COD System Operational Update – Reporting Deadlines and Reminders for CARES Act Relief, Coronavirus Indicator and R2T4 (EA ID: COD-21-01)
January 22, 2021
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.
