Empowering lives for 90 years!

COVID-19 Financial Aid Policies

Standards of Academic Progress (SAP) and Return of Title IV Funds (R2T4)

Updated Policy

In December 2020 Berkeley College decided to allocate a portion of its 2020-2021 Federal Work Study Federal Capital Contribution to Title IV-eligible students registered for the winter 2021 semester. Berkeley College identified 449 registered students that were Title IV-eligible and who had balances for the winter 2021 term. On December 22, 2020 Berkeley College awarded all 449 students as follows:

Balances of $500 - $999 received $500

Balances of $1,000 - $2,999 received $1,000

Balances of $3,000 or more received $1,500

Students who do not maintain at least a half-time status (6 credits or more) at the college’s winter 2021 term census point will forfeit the award. Students whose balances change due to a change in credit load or additional Financial Aid will have their Emergency SEOG moved to a prior balance, if any. Otherwise, the College will hold the credit for the spring 2021 semester. If not needed for the spring 2021 term, the student will receive the appropriate refund by the 6th week of that term.

Updated: Winter 2021


Original Policy dated Winter 2020


Based on the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. No. 116-136, and guidance provided by the US Department of Education (USDOE) on May 15, 2020 (updated on June 16, 2020), Berkeley College has adopted an Interim Satisfactory Academic Progress ( 34 CFR 668.34) policy of waiving “WF” and “WP” grades (occurring on or after March 12, 2020) for the Winter 2020 semester. Based on updated guidance, the College has adopted a somewhat different policy for students who withdraw from classes during the Spring 2020 semester and again for the Fall 2020 semester.

According to USDOE guidance dated May 15, 2020: “Section 3509 of the CARES Act allows institutions to exclude from the quantitative component (pace measurement) of satisfactory academic progress (SAP) attempted credits a student was unable to complete as a result of the COVID-19 national emergency. It is not necessary for a student to have filed an SAP appeal for an institution to exercise this flexibility. However, to exclude attempted credits from SAP, an institution must have reasonably determined that the student’s failure to complete those credits was the result of a COVID-19 related circumstance. Allowable circumstances include, but are not limited to, illness of the student or family member, need to become a caregiver or first responder, economic hardship, added work hours, loss of childcare, inability to continue with classes via distance education, inability to access Wi-Fi due to closed facilities…For example, the pace of a student who has completed 78 of 120 attempted hours is 65 percent (78/120), below what is necessary to be making SAP. However, if the 12 credits the student attempted but was unable to complete in (Winter) of 2020 are excluded due to a COVID-19 related circumstance, the pace becomes 72 percent (79/108) and the student is making SAP.”

Berkeley believes that every student enrolled in at least one onsite class was adversely impacted by the pandemic and resulting suspension of onsite classes. This is consistent with USDOE guidance dated May 15, 2020 that states “Any institution that moved students from ground-based instruction 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.” Therefore, for the Winter 2020 semester, Berkeley considers every withdrawn course, on or after the first day of suspension of onsite classes (March 12, 2020), to be COVID-19 related except for 100% online students. For withdrawals by 100% online students to be considered COVID-19-related, the student must submit an attestation to that effect. Based on June 16th guidance, the College has extended this policy through Spring 2020 assuming the national emergency is still in effect. For that semester every student will require an attestation to receive the SAP waiver.

For the Fall 2020 semester the College does not anticipate a disruption of classes. All students, with few exceptions are fully online or hybrid and are accustom to that experience. Students who withdraw from one or more classes will be sent a communication advising they can request an attestation to document that their withdrawal was due to a COVID-19 medical event that will have to be documented. In addition, those students who are completely on campus for the Fall, should there be a disruption, will be afforded the same policy as we had in the Spas those in the Spring were afforded.

Attestation Process

The College is sending all appropriate people an email that will include a link to an eform attestation. The attestation should be completed by the deadline indicated. Those past the deadline may or may not be considered for waivers.

If the College denies a student’s eligibility for waiver, based on the guidelines from the US Department of Education referenced above, the student will be given the ability to appeal via the appeal committee’s email address. The committee’s determination is final.

Updated: Fall 2020


Original Policy dated Summer 2020


Federal regulations require that a college perform an R2T4 calculation if a student fully withdraws prior to the 60.01% point of the semester. As Berkeley is not an attendance-taking institution, unofficial withdrawals, per federal regulation, are brought to the 50% point for this calculation. The college/student must return all the federal financial aid, as indicated by the results of the R2T4 calculation. The waiver, provided by the CARES Act, allows the college to not return the funds or, if the college already did so, to re-disburse the aid to the student’s accounts. If there is an open balance, Berkeley will apply the aid to that first. Any remaining credit will be refunded to the student.

