What Is the Deadline For Setting the Coronavirus Indicator?

This AskRegs Knowledgebase Q&A was updated on July 5, 2022 to change add the award year deadlines from the June 27, 2022 Electronic Announcement (GENERAL-22-36).

There are two Coronavirus Indicators:

• The Coronavirus Indicator that is assigned to individual disbursements in the Common Origination and Disbursement (COD) System, which is used to indicate which Title IV disbursements qualify for the CARES Act withdrawal benefits (e.g., Direct Loan disbursement cancellation, etc.); and
• The Coronavirus Indicator that is assigned to the return of Title IV funds (R2T4) Calculator Tool in COD, which is an option for the school to use when reporting the total amount of Title IV funds that were not returned to ED under the R2T4 waiver.

Coronavirus Indicator for Disbursements: If a student withdrew for reasons related to COVID-19 for a payment period or period of enrollment within the covered period, the school is required to set 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 two options. It can use the Coronavirus Indicator in the R2T4 Tool in COD, or it can use the R2T4 Lump Sum Reporting page in COD. See the AskRegs Q&A: Can the School Use Both the R2T4 Calculator Tool and the Alternative Reporting Method For CARES Act Reporting Requirements?

Reporting Deadlines: Per the June 27, 2022 Electronic Announcement, the respective deadlines for setting both Coronavirus Indicators and the R2T4 waiver reporting are as follows:

Note: In some cases, a school may become aware after the appropriate deadline for an award year that a withdrawal that occurred prior to the deadline was related to COVID-19 and qualifies for CARES Act relief. In these circumstances, the school is directed to add the Coronavirus Indicator for qualifying disbursements for such students as soon as possible.

Update Notes:

• This Q&A was updated on October 4, 2021 to change the deadline for setting the Coronavirus Indicator for the 2020-21 award year to September 30, 2022 for R2T4 reporting (R2T4 Tool and lump sum reporting).
• This Q&A was updated on March 12, 2021, to include updated guidance published in the March 10, 2021 Electronic Announcement: COD System Implementation for 2021-22 Award Year (EA ID: COD-21-02) and attachment, COD System Processing Function Modifications for 2021-22.
• This Q&A was updated on December 21, 2020 to note that the December 16, 2020 COD Processing Update announced that ED extended the timeframe for schools to add the Coronavirus Indicator for Title IV disbursements for the 2020-21 award year 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.
• This Q&A was updated on December 16, 2020 to note that the December 11, 2020 Federal Register did not change the December 31, 2020 deadline for setting the Coronavirus Indicator on qualifying disbursements in COD.
• This Q&A was updated on November 25, 2020 to clarify that there are two Coronavirus Indicators--one has a December 31, 2020 deadline; the other does not.
• This Q&A was updated on September 24, 2020 to indicate that ED set a December 31, 2020 deadline for adding the Coronavirus Indicator to eligible disbursements in COD.
• See also AskRegs Q&A, What Are the R2T4 Reporting Requirements Under the CARES Act?