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COVID-19 Resources: Higher Education

Federal Loans

  1. PPP FAQ. Updated
  2. Loan Forgiveness Application .Updated
  3. Other PPPInformationn. Updated
  4. How to use a PPP loan to refinance an Economic Injury Disaster Loan (EIDL).
  5. SBA updated requirements regarding borrower's self-certification (loan necessity). FAQ #31 and #46
  6. Borrowers must adhere to federal nondiscrimination regulations.
  7. Safe harbor extended to give borrowers time to return Paycheck Protection Programs (PPP) loans secured with faulty self-certifications without penalty. FAQ #43
  8. When calculating loan eligibility all employees must be counted (full-time, part-time, and other work arrangements). FAQ #36
  9. When calculating loan forgiveness, count only the number of full-time equivalent employees. FAQ #36
  10. There is an alternative means of determining eligibility of seasonal employers. FAQ #9
  11. There is an alternative formula for calculating maximum loan amount for seasonal employers. FAQ #41 (additional information on increasing loan amount provided here.
  12. PPP borrowers may not defer payroll taxes or use employee retention credits.
  13. Students in Work-Study programs excluded from employee count.
  14. Info on Express Bridge Loans. and SBA Debt Relief.










Compliance

  • Because colleges and universities (NAICS 6113) are partially exempt industries, they are not required to keep injury and illness records. However, according to the updated OSHA FAQ, they are required to report employee hospitalization if it occurs within twenty-four hours of exposure to COVID-19 in the workplace. New
  • The COD system update includes a coronavirus indicator and a Return to title IV calculator.
  • The Return to Title IV (R2T4) requirements for student withdrawals related to COVID-19 are waived.
  • Financial statement and compliance audit deadlines are extended six months. Updated
  • Accreditors are permitted to continue virtual evaluation visits through December 31, 2020. Updated
  • Institutions are permitted to continue their distance programs without satisfying the accreditation requirements through December 31, 2020. Updated
  • Quarterly reporting mandated by the Cares Act is satisfied through the monthly reporting already required by the Federal Funding Accountability and Transparency Act (FFATA). Updated
  • 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
  • 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.

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.