Due to the uncertainty of the pandemic, the Department of Education (DOE) has continually provided updates to its guidance for interruptions of study related to the Coronavirus. Since there have been frequent updates during these difficult times, some can be easily overlooked. One such update that has seemed to have slipped through the cracks with many schools is the addition of the Coronavirus Indicator to the Common Origination and Disbursement (COD) system.
The Coronavirus Indicator is a checkbox that was added to the Disbursement Information page in the COD system that is used to update disbursement records for aid recipients who have withdrawn due to COVID-19-related matters. This box should be checked when a student’s actual disbursement qualifies for Direct Loan cancellation and exclusion from the Direct Loan annual limits, Subsidized Loan usage (SULA) calculations and the Pell Grant Lifetime Eligibility Used (LEU) calculations.
Per the DOE’s Electronic Announcement on November 6, 2020, a school should select the Coronavirus Indicator when:
The Coronavirus Indicator should be used for eligible Direct Loan disbursements and grant awards from the 2017–2018 award year and forward. Note: Set the Coronavirus Indicator after confirming there are no further changes to a disbursement. Once the Indicator is set, it cannot be unchecked and, therefore, no additional changes can be submitted on that disbursement.
According to the DOE’s September 27, 2020 COD System Reporting update, once a disbursement is flagged with the Coronavirus Indicator, the following actions will be triggered:
If the Coronavirus Indicator needs to be marked for a disbursement in which the award year has passed the data submission deadline, the school can request to reopen the award year in COD to enter changes. If a disbursement is not flagged, it will be processed in COD under existing business rules. The DOE states that the Coronavirus Indicator is not a required data element and can be blank if not applicable.
As stated in the DOE’s September 27, 2020 COD System Reporting update, the deadline to add the Coronavirus Indicator to disbursement is no later than December 31, 2020. Disbursements not submitted by the deadline may be calculated incorrectly for students who are entering or re-entering repayment at that time. Furthermore, it could result in students not receiving the full amount of Title IV aid for which they are eligible. Note: Schools should coordinate with their third-party servicers to confirm who is responsible for checking the Coronavirus Indicator.
For best practices when using the Coronavirus Indicator and other COD system changes to support the CARES Act, please visit the following link or contact a Sikich Title IV expert: COD System Implementation Information for Additional COD System Changes to Support the CARES Act – Supplemental Phase
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