institutions on implementing and interpreting this guidance. As a result, we have compiled this Questions and Answer for institutions to utilize as we await future guidance from ED. While, ED has not issued any guidance related to provisions in the CARES Act, we anticipate this is forthcoming at some point.

General Notes
1) ED has provided guidance for interruptions of study related to the Coronavirus.

• https://ifap.ed.gov/electronic-announcements/030520Guidance4interruptionsrelated2CoronavirusCOVID19

• https://ifap.ed.gov/electronic-announcements/040320UPDATEDGuidanceInterruptStudyRelCOVID19

• https://ifap.ed.gov/electronic-announcements/051520UPDATEDGuidanceInterruptStudyRelCOVID19May2020

2) To date, ED hasn’t waived any of the Cash Management provisions in the Q&As which it has issued (March 5, 2020 and March 20, 2020) nor the CARES Act. Thus, all aspects of cash management including drawdowns under HCM1 and the requirements surrounding student Title IV credit balances still in place. However, in its 4/3/2020 electronic announcement, ED indicates that exceptions could be made if an institution is unable to comply due to COVID-19 disruptions. Where an institution is unable to comply, it should document the reason(s) for instances where it is unable to comply and retain the documentation in its records.

• M&A recommends attempting to obtain authorizations and the student’s intent via email or phone calls.

• Delays which arise due to institutional personnel being available to work or access to the appropriate information should be documented.

• Ensure you document why a decision made was in the best interest of the student.

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