What Are the R2T4 Reporting Requirements Under the CARES Act?

This AskRegs Knowledgebase Q&A was updated on January 31, 2023 to note that the COVID-19 national emergency will end on May 11, 2023.

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, 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:

• Cancel the entire amount of any Direct Loan disbursement borrowed by the student or his or her parent for the payment period or period of enrollment;
• Exclude from a student’s Federal Pell Grant lifetime eligibility used (LEU) any payment period that the student does not complete due to a qualifying emergency;
• Exclude from a student's subsidized usage limit applies (SULA) any payment period that the student does not complete due to the qualifying emergency; and
• Cancel the entire amount of any TEACH Grant disbursement received by the student for the payment period or period of enrollment and restore grant eligibility for that amount.

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.

Deadlines: As announced in the attachment to the September 23, 2020 Electronic Announcement and a December 16, 2020 COD Processing Update, schools had until December 31, 2020 to set the Coronavirus Indicator for 2019-20 disbursements that qualify for the COVID-related withdrawal benefits. Per the September 30, 2021 Electronic Announcement (COD-21-01), the deadline was September 30, 2022 for the 2020-21 award year. ED is continuously evaluating the reporting deadlines, as such  the current reporting deadlines were consolidated in the June 27, 2022 Electronic Announcement (GENERAL-22-36). The deadline for the 2021-22 and 2022-23 award years is September 29, 2023.

If the school learns that the student qualifies for the R2T4 waiver and withdrawal benefits after the respective deadlines, and the school accepts the student's attestation that the withdrawal was COVID-related, the school must apply the waiver and set the Coronavirus Indicator even after the deadline.

Note that the payment period start date has also been extended. The Coronavirus Indicator will be accepted when the payment period start date is a date inclusive of or between January 1, 2018 and July 1, 2023.

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 also requires the school to report "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:

• Identifying information for each student for whom R2T4 was waived under the CARES Act;
• The payment period “begin” and “end” dates for the period that the student did not complete as a result of the COVID-19 emergency;
• The amount of Title IV grant or loan assistance (other than Federal Work Study funds) that each such student received for the payment period in which he or she withdrew; and
• The total amount of Title IV grant or loan assistance that each institution has not returned to ED as a result of the R2T4 waiver.

NASFAA has confirmed with ED that the information in these first three bullets is fully satisfied using the Coronavirus Indicator on individual Title IV disbursements in COD. To meet the requirement of this last bullet--the total amount of Title IV grant or loan assistance that each institution has not returned to ED as a result of the R2T4 waiver, the school has two options. It can either:

1. Use the R2T4 Calculator Tool in COD to assign a separate Coronavirus Indicator to the qualifying payment period/period of enrollment for all students who qualify for the R2T4 waiver; or
2. Use the R2T4 Lump Sum Reporting page in COD for all students who qualify for the waiver.

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 had begun to use the R2T4 Calculator Tool in COD may switch and 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, it must include in that reporting all amounts that were previously reported using the R2T4 Calculator Tool. 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 R2T4 Lump Sum Reporting Page For CARES Act Reporting Requirements?

Per the April 28, 2021 Electronic Announcement (GENERAL-21-26), the R2T4 Lump Sum Reporting page is now available. Schools can use this page to report summary-level totals of Title IV funds that were not returned due to the CARES Act. For more details about the functionality, refer to the March 10, 2021 Electronic Announcement (COD-21-02) and its attachment. Any questions go to the COD School Relations Center at 1-800-848-0978 or [email protected].

Deadline: Whichever option the school chooses, the deadline for this reporting requirement is September 30, 2022 for the 2019-20 and 2020-21 award years. According to the June 27, 2022 Electronic Announcement, September 29, 2023 is the deadline for the 2021-22 and 2022-23 award years.

According to ED, for R2T4 Lump Sum Reporting, the school only reports the grand total amount that the school otherwise would have been required to return to ED for all students, but did not return under the R2T4 waiver (Box O on the R2T4 worksheet). Schools are not required to report amounts not returned by students as a result of the R2T4 waiver. Lump sum reporting is not done on a student-by-student basis; it is only at the institutional level.

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. The COVID-19 national emergency is now set to end on May 11, 2023.

For more detailed information, reference the following ED guidance:

• June 27, 2022 Electronic Announcement
• March 10, 2021 Electronic Announcement (COD-21-02) and attachment
• November 6, 2020 Electronic Announcement
• September 23, 2020 Electronic Announcement
• July 30, 2020 Electronic Announcement
• May 15, 2020 Electronic Announcement

See also the following AskRegs Q&As:

• How Do We Determine If a Withdrawal Was the Result Of a Qualifying Emergency Due To Coronavirus?
• Does the CARES Act Waive R2T4 Requirements When a Student Withdraws Due To COVID-19?

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

Update Notes:

• This Q&A was previously updated on October 18, 2022 to change the deadline for setting the Coronavirus Indicator for the 2021-22 and 2022-23 award years. That deadline is now September 29, 2023. The deadline for Lump Sum Reporting is also now September 29, 2023.
• This Q&A was updated on October 4, 2021 to change the deadline for setting the Coronavirus Indicator for the 2020-21 award year. That deadline is now September 30, 2022. The deadline for Lump Sum Reporting is also now September 30, 2022. The payment period start date has also been extended. The Coronavirus Indicator will be accepted when the payment period start date is a date inclusive of or between January 1, 2018 and July 1, 2022.
• This Q&A was updated on August 4, 2021 to provide further clarification NASFAA received from the U.S. Department of Education (ED) about the R2T4 Lump Sum Reporting and how the Coronavirus Indicator on individual disbursements takes care of several reporting requirements.
• This Q&A was updated on June 16, 2021 to clarify that the R2T4 Lump Sum Reporting is only for Title IV funds that the institution otherwise would have been required to return under the R2T4 waiver.
• This Q&A was updated on April 29, 2021 to announce the availability of the R2T4 Lump Sum Reporting page in COD, per the April 28, 2021 Electronic Announcement.
• This Q&A was updated on March 11, 2021, to include updated guidance published in the March 10, 2021 Electronic Announcement (COD-21-02) and attachment.
• This Q&A was updated on January 6, 2021 to provide clarification on the separate reporting requirements previously noted in AskRegs Q&A, What Is the Deadline For Setting the Coronavirus Indicator?
• This Q&A was updated on September 24, 2020 to include a reference to reporting guidance in the September 23, 2020 Electronic Announcement and its attachment.
• This Q&A was previously updated to include a reference to reporting guidance in the July 30, 2020 Electronic Announcement and its attachment.
• This Q&A was previously updated to reflect guidance in the May 15, 2020 Electronic Announcement that further defines the R2T4 reporting requirements under the CARES Act.