This AskRegs Knowledgebase Q&A was updated on December 21, 2020 to note that the December 16, 2020 COD Processing Update announced that the U.S. Department of Education (ED) has extended the timeframe for schools to add the Coronavirus Indicator for Title IV disbursements for the 2020-21 award year that qualify for COVID-19 related withdrawal relief under the CARES Act until September 30, 2021. There has been no change in the deadline to add the Coronavirus Indicator for disbursements from the 2019-20 award year; that deadline remains December 31, 2020.
There are two Coronavirus Indicators:
Coronavirus Indicator for Disbursements: According to the COD Processing Update dated December 16, 2020, ED has extended the deadline for schools to set the Coronavirus Indicator for 2020-21 award year disbursements that qualify for COVID-19 related withdrawal relief under the CARES Act until September 30, 2021. As previously announced in the September 23, Electronic Announcement and its attachment, schools continue to have until December 31, 2020 to set the Coronavirus Indicator for 2019-20 disbursements that qualify for COVID-19 related withdrawal relief under the CARES Act. 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."
If a student withdrew for reasons related to COVID-19 for a payment period or period of enrollment within the covered period, the school sets the Coronavirus Indicator for Title IV disbursements that were made during that payment period/period of enrollment. See AskRegs Q&A, How Do We Determine If a Withdrawal Was the Result Of a Qualifying Emergency Due To Coronavirus?, for more information including what is the covered period.
Coronavirus Indicator for the R2T4 Calculator Tool: 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)."
To meet this reporting requirement, the school has options. It can use the R2T4 Tool in COD, or it can wait until ED develops and releases an alternative method in early 2021 (no further details have been released by ED). Whichever option the school chooses, the deadline for this reporting requirement is not until September 30, 2021.
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