How Institutions Can Access Title IV Financial Aid Relief During Disasters

When a community faces a natural disaster, institutions and the teams that keep them running may struggle to keep up. From one moment to the next, students may feel that their plans are suddenly unclear. The idea of navigating financial aid relief during a disaster, no matter how significant the impact, may be overwhelming at first. However, the Department of Education (ED) has straightforward guidance to help schools and students manage Title IV financial aid during difficult times. We’ve outlined a few key areas to consider if Hurricane Helene has impacted your school. With these tools, you can lead through times of uncertainty and crisis.    

The Role of Dear Colleague Letter GEN-17-08   

Finding clear guidance can be challenging when facing the aftermath of a natural disaster. The Dear Colleague Letter GEN-17-08 provides general guidance that is essential for understanding Title IV federal student aid during declared disasters. 

The GEN-17-08 letter offers straightforward guidance on what to do, covering everything from aid disbursement to managing student records.  Clearly, understanding the steps you need to take can save your team significant rework and help students get back on track as soon as possible.   

Reference: Department of Education  

Disaster Area Designations & Regulatory Relief  

The guidance in the Dear Colleague Letter GEN-17-08 applies specifically to areas that FEMA has designated for “Individual Assistance” during federally declared disasters. The designation is key because it determines which areas and institutions are eligible for relief measures.   

Additionally, the HEROES Act offers further flexibility in certain circumstances, such as allowing deadline extensions and deferring requirements to ease the burden on institutions dealing with the disaster’s aftermath.  

Maintaining Institutional Participation and Eligibility  

Although GEN-17-08 doesn’t spell out all you need to do to maintain eligibility, it does provide steps institutions should take to stay compliant during a disaster.  

If your institution has to close temporarily, or needs other regulatory relief, open communication is key. It’s important to reach out to your School Participation Division to discuss the challenges you’re facing.  

The Department of Education handles cases individually, working with schools to determine how they can maintain eligibility and minimize disruptions.  

Establishing Agreements for Continued Study  

Sometimes, a disaster makes it impossible for an institution to continue offering its programs. In these cases, GEN-17-08 suggests that schools make agreements with other institutions. Setting up these agreements can help ensure that students do not lose time because of factors they cannot control.  

Adjusting Financial Aid through Professional Judgment (PJ)  

Financial aid administrators have significant flexibility when adjusting aid for students impacted by a disaster. Using Professional Judgment (PJ), administrators can account for a student’s special circumstances, such as sudden unemployment or loss of income that would incur from the natural disaster.   

• Income Adjustments: Administrators can set a student’s income to zero if the student provides documentation of unemployment. 
• Family Financial Changes: Adjustments can also be made for broader family financial impacts caused by the disaster.  

PJ is essential for ensuring that the financial aid package accurately reflects a student’s current situation rather than just what was true before the disaster.  

Satisfactory Academic Progress, Verification Waivers, and Handling Lost Records  

Natural disasters can impact students’ ability to meet Satisfactory Academic Progress (SAP) standards, and institutions have the authority to make exceptions when necessary. If students fall behind because of unexpected events, they can still be in good standing – if documented correctly.  

Similarly, verification requirements—needed for confirming application data—can be waived if records are lost or destroyed, provided there has been a reasonable effort made to reconstruct them.  

Additionally, disasters may lead to the loss of important student records. Dear Colleague Letter GEN-17-08 acknowledges these challenges and states that institutions won’t be held responsible for lost records if they document their efforts to preserve or reconstruct them.  

The Department of Education also provides administrative relief to help manage compliance issues, covering areas like cash management, loan cancellations, and late disbursements. This flexibility helps schools manage disaster impacts while staying compliant.  

Financial Aid Relief for Students – Return of Funds, Waivers, and Federal Work-Study  

If students must withdraw from school due to a disaster, institutions are still required to perform a Return of Title IV Funds calculation to determine how much aid the student earned during their enrollment. This ensures that students aren’t responsible for loans they didn’t fully use.  

Similarly, disasters can disrupt Federal Work-Study (FWS) jobs, leaving students without income. Relief measures allow institutions to continue paying students who are unable to fulfill their work obligations. Institutions are also encouraged to employ FWS students in cleanup and relief efforts, which counts as community service under the FWS program. This helps the community but also ensures that students can continue to benefit from their work-study awards.  

Flexibility in Deadlines and Reporting  

Meeting reporting deadlines during a disaster can be challenging. Both the Dear Colleague Letter GEN-17-08 and the HEROES Act waivers provide flexibility on deadlines. This allows institutions to meet compliance requirements based on individual cases. This helps institutions focus on what matters most during a crisis: keeping their students safe and supported.  

Navigating Challenges with Title IV Disaster Relief Measures  

Navigating financial aid during a natural disaster can feel overwhelming, but you’re not alone. Resources exist to help both institutions and students find a path forward. The Department of Education helps Title IV recipients by offering relief in several areas.  

This includes maintaining eligibility, adjusting aid, and providing verification waivers. Their goal is to reduce disruptions and ensure ongoing access to education. For more detailed guidance and resources, visit the ED’s Federal Student Aid National Disaster Information page or contact your School Participation Division for any institution-specific questions. With the right tools and support, we can navigate even the most difficult circumstances together.  

If you’re a FAS client, reach out to us directly to see how we may be able to support you in this challenging time. 

Links for quick access:

📌Department of Education – Guidance for Title IV Participants Affected by Helene

📌Department of ED – Natural Disaster Information

📌Department of ED – Dear Collegue Letter GEN-17-08

📌NASFAA AskRegs Resource (Requires Member Access)