This interim policy is based on the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), Pub. L. No. 116-136, (CARES Act), and guidance provided by the US Department of Education (USDOE) on March 5, 2020 (updated March 20, 2020), April 3, 2020 and May 15, 2020 (updated June 16, 2020).

The May 15, 2020 guidance clarified the timeframe for R2T4 waiver eligibility. Specifically, the guidance states: “For any student who begins attendance in a payment period or period of enrollment that begins on or includes March 13, 2020, and subsequently withdraws from the period as a result of COVID-19-related circumstances, an institution is not required to return Title IV funds.” This means that all students who withdrew from Berkeley College’s winter 2020 semester are potentially eligible for the R2T4 waiver.

The May 15, 2020 guidance also clarified which onsite and online students are eligible for the CARES Act R2T4 waiver. Specifically, the guidance states: “Any institution that moved students from ground-based instruction 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.” Therefore, based on this guidance, all Berkeley students enrolled in at least one onsite class during the Winter 2020 semester are eligible for the CARES Act R2T4 waiver.

As for students who were 100% online during the winter 2020 semester, the May 15, 2020 guidance states: “Institutions must obtain written attestations from students who withdrew from distance education programs explaining why the withdrawal was the result of the COVID-19 emergency.” Therefore, Berkeley will be reviewing records and contacting all students who were 100% online and withdrew during the winter 2020 semester to determine if the withdrawal was the result of the COVID-19 emergency and, if so, obtain an attestation to that effect.

Those students who are now eligible for the waiver, based on the new guidance, already had the R2T4 calculation completed and funds were returned. For these students, Berkeley will request funds back. Berkeley will make every effort to retrieve and return any monies due to the government. If retrieved funds cause a credit balance, Berkeley will refund the student within 14 days of that credit.

Students who withdrew due to COVID-19 and were left with open balances as a result, that appealed for and received an offsetting credit and had their aid reinstated, will have the offsetting credit removed before the college determines the amount of student refund available.

Based on June 16th guidance, we have extended this policy through spring 2020 and fall 2020 assuming the national emergency is still in effect. For these two semesters every student will require an attestation to receive an R2T4 waiver.

For the Fall 2020 semester the College does not anticipate a disruption of classes. All students, with few exceptions, are fully online or hybrid and are accustomed to that experience. Students who do fully withdraw from classes will be sent a communication advising they can request an attestation to document that their withdrawal was due to a COVID-19 medical event that will have to be documented. Those students who are completely on campus for the Fall, should there be a disruption, will be afforded the same policy as those in the Spring were afforded.

Attestation Process

The college is sending all appropriate people an email that will include a link to an eform attestation. The attestation should be completed by the deadline indicated. Those past the deadline may or may not be considered for waivers.

If the college denies a student’s eligibility for waiver, based on the guidelines from the U.S. Department of Education referenced above, the student will be given the ability to appeal via the appeal committee’s email address. The committee’s determination is final.

As the CARES Act waives all student loans disbursed to eligible withdrawn students, Berkeley will not request permission to reinstate or not return loan(s) from these students. Disbursement letters will be sent to students, as required by the regulations, when funds are received the second time. Students will still have the option to decline the loan, however, as the loan is being forgiven it is expected that students will not do so and instead will accept refunds as anticipated by the CARES Act.

Berkeley will report the names and aid values that would have otherwise been returned as required by USDOE.

Updated: Fall 2020


Original Policy dated Summer 2020


New York State (NYS) defined impacted students as those who are (a) unable to complete courses for the term or (b) earn fewer credits or a lower grade than required by award programs due to COVID-19, regardless of where or how, including:

  • Students enrolled in or who were supposed to begin travel-abroad experiences and were either called back to the US or were not able to begin
  • Students who met full-time requirements, but because of COVID-19, have fallen below the credit requirements
  • Students who have come in contact or become sick with the virus and could not complete a class
  • Students impacted by emergency closures or temporary campus closures in order to prevent the spread of COVID-19
  • Students impacted by other related emergency events to prevent the spread of COVID-19

For students, that meet the above criteria, NYS has allowed colleges that have collected documentation (in Berkeley College’s case we have been using the same attestations collected for the federal waivers), to certify students as COVID impacted. These students will be forgiven:

If for Winter 2020 – the Winter payment and SAP/POP for their next payment

If for Spring 2020 – the Spring payment and SAP/POP for their next payment

If for Fall 2020 – the Fall payment and SAP/POP for their next payment

As of this November 1, 2020 the above policy is based on guidance provided by New York State Higher Education Services Corporation. However, it is important to note that the New York State Governor’s Office has not yet officially approved it. Berkeley College is proceeding based on the guidance.

Empowering lives for 90 years!