What Are the R2T4 Reporting Requirements Under the CARES Act?

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This AskRegs Knowledgebase Q&A was updated on March 11, 2021, to include updated guidance published in the March 10, 2021 Electronic Announcement: COD System Implementation for 2021-22 Award Year (COD-21-02) and attachment, COD System Processing Function Modifications for 2021-22.

There are two sets of return of Title IV funds (R2T4) reporting requirements and Coronavirus Indicators under the CARES Act:

  1. Reporting necessary to apply the CARES Act withdrawal benefits; and
  2. Reporting the total amount of Title IV funds that were not returned to ED under the R2T4 waiver.

Reporting Necessary to Apply the CARES Act Withdrawal Benefits: Under Sections 3506, 3507, and 3508 of the CARES Act, the U.S. Department of Education (ED) will apply certain benefits when a student withdraws from a payment period or period of enrollment within the covered period due to COVID-19 and the school has applied the R2T4 waiver. Upon learning that the student qualifies for the withdrawal benefits, ED will:

In order to meet this reporting requirement, the school is required to set the Coronavirus Indicator in the Common Origination and Disbursement (COD) System on all individual Title IV disbursements that were made during that qualifying payment period/period of enrollment.

As announced in the attachment to the September 23, Electronic Announcement and a December 16, 2020 COD Processing Update, schools have until December 31, 2020 to set the Coronavirus Indicator for 2019-20 disbursements that qualify for the COVID-related withdrawal benefits. The deadline is September 30, 2021 for the 2020-21 award year.

Per the Electronic Announcement, "Failing to add the Indicator by that date could cause loan repayment amounts to be calculated incorrectly for students who are entering or re-entering repayment at that time. Similarly, failing to add the Coronavirus Indicator on all Title IV aid types in a timely manner could result in students not receiving the full amount of Title IV aid for which they are eligible. Note: Schools should set the Coronavirus Indicator only after confirming that no further changes to a disbursement will be necessary. No changes may be made to a disbursement after the Coronavirus Indicator is selected."

Reporting the Total Amount of Title IV Funds That Were Not Returned to ED Under the R2T4 Waiver: Per the May 15, 2020 Electronic Announcement, "The CARES Act requires an institution to report to the Department information specific to each student for whom it was not required to return Title IV funds under the waiver exception (and for each student for which Title IV funds were previously returned and are now being redrawn)." The required information is:

To meet this reporting requirement, the school has two options. It can either:

The school may use either one of these options; however, it must use the same option for all students. NASFAA has received updated guidance from ED indicating a school that used the R2T4 Calculator Tool in COD may use the R2T4 Lump Sum Reporting page. However, when doing so, the school must report all amounts not returned using the Lump Sum Reporting page, “even amounts that it previously reported using the R2T4 Calculator Tool.” That is, if a school decides that it would rather use the new R2T4 Lump Sum Reporting page in COD when it becomes available, it must include in that reporting all amounts that were previously reported using the R2T4 Calculator Tool; that is, it must complete reporting for all students using the R2T4 Calculator Tool or it must complete reporting for all students using the R2T4 Lump Sum Reporting page. See AskRegs Q&A, Can the School Use Both the R2T4 Calculator Tool and the Alternative Reporting Method For CARES Act Reporting Requirements?

Whichever option the school chooses, the deadline for this reporting requirement is not until September 30, 2021 for both award years.

R2T4 waiver refers to the fact that the CARES Act waives the requirement for the school or the student to return Title IV funds when a student withdraws due to COVID-19 anytime during the entire payment period that falls within the covered period.

Covered period refers to the fact that the May 15 Electronic Announcement allows schools to apply the R2T4 waiver to: 1) payment periods or periods of enrollment that include March 13, 2020; or 2) payment periods or periods of enrollment that begin between March 13 and the later of December 31, 2020 or the last date the national emergency is in effect.

As soon as we have additional information on the reporting process and method, we will update this AskRegs Q&A and post it in Today's News.

Reference the May 15, 2020 Electronic Announcement, the September 23, Electronic Announcement, the July 30, 2020 Electronic Announcement, and the November 6, 2020 Electronic Announcement for more information. See also the following AskRegs Q&As:

Remember: These R2T4 reporting requirements are unrelated to the reporting requirements for Higher Education Emergency Relief Fund (HEERF) grants to students or institutions.

Notes:

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.