International Education

Academic Affairs Division

Virtual Study Abroad & Financial Aid

Information below garnered from representatives of the following organizations: 1) National Association of Student Financial Aid Administrators (NASFAA) and Subcommittees of NAFSA: Association of International Educators including 2) NAFSA Federal Financial Aid Subcommittee and 3) NAFSA Financing Education Abroad Subcommittee


Alternative to Faculty-Led:

If you are planning a virtual study abroad program as an alternative option to an in-person home institution faculty-led study abroad program in which the students are students at your (U.S.) home institution, and these courses are taught or facilitated by instructors at your home institution, earning resident credit, these courses would be treated the same as any other distance learning course for the purposes of determining Federal Student Aid eligibility.

Foreign Institution Courses, with Written Agreement:

If the student is enrolled in a course with a foreign institution as part of a written arrangement with the home school, the distance course would be eligible for Federal Student Aid under the agreement if accepted for credit at the home school (e.g. some kind of placeholder credits that will turn into your school’s credits once they complete their program). See the Office of Postsecondary Education’s April 3, 2020 Electronic Announcement which states (emphasis added):

“Pursuant to section 3510 of the CARES Act, the Secretary permits any part of an otherwise eligible program at a foreign institution to be offered via distance education, if the applicable government authorities in the country in which the foreign institution is located have declared a public health emergency, major disaster or emergency, or national emergency related to COVID-19. Retroactive to March 1, 2020, institutions may use this flexibility for the duration of such emergency or disaster and the following payment period for purposes of Title IV of the HEA. The term “foreign schools” are those institutions located outside of the United States that participate in the Title IV Direct Loan Program and award their credentials to U.S. students. This term excludes study-abroad programs in which a foreign institution provides instruction to a student who remains a degree-seeking student from the student’s domestic U.S. institution. Students in this category have always been permitted to engage in distance learning.”

Third Party Program:

If a student is participating in a 3rd party (including overseas institutions) program whereby a student is not registered for courses at their home institution and not earning resident credit, then Federal Student Aid cannot be used. The logic is that – if a matriculating student at your institution is not enrolled at your institution for a term, they are not eligible for your institution to process and provide Federal Student Aid.

Online Learning:

The NAFSA Financing Education Abroad Subcommittee indicates that each institution’s financial aid office will have its own interpretation regarding whether Federal Student Aid can be applied to virtual abroad programs. USG Study Abroad colleagues should consult with your institution’s Financial Aid Office


The NAFSA Federal Financial Aid Sub-committee put out a web page last March and have since updated it as the CARES Act (in June) rolled into law with our understanding of how it works. Take a look here.

Please note that the Department of Education has not changed the wording of their FAQ page, or any other documents concerning study abroad and virtual learning since the CARES Act. The language still talks in terms of the mid-Spring 2019 term shutdown of campuses and partial online learning to finish the term. Members of the NAFSA Federal Financial Aid Sub-committee have been trying to get better clarification for Fall 2020 and beyond.

In short, for Federal Student Aid to work, the students still need to be in “placeholder” or credit at a Federal Student Aid (Title IV) eligible school. That is not changing.