Not really. Defining what a hardship distribution is and is not, writing rules regarding hardship distributions, and implementing those rules is the responsibility of each retirement plan and not the IRS. Generally speaking, “hardship distributions are subject to income taxes (unless they consist of Roth contributions). They may also be subject to a 10% additional tax on early distributions.”
So, a quick recap: retirement plans, and not the IRS, make the rules about hardship distributions from retirement accounts. Independent of a retirement plan’s hardship distribution rules, school financial aid officers will use professional judgment to determine whether or not taking a hardship distribution should change a student’s EFC.