Section 443(b)(2)(A) of the Higher Education Act of 1965, as amended (HEA) and the corresponding regulations at 34 CFR 675.18(g) set forth the Federal Work-Study (FWS) community service expenditure requirements that a school must meet unless the school is granted a waiver from the Secretary.
A school participating in the FWS Program is required to expend at least seven percent (7%) of its FWS federal allocation to pay the federal share of wages to students employed in community service jobs in an award year. A school is also expected to provide the institutional share of wages to students employed in community service jobs. In addition, one or more of the school's FWS students must be employed as a reading tutor for children in a reading tutoring project or performing family literacy activities in a family literacy project [34 CFR 675.18(g)(1)].
A school that fails to meet one or both of the FWS community service requirements may be:
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required to return FWS federal funds in an amount that represents the difference between the amount the school should have spent for community service and the amount it actually spent,
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subject to a substantial fine, and/or
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subject to other sanctions, including a Limitation, Suspension, and Termination (L, S, & T) proceeding, through which the school could be denied future participation in the FWS Program, and possibly other Title IV, HEA programs.
The Secretary may waive one or both community service requirements for a school if the school demonstrates that enforcing the requirement(s) would cause a hardship for students at that school. The fact that it may be difficult for the school to comply with the requirement(s) is not in and of itself a basis for granting a waiver [34 CFR 675.18(g)(2)]. In the past, the Secretary has approved a limited number of waivers for schools that were able to demonstrate an exceptional circumstance. These include, but are not limited to:
Small FWS Allocation – The supporting information submitted by the school noted that seven percent (7%) of the school's allocation provided only enough funds for a student to work in a community service job for a short period of time. Therefore, the school was unable to find placement for a student in a community service job.
Rural Area - The school is located far from the type of organizations that would normally provide community service jobs. Information provided showed that the school’s students lacked the means of transportation to get to the location of the community service jobs. In a similar waiver request in which transportation did exist, the school provided documentation that showed that the transportation costs were extremely high for the students.
Specialized Program - The school offered only a single program of specialized study that required its students to spend extensive amounts of time in classroom and non-classroom academic activities. The school provided information that demonstrated that this specialized educational program did not allow its students to have time for performing community service jobs at the time those work opportunities were available.
Note: As explained in Dear Colleague Letter 17-08, if a school is unable to meet the community service requirements due to the impact of a Federal Emergency Management Agency (FEMA)-declared disaster, it should complete a waiver request using the submission process described below.
A school must submit its waiver request to the Department of Education (the Department) electronically via the Common Origination and Disbursement (COD) website. To submit the request:
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Log into the COD Website
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Select the “School” link from the top navigation bar
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Select “Campus-Based” from the left navigation menu
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Select “Forms and Waivers” from the left navigation menu, then click “Manage Application”
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From the Manage Application page, locate the Community Service Waiver and click “Create”
The school's waiver request must specify whether the school is requesting a waiver of the 7% community service requirement, the reading tutors of children or family literacy project requirement, or both. It must also include detailed information to demonstrate that complying with the requirement(s) would cause hardship for the school's students.
Completed submissions must be accepted by the COD system by midnight ET.
A waiver request that is received after April 21, 2025, will not be considered.
The Department plans to notify, via email, each school that submitted a 2025–26 FWS Community Service waiver request that a determination has been made regarding its waiver request no later than June 27, 2025.
Emails are sent to the school’s Financial Aid Administrator, as provided in the school’s most recently submitted Fiscal Operations Report and Application to Participate (FISAP).
In the email, we will inform the school that the Secretary's determination regarding the school's waiver request has been posted to the COD website.
To review the Secretary’s determination:
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Log into the COD Website
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Select the “School” tab from the top navigation bar
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Select “Campus-Based” from the left navigation menu
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Click "Self-Service" on the left navigation menu
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Select “Notifications” to view a copy of your school’s FWS Community Service Waiver letter
If you have additional questions about the FWS community service expenditure requirements or the procedures for requesting a waiver, contact the FSA Partner and School Relations Center at 1-800-848-0978. You may also email CODSupport@ed.gov.