Federal Student Aid
COD System Operational Update – Reporting Deadlines and Reminders for CARES Act Relief, Coronavirus Indicator and R2T4 (EA ID: COD-21-01)

This announcement provides a Common Origination and Disbursement (COD) System update about reporting deadlines and related reminders for reporting disbursement information qualifying for CARES Act relief.

Coronavirus Indicator

We are extending the timeframe for schools to add the Coronavirus Indicator for disbursements of Title IV funds for the 2020–21 Award Year until Sept. 30, 2021. In previous guidance, including a Sept. 23, 2020 Electronic Announcement, we stated that schools should add the Coronavirus Indicator to disbursements qualifying for CARES Act relief no later than Dec. 31, 2020. Because of the ongoing impacts postsecondary institutions and their students face resulting from the coronavirus disease (COVID-19) pandemic, it is necessary to extend the timeframe for schools to add the Coronavirus Indicator for disbursements for the 2020–21 Award Year until Sept. 30, 2021.

There was no change to the deadline to add the Coronavirus Indicator for disbursements from the 2019–20 Award Year; however, in limited circumstances, schools may become aware after Dec. 31, 2020 that a withdrawal from the 2019–20 Award Year 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.

As a reminder, 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.

Unclaimed Credit Balances Resulting from Disbursements with the Coronavirus Indicator

When Title IV funds disbursed to a student’s account result in a Title IV credit balance, there may be occasions when the school is unable to deliver the appropriate amount of the credit balance refund (e.g., when the student fails to cash or deposit a check or if an electronic funds transfer is unsuccessful). In these cases, if the school is unable to deliver the proceeds of the credit balance to the student, the school must have a process that ensures that the unclaimed funds never escheat to a State or revert to the school or any other third party. If the school is unable to deliver the funds by the applicable deadlines (see Volume 4, Chapter 2 of the FSA Handbook), the funds must be returned to the Department.

Normally, any such returns would be offset by a downward adjustment in the student’s Pell Grant, Direct Loan, and/or TEACH Grant record in the COD System. However, once a school has assigned the Coronavirus Indicator to a Pell Grant, Direct Loan, or TEACH Grant disbursement, the school is unable to modify the disbursement amount. In these situations, a downward adjustment to the student’s COD records is not required, and the school is instead directed to return the funds using the G5 Miscellaneous Refund process:

  • Select Payments; then Create Refunds; then Create Miscellaneous Refunds.
  • Once the Miscellaneous Refunds window is displayed, enter the amount to be refunded.
  • Select the Bank Account to be used to process the refund.
  • Because there is not a selection for the Coronavirus, the user would select “GAPS Excessive Cash” as the “Refund Type” for the refund.
  • Select enter to complete the processing of the refund.

Changes to the Payment Period Start Date for the Coronavirus Indicator

In our previous guidance, we provided the valid date range for a disbursement’s payment period start date that must be used when selecting the Coronavirus Indicator. The valid date range has been expanded over the past several months, but currently, the Coronavirus Indicator will be accepted when the payment period start date is a date inclusive of or between Jan. 1, 2018 and June 30, 2021.

Note: While the payment period start date window has been expanded, all other requirements related to the Coronavirus Indicator still must be met.

Return of Title IV (R2T4) Reporting

The deadline for reporting funds not returned under R2T4 requirements due to CARES Act relief, for all award years, remains the same: Sept. 30, 2021. As a reminder, we plan to update the COD website to provide an additional option for schools to report lump sum amounts of Title IV aid that would have been returned under normal circumstances. Reporting will be by program type and associated schools will report though the OPEID of the main school. Currently, we plan to implement this functionality in late April 2021; more information will be provided in forthcoming electronic announcements later this spring.

Contact Information

If you have additional questions about setting the Coronavirus Indicator, contact the COD School Relations Center at 1-800-848-0978. You may also email CODSupport@ed.gov.