Return to Title IV Calculations and the CARES Act


You may recall that last spring, as part of the CARES Act, Federal Student Aid (FSA) instituted exceptions to the Return to Title IV (R2T4) calculation and reporting requirements for students withdrawn from an enrollment period that included March 13, 2020 (the date the national emergency due to COVID-19 was declared) or which began between March 13 and December 31, 2020 for a reason related to Coronavirus. COVID-19 related reasons include the student’s illness or that of a family member; the student became a caregiver or first responder; loss of child care; economic hardship; lack of wi-fi to participate in distance learning and an increase in working hours. Any student that withdrew due to a switch to remote learning is automatically considered to have withdrawn for a Coronavirus-related reason. If in-person learning continued, the student had to submit the reason for withdrawing in writing (and include one of the reasons mentioned above). See FSA’s May 2020 Electronic Announcement for more details.

The CARES Act waived the need for either the institution or the student to return unearned funds due to withdrawal if the criteria above was met. In fact, institutions were directed to re-disburse aid to withdrawn students that met the criteria and the R2T4 calculation was done prior to issuance of this guidance. However, institutions need to make sure the student R2T4 record reflects the reason for withdrawal is Coronavirus to qualify for the waiver.

In January, FSA issued an electronic announcement reminding institutions that any R2T4 processed due to a COVID-19 reason during the current academic year (2020 – 2021) needs to be updated in COD Online by September 30, 2021. The deadline to do so for 2019 – 2020 was not extended; however, consideration will be given if the school did not have knowledge of the withdrawal/reason for withdrawal prior to December 31, 2020. The announcement also includes a reminder not to set the Coronavirus indicator until you confirm no further adjustments to disbursement amounts are needed.

To learn more about the R2T4 regulations read Volume 5 of the Federal Student Aid Handbook. Also, FSA has created a training video to assist with the process of updating R2T4 records already submitted –