New FISAP Instructions Under the CARES Act

On August 3, 2020, the Fiscal Operations Report for 2019-20 and the Application to Participate for 2021-22 (FISAP) instructions became available. The reporting instructions include additional flexibilities provided by the Coronavirus Aid, Relief, and Economic Security Act (CARES Act). The submission of the FISAP was extended this year from October 1 to November 2. The FISAP added five supplemental reporting instructions and additional flexibilities to provide relief to schools under the CARES Act due to COVID-19:

• Schools that meet certain guidelines will not need to request an underuse waiver, and underuse penalties will not be applied on any 2021-22 Federal Work-Study (FWS) or Federal Supplemental Educational Opportunity Grant (FSEOG) awards for all schools due to the impact of the COVID-19 emergency.
• Schools are permitted to transfer up to 100% of their unexpended FWS allocation to FSEOG.
• Institutions are allowed to reimburse themselves from the FWS allocation for the nonfederal portion of wages paid to students on or after March 13, 2020.
• Schools are provided an option to use any amount of their FSEOG allocation to award emergency financial aid grants to assist undergraduate or graduate students with qualifying emergency expenses.
• A specific section within the FISAP is included to report any FWS wages paid to students after they ceased working due to COVID-19.

For additional information, please refer to the Department of Education announcement or contact Schneider Downs.