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COVID-19 Resources: Higher Education

Federal Loans

  1. President Signs PPP Flexibility Act New
  2. Treasury Department Links
  3. PPP FAQ
  4. SBA updated requirements regarding borrower' self-certification concerning the necessity of the loan. FAQ #31 and #46
  5. Borrowers must adhere to federal nondiscrimination regulations (PPP loans are considered federal financial assistance) Published on the SBA website and on the Treasury website
  6. Safe harbor extended to give borrowers time to return Paycheck Protection Programs (PPP) loans secured with faulty self-certifications without penalty. FAQ #43
  7. When calculating loan eligibility all employees must be counted (full-time, part-time, and other work arrangements) FAQ #36
  8. When calculating loan forgiveness, count only the number of full-time equivalent employees. FAQ #36
  9. Change in ownership occurring after February 15, 2020 may not impact eligibility. FAQ #38
  10. SBA provided an alternative means of determining eligibility of seasonal employers ( February 15, 2020 or for an 8-week period between February 15, 2019 and June 30, 2019) FAQ #9
  11. SBA offered an alternative formula for calculating maximum loan amount for seasonal employers. FAQ #41 and additional information on increasing loan amount using the revised calculations was published on the Treasury website
  12. Loan awards must be disbursed in totality within 10 days of the assignment of a loan number by the SBA. Published on the SBA website
  13. Lenders will have a standard form to report disbursement and must do so in order to collect the processing fee. Published on the SBA website. with additional guidelines on the Treasury website
  14. Combined loans to businesses that are part of a group many not exceed $20,000,000. Such loans that have already been disbursed must be withdrawn or cancelled. Failure to do so will result in forfeiture of forgiveness eligibility. Published in the Federal Register
  15. PPP borrowers may not defer payrolltaxes or use employee retention credits
  16. Students in Work-Study programs excluded from employee count
  17. Paypal, Square, Kabbage, Bluevine and other the fintech companies added to PPP lenders
  18. Info on Express Bridge Loans
  19. Info on SBA Debt Relief


  • Financial statement and compliance audit deadlines are extended six months.
  • Accreditors are permitted to continue virtual evaluation visits through December 31, 2020.
  • Institutions are permitted to continue their distance programs without satisfying the accreditation requirements through December 31, 2020.
  • Institutions may accept a signed and dated statement from applicants in which they truthfully attests to secondary school completion or the equivalent. This is permissible through December 31, 2020 and is valid for both the 2019-2020 and 2020-2021 award years. New
  • Deadlines for providing documentation and getting required approvals to establish institutional eligibility during change of ownership are extended six months.
  • MCAT requirement waived for foreign graduate medical school admissions for students admitted to medical school during a year when the test was unavailable.
  • If an estimated or actual amount of PPP loan forgiveness is identified on an institution’s audited financial statements for the year in which the loan was received, and attested to by the institution’s auditor, the Department will exclude that portion of the PPP loan from total liabilities and increase the institution’s equity or net assets by that amount in calculating the institution’s composite score. See here for details.
  • Institutions must exclude work-study students when counting employees for PPP loan eligibility.
  • Institutions must exclude payroll costs for FWS students from the calculation of payroll costs used to determine their PPP loan amount. See here for details.
  • The institutional share match requirement for the Federal Work-Study (FWS) and Federal Supplemental Educational Opportunity Grant (FSEOG) programs is waived for the 2019-2020 and 2020-2021 award years.
  • An institution may reimburse itself from the FWS allocation for the nonfederal portion of wages paid to students on or after March 13, 2020. An institution may, for all disbursements of FSEOG made on or after March 13, 2020, reimburse itself from the FSEOG allocation for the nonfederal portion of FSEOG awards contributed through a fund-specific match. Additionally, this section permits an institution to transfer up to 100 percent of its unexpended FWS allocation to FSEOG. See here for details.
  • The requirement for term-based programs that a student returning from an approved leave of absence (LOA) must resume training at the same point in the academic program that he or she began the LOA is waived. See here for details.
  • For the purposes of qualifying for R2T4 relief, an institution that moved to distance learning, closed campus housing or other campus facilities, or experienced other interruptions in instruction may consider all withdrawals from students enrolled in ground-based instruction during the covered period to have been the result of circumstances related to the COVID-19 national emergency. For institutions that did not undergo changes in educational delivery or campus operations as a result of the COVID-19 emergency, the institution will be required to obtain a written attestation (including by email or text messages) from the student explaining why the withdrawal was the result of the COVID-19 emergency. Institutions must also obtain written attestations from students who withdrew from distance education programs explaining why the withdrawal was the result of the COVID-19 emergency. See here for details.
  • Institutions are allowed to exclude from the quantitative component of satisfactory academic progress attempted credits a student was unable to complete as a result of the COVID-19 national emergency. See here for details.
  • The statutory requirement for institutions to return Title IV funds as the result of student withdrawals related to a qualifying emergency is waived. See here for details.
  • Student grant overpayments are waived but must be fully documented (perform an R2T4 calculation for each waiver). This will cancel disbursement of Direct Loans but will be excluded from subsidized loan usage and Pell Grant lifetime eligibility calculations. See here for details.
  • A TEACH Grant recipient who was performing qualifying service that was interrupted due to the COVID-19 national emergency will receive credit for a full year of his or her service obligation.
  • A short question and answer document regarding pass/fail and Satisfactory Academic Progress, selective service registration verification, record retention, and data security was made available.
  • Reporting Rules for Higher Education Emergency Relief Funds New
  • Filing and Payment Deadline Extended
  • Employee Retention Credit
  • Deferral of Payment of Employer Portion of Social Security Taxes
  • Paid Sick Leave/Family Leave Credit
  • Modifications to the Limitations on Net Operating Losses
  • Modifications of Limitations on Business Interest
  • Modification of Credit for Prior Year Minimum Tax Liability of Corporations
  • Modifications for Nonprofits
  • Mandated Sick Leave
  • Student Loan Benefit
  • High Deductible Health Plans


Topics to Watch

  • Insurance: Several states are considering laws that would permit businesses to collect on business interruption claims despite lack of physical damage and specific virus or pandemic exclusions. If passed, the constitutionality of those laws may come under fire.