Common Origination

and

Disbursement System

Update for Award Year 2014-2015

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Wood Mason

U.S. Department of Education

Federal Student Aid

Atlanta, GA

770.383.9662

wood.mason@ed.gov

AGENDA

• New Award Year Setup (NAYS)

• Phase 2 of the Direct Subsidized Loan 150% Limitation

New schema 4.0a

100% schema validation

150% Phase 2 SULA tags and data

Enforcement of the 150% threshold

• Sequestration enhancements

• Pell Grant Dispute Portal

• Program Year Closeout

• Still to come…

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New Award Year Setup

(NAYS)

The NAYS will include the normal “changes” from one award year to the next…AGENDA

• Funding method will remain Advance Funded

• System generated files are returned with the message class award year designator “15”

Common record response files returned in the schema of submission

• Award year designator changed to “15” elsewhere as appropriate

Master Promissory Note (MPN) ID

Direct Loan Award ID

Agreement to Serve ID

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The funding method remains Advance Funded

• Pell Grant and TEACH Grant programs remain “records

first” and no initial authorization will be generated

Accepted actual disbursement data will establish a Current

Funding Level (CFL) for the school in COD and an available

balance in G5

Increases to the CFL are accomplished ONLY by reporting

actual disbursement data to, and being accepted by, COD

Can report actual disbursement data up to 7 days prior to the

actual disbursement date

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Advance Funded Direct Loan schools with a history of

“early” disbursement activity received an initial CFL

shortly after COD Release 13.0 implementation

• Second assignment of CFLs will be generated in June for

remaining Advance Funded schools

• Third assignment of CFLs will be generated in November

• Increases to your CFL can be generated by reporting actual

disbursement data to, and being accepted by, COD

• Internal Controls Division (ICD) staff will monitor CFLs and

“bump” a CFL if necessary

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For award years 2014-2015, as in years past, Direct

Loan schools operating under Heightened Cash

Monitoring Level 1 (HCM 1) will not receive an initial

CFL

• Submission of actual disbursement data to, and accepted

by, COD will establish a CFL in the COD system and a

corresponding available balance in G5

• Must submit, and COD must accept, actual disbursement

data for a “bump” in your CFL and a corresponding

“bump” in your G5 available balance

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A couple of your processing options should be double

checked…

• Report formats from award year 2013-2014 have been

carried over to award year 2014-2015

• Valid dates of participation in the PLUS Request process

via the StudentLoans.gov website have been incremented

one (1) year

• It’s a good idea to double check ALL of your processing

options with each NAYS

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Phase 2 of the 150% Direct

Subsidized Loan Limit

Phase 2 of the 150% Direct Subsidized Loan Limitation

(SULA) brought…

• 150% SULA tags and data

• New edits

• Real-Time processing

New system generated response

• New Schema 4.0a

Full XML Common Record Schema validation

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150% limit is met and further

eligibility is lost when Remaining

Eligibility Period is zero (or less)

Maximum Eligibility Period (MEP) of the published

length of your borrower’s current, or upcoming,

academic program

• Varies by program

• Multiply published program length by 1.5

• Measured in academic years or portions of academic

years

• If your published program length is reported in months or

weeks COD will convert it to years or portions thereof

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A Subsidized Usage Period (SUP) is the period of time for which a borrower receives a Direct Subsidized Loan

• Calculated on a loan-by-loan basis

• Measured in academic years or portions thereof

• Rounded up or down to the nearest tenth of a year

• Included ONLY periods when a Direct Subsidized Loan is received

• COD will calculate using school-reported data

• There are two exceptions…

Enrollment Status

Single-term, full annual loan limit

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# days in the loan period

# days in the academic year Subsidized Usage Period

Accurate reporting of academic year and award start/end dates is vital to the accurate calculation of a SUP

• Award Year 2013-2014 and forward

All loans and all borrowers

• Schools MUST change the anticipated dates if they differ from actual attendance

• Loan periods should include ONLY those terms/payment periods in which the borrower receives funds

• Dear Colleague Letter (DCL) GEN 13-13 posted May 10, 2013, has the particulars

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Example… • Scheduled academic year

Fall/Spring…September 10, 2014-May 10, 2015 and a corresponding loan period

242 days in the loan period and 242 days in the academic year

= 1.0 YEARS

• But what is the borrower doesn’t return for the Spring Term?

