AUTHOR: Federal Student Aid
SUBJECT: COD System Operational Update 2022 – Reporting Deadlines and Reminders for CARES Act Relief, Coronavirus Indicator and R2T4
Because of the ongoing impacts postsecondary institutions and their students face resulting from the coronavirus disease (COVID-19) pandemic, we are continuously evaluating the reporting deadlines for schools to add the Coronavirus Indicator for disbursements and reporting funds not returned under Return of Title IV (R2T4) requirements due to CARES Act relief. While guidance has been provided in several different announcements, we have consolidated the current reporting deadlines in this announcement.

Summary of Deadlines for Coronavirus Indicator and Return of Title IV (R2T4) Reporting

The reporting deadlines for schools to add the Coronavirus Indicator for disbursements of Title IV funds and for reporting funds not returned under R2T4 requirements due to CARES Act relief are provided in the table below. The deadlines vary across award years, and the deadline for the Coronavirus Indictor is not always the same as it is for R2T4, so be sure to review the table carefully.


Award Year


Coronavirus Indicator






Dec. 31, 2020


Sept. 30, 2022




Sept. 30, 2022


Sept. 30, 2022




Sept. 29, 2023


Sept. 29, 2023




Sept. 29, 2023


Sept. 29, 2023


Note: In some cases, a school may become aware after the appropriate deadline for an award year that a withdrawal that occurred prior to the deadline was related to COVID-19 and 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.


Changes to the Payment Period Start Date for the Coronavirus Indicator

As with 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 in the Common Origination and Disbursement (COD) System, and the Coronavirus Indicator will be accepted when the payment period start date is a date inclusive of or between Jan. 1, 2018, and July 1, 2023.

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


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