Clarification of R2T4 Guidance Related to the COVID-19 National Emergency (EA ID: GENERAL-21-19)

Office of Postsecondary Education
Clarification of R2T4 Guidance Related to the COVID-19 National Emergency (EA ID: GENERAL-21-19)


On May 15, 2020 we published an Electronic Announcement (EA) announcing waivers of Return of Title IV Funds (R2T4) requirements for students affected by the COVID-19 national emergency. That announcement explained that an institution is required to waive returns under the R2T4 requirements for any student that it determines began attendance and subsequently withdrew as a result of COVID-19 during payment periods or periods of enrollment occurring during the national emergency (see the R2T4 Q&As from the Department’s COVID-19 Title IV Frequently Asked Questions for more information). For such students, institutions must also perform the two required reporting steps:

  • Institutions must add the Coronavirus Indicator to all disbursements in the Common Origination and Disbursement (COD) System that such students received during the payment period(s) in which they withdrew due to COVID-19; and

  • Institutions must report the amount of Title IV funds not returned as a result of Coronavirus Aid, Relief, and Economic Security Act (CARES Act) R2T4 relief in the COD System, either student by student in the COD R2T4 Tool or in a forthcoming lump sum reporting tool.

As a reminder, we explained in the May 15, 2020 EA that only where students were moved from ground-based instruction to distance learning, campus housing or other campus facilities were closed, or other interruptions in instruction occurred during a payment period within the covered timeframe, may all students who withdrew during that payment period be considered to have withdrawn as the result of circumstances related to the COVID-19 emergency. Otherwise, the institution must obtain a written attestation (including by email or text message) from the student explaining why the withdrawal was the result of the COVID-19 emergency; this includes for subsequent payment periods (payment periods following the payment period in which the disruption occurred where instruction continues in a distance format). It is important to remember that the institution is responsible for making the determination that the student’s withdrawal was in fact due to issues related to COVID-19.

The following examples illustrate when it is and is not appropriate to apply the blanket R2T4 waiver for a covered period.


Example 1

An institution offering ground-based instruction during the spring term of 2020 (January 18 to May 15) switched to a 100 percent distance education format on March 20 of that year due to the COVID-19 pandemic. During the spring semester, 30 students withdrew from their respective programs of study. The institution was able to consider all of those students (including those who withdrew at the very beginning of the term) to have withdrawn as the result of circumstances related to the COVID-19 national emergency. The Coronavirus Indicator in the COD System was set for each of the spring term disbursements for these students.

Example 2

The same institution continued offering instruction in a 100 percent distance format during the subsequent summer term. Nine students withdrew during the summer term. However, only three of those students provided written attestations explaining why their withdrawals were the result of the COVID-19 pandemic. The institution set the Coronavirus Indicator for those three students’ summer term disbursements in the COD System. For the remaining six students who withdrew for reasons not related to the Coronavirus pandemic, the institution did not set the Coronavirus Indicator and returned Title IV funds according to the R2T4 calculations performed for those students. Even though instruction continued in a distance education mode, no disruption occurred in the summer term. Accordingly, it would not have been correct for the institution to consider all nine students who withdrew to have done so as the result of a COVID-19 related circumstance.

Example 3

Another institution had been offering instruction in a 100 percent distance education format due to the pandemic but returned to ground-based instruction at the beginning of the fall 2020 term. However, during that term an outbreak of COVID-19 cases on campus caused the institution to return to 100 percent distance education. During the fall semester, 25 students withdrew from their respective programs. The institution was able to consider all 25 withdrawals to be the result of COVID-19 related circumstances and set the Coronavirus Indicator for all 25 students’ fall term disbursements. The institution was able to do this because another disruption occurred in that term.

Example 4

Prior to the pandemic, a different institution offered some programs on campus and some programs solely through distance education. The institution ceased ground-based instruction on March 27, 2020 due to the COVID-19 pandemic and moved all coursework online, but no disruption occurred to programs that were already offered online without any in-person instruction. During the spring semester, 20 students withdrew from a program that had previously been offered on campus and had been moved online due to the pandemic, and 10 withdrew from online programs where no disruption to instruction had occurred. The institution was able to consider all students who withdrew from the previously ground-based programs to have withdrawn due to COVID-19. However, it would not have been correct for the institution to consider the 10 students who had withdrawn from the online programs that had not experienced a disruption to have withdrawn due to COVID-19 without a written attestation from each student to that effect.

Coronavirus Indicator

The COD System changes to support the CARES Act, including phase-in of a Coronavirus Indicator, were first announced in a July 30, 2020 Electronic Announcement that includes an attachment providing detailed information on reporting and processing for withdrawn students. The attachment advises institutions that once the Coronavirus Indicator is set and accepted by the COD System, a school will not be able to submit any further maintenance on that disbursement record. In addition, once the Coronavirus Indicator is set, it cannot be “unchecked.” Because of this, institutions are urged to ensure that disbursement amounts in COD are correct and that students qualify for a waiver of R2T4 requirements (as discussed above) before checking the Coronavirus indicator. We appreciate the diligence shown by institutions in timely reporting for students who withdrew as a result of the pandemic. While it is important that the CARES Act waivers for R2T4 are reflected for these students as soon as possible, it is equally important that COD records on which the Coronavirus Indicator is checked are accurate.

Additionally, in response to questions from institutions, the Department recently provided operational guidance in a January 22, 2021 Electronic Announcement that describes the steps an institution is to take when it is unable to deliver the proceeds of a credit balance to a student that is associated with disbursements marked with the Coronavirus Indicator in the COD System. In these situations, the institution is directed to use the G5 Miscellaneous Refund process to return the unclaimed credit balance to the Department rather than reducing the amount of the associated disbursement(s) in the COD System under normal requirements.

As a reminder, institutions are required to use the Coronavirus Indicator for all students who begin attendance and are determined by the institution to have withdrawn due to COVID-19 during the period of the national emergency, including those who would otherwise have earned 100 percent of their Title IV funds under normal R2T4 requirements.

Reporting Amounts Not Returned

As described in the May 15, 2020 EA, schools are required to report to the Department the total amount of Title IV grant or loan assistance that each institution has not returned to the Secretary as a result of the CARES Act provisions.

In April 2021, Federal Student Aid plans to add functionality to the COD System that will allow institutions to report summary-level totals of Title IV funds that were not returned under R2T4 requirements due to CARES Act R2T4 relief. Schools are only required to use this summary-level reporting tool if they have not used the COD R2T4 calculator to flag records with the “R2T4 Coronavirus Indicator” for all students who withdrew due to COVID-19.

Schools using the lump sum reporting tool will be required to report an amount not returned for each Title IV program in which the institution participates by award year. In calculating the total amount not returned for a given Title IV program during an award year, the institution should identify the total amount of funds that would have been returned by the institution under Step 6 of the R2T4 calculations for all students who qualified for CARES Act R2T4 relief that year. The institution should not include in that total any funds for which students were responsible for returning or repaying under Step 8 or Step 10 of the calculation, nor any funds associated with post-withdrawal disbursements that the calculation would have directed the institution to make.

Contact Information

Please submit any policy questions related to this announcement to Technical questions related to the use of the COD System should be submitted to the COD School Relations Center at