The school updates the loan period to Fall only

Does NOT adjust the academic year

91 days for the Fall Term

Still 242 days in the academic year

The SUP is now 0.4 YEARS!

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Exception #1

Calculated

subsidized usage

period is prorated by

enrollment status

Proration occurs

before rounding

Full-time = 1.00

¾-time = 0.75

½-time = 0.50

Prorate Subsidized Usage Period based on enrollment status

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Exception #2…Only circumstance where dollars are considered is when a student receives a Direct Subsidized Loan in the amount of the annual loan limit

Exception #2 can only occur for standard-term programs or for

non-standard-term programs that are substantially equal and are each at least nine weeks in length

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When both Exception #1 and Exception #2 apply

Result is always the same as the proration factor used in the enrollment status exception - 0.5 or 0.75

New data tags for Award Year 2014-2015

• Award Block

<PublishedPgmtLentghYears>

<PublishedPgmtLengthMonths>

<Published PgmtLengthWeeks>

<WeeksProgramAcademicYear>

<SpecialPrograms>

<ProgramCredentialLevel>

• Disbursement Block

<PaymentPeriodStartDate>

<ProgramCIPCode>

<EnrollmentStatus>

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Reporting your Published Program Length in weeks or

months …

• COD will convert weeks and months to years or portions

• You can report ONLY one Published Program Length tag

in the award block of your Common Record

# days in the Program

# days in the Title IV Academic Year Program Length

Month = 30 days

Week = 7 days

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Reporting your CIP Code and Academic Year…

• “Classification of Instructional Program” (CIP) Code

Provides a taxonomic scheme, or classification into

ordered categories, that supports the accurate tracking

and reporting of fields of study

http://nces.ed.gov/ipeds/cip2010

• Your Academic Year is school-defined

Minimum of 30-weeks of instruction and 24 semester (36

quarter) credit hours for a credit-hour based program

No hour minimum for a graduate level program

Minimum of 26 weeks and 900 clock-hours of instruction

for a program measured in clock-hours

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Value Description

A Selective Admission Associate Program

B Bachelor’s Degree Completion Program

N Not applicable

P Preparatory Coursework Graduate Professional Program

T Non-Credential Teacher Certification Program

U Preparatory Coursework Undergraduate Program

The new <SpecialPrograms> tag will identify borrowers in those programs

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Special Programs Tag Value Valid Grade Levels

Sel Adm Assoc Prgm A TBD

Bach Deg Completion Prgm B TBD

Not Applicable N No G/L Validation

Tag Not Submitted N/A No GL Validation

Prep Graduate Prgm P 5

Non Cred Tchr Cert T 5

Prep Undergraduate U 1 & 0

COD will validate the <SpecialPrograms> tag against

Grade Level on an incoming Loan Origination Record

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Description Program Credential

Level Student Level Code

Undergraduate certificate or diploma 01 0-5 (Undergraduate)

Associate’s degree 02 0-5 (Undergraduate)

Bachelor’s degree 03 0-5 (Undergraduate)

Post Baccalaureate certificate 04 0-5 (Undergraduate)

Master’s degree 05 0-7 (Graduate)

Doctoral degree 06 0-7 (Graduate)

First Professional degree 07 07 (Graduate)

Graduate/Professional certificate 08 0-7 (Graduate)

Non-credential programs (preparatory coursework/teacher certification)

99 0-5 (Undergraduate)

The <ProgramCredentialLevel> tag will be validated

against Grade Level as well…

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Edit Program Trigger

Reject 202 DL Cannot submit more than one tag for Published Program

Length (Years, Months or Weeks)

