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On January 22, the Department of Education published an electronic announcement (EA) with a Common Origination and Disbursement (COD) System update on reporting deadlines and related reminders for reporting disbursement information for CARES Act relief.

While this summary provides highlights, business officers are encouraged to read the complete EA.

Coronavirus Indicator

ED has extended the timeframe for institutions to add the Coronavirus Indicator for disbursements of Title IV funds for the 2020-21 award year until September 30, 2021. While there was no change to the deadline for the indicator for the 2019-20 award year, ED acknowledges there may be instances where institutions became aware after December 31, 2020, that a withdrawal from the 2019-20 award year qualifies for CARES Act relief. In those cases, schools should add the indicator for qualifying disbursements as soon as possible.

Unclaimed Credit Balances

Under existing ED regulations, if an institution is unable to deliver a Title IV credit balance refund to a student (e.g., an uncashed check), the school must have a process to ensure that the unclaimed funds never escheat to a state or revert to the school or a third party. If the school cannot deliver the funds by the applicable deadline, the funds must be returned to ED.

Normally, those 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 institution should return the funds using the G5 Miscellaneous Refund process.

R2T4 Reporting

The deadline for reporting funds not returned under ED’s Return to Title IV requirements due to CARES Act relief, for all award years, remains at September 30, 2021. ED plans 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. ED plans to implement this function in late April 2021 with details provided in a future electronic announcement.


Bryan Dickson

Director, Student Financial Services and Educational Programs


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