Are We Required To Set Both Coronavirus Indicators If the Student Withdrew Past the 60% Point and Earned All Title IV Aid?

This AskRegs Knowledgebase Q&A was updated on March 15, 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.

Yes, but there is an exception. There are two Coronavirus Indicators:

• The Coronavirus Indicator that is assigned to individual disbursements in the Common Origination and Disbursement (COD) System and used to indicate which Title IV disbursements qualify for the CARES Act withdrawal benefits (e.g., Direct Loan disbursement cancellation, Pell Lifetime Eligibility Used restoration, 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 was not returned to ED under the R2T4 waiver.

According to guidance NASFAA has received from the U.S. Department of Education (ED), even if the student withdrew due to COVID-19 after the 60 percent point and earned all Title IV aid for the payment period or period of enrollment, the school must set the Coronavirus Indicator for all qualifying disbursements in COD (first bullet).

Schools are not required to use the R2T4 Calculator Tool when reporting the total amount of Title IV funds that were not returned to ED under the R2T4 waiver (second bullet). However, if the school opts to use the R2T4 Tool to meet this reporting requirement, the school must set the Coronavirus Indicator in the R2T4 Tool for students who withdrew due to COVID-19 after the 60 percent point and earned all Title IV aid.

As an alternative to the R2T4 Tool, the school can use the Lump Sum Reporting page in COD which is being released in late April 2021. If the school chooses to wait for the Lump Sum Reporting page, it does not set the Coronavirus Indicator in the R2T4 Tool (but still sets the Coronavirus Indicator on eligible disbursements in COD).

See also AskRegs Q&As, What Is the Deadline For Setting the Coronavirus Indicator?, and, Can the School Use Both the R2T4 Calculator Tool and the Alternative Reporting Method For CARES Act Reporting Requirements?