Reject 203 DL Incorrect Special Program submitted

Reject 206 DL Sub Remaining Subsidized Eligibility Period is less than zero for

this award

Warning 207 DL Sub Maintenance to this tag may have caused the Remaining

Subsidized Eligibility Period to drop below zero for this award

Reject 208 DL Incorrect Student Level Code submitted

Reject 209 DL Invalid value submitted for Weeks Programs Academic Year

New award level edits

Note: “Maintenance Record” and “Change Record” are synonymous

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Edit Program Trigger

Reject 204 DL & TEACH Incorrect Program CIP Code submitted

Reject 205 DL Payment Period Start Date is outside the Award Begin and End

dates

Reject 207 DL Sub For HCM/Reimbursement schools, sequence issues

Existing Edit 994 and Edit 996 will be

triggered if a value is missing or not valid

New disbursement edits

Phase 2 will also bring “real-time” processing to COD

• Subsidized Usage Period calculations

SUP will be returned per award via the Common Record

Response

• Normal and routine program and COD editing

The Subsidized Usage Limit Applies (SULA) tag will be

returned at the Person level for award year 2014-2015

Warning Edit #200 will continue to be returned on award

year 2013-2014 awards

The COD website will continue to display the SULA date on

the View Person Information screen

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Phase 2 will also bring a new SULA notification via a

new system generated response

• Generated each night after daily SULA processing is

complete

• Sent to schools reflecting a student’s changed SULA data

and the change was NOT initiated by the receiving school

Schools cannot opt out

COD sent a “blast” to all attendant schools after the

implementation of Cod Release 13.0

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Schema 4.0a

For award year 2014-2015 and forward COD will

perform 100% (Full) XML Common Record Schema

validation

• Based on the published Common Record XML schema

COD will enforce 100% full schema validation on schemas

3.0d, 3.0e, and 4.0a

COD will retire schemas 2.0e, 3.0a, 3.0b, and 3.0c

An electronic announcement (EA) dated October 29, 2013,

provides schema 4.0a details

• Examples of errors has been provided to software vendors

and “IT” shops

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A new “temporary” Warning Edit #211 will be triggered

and returned to indicate a schema validation issue

• On inbound XML Common Records that do not meet 100%

schema validation but would have been accepted under

prior year rules

Tags out of order

Blank tag that cannot be blank

Will be discontinued at a yet-to-be-determined later date

• Warning Edit #211 will be discontinued at a yet-to-be-

determined date

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A new Reject Edit #210 will be triggered and returned

for malformed XML documents

• Failed 100% schema validation

Missing value

Invalid value

• The edit is returned at the <DocumentID> tag

Batch level reject

• COD School Relations Center will communicate with the

school via an e-mail when malformed XML is submitted

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Phase 2 COD Website

Enhancements

Phase 2 of the 150% Direct Loan Limit modifications to

COD will include enhancements to the COD website

• A new SULA report

• The COD website will be updated to include, and display,

all of the new SULA data

• New SULA Request and SULA Information screens will be

implemented on the COD website

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The currently produced Direct Subsidized Loan Usage

Limit School Report will be discontinued

• A new Direct Loan Subsidized Usage Change report will be

created and implemented

Posted weekly in your school NewsBox

CSV format

Option to receive the report of not

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The currently produced Direct Subsidized Loan Usage

Limit School Report will be discontinued

• A new Direct Loan Subsidized Usage Change report will be

created and implemented

• The new report will display subsidized loans when a

change to a calculated SULA value occurs

• The new report will be posted in your school NewsBox

Weekly

CSV format

Option to receive the report of not

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COD will update screens to display SULA data

• View Person Information screen

Redesigned

Pop-up on Personal History events give additional

information

• Disbursement History Information screen will display

additional SULA data

Enrollment Status

Program CIP Code

Payment Period Start Date

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COD will implement and display two (2) new website

screens

• Subsidized Usage Information Screen

Accessible via a hyperlink on the Person Direct Loan

Information screen

• Subsidized Usage Request

Allows a user to request the most recent SULA data via the

new system generated response

Accessed via the Batch tab

Search by SSN or Entity ID

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StudentLoans.gov

StudentLoans.gov modified the Direct PLUS Loan endorsement process

• To endorse a credit-denied Direct PLUS Loan…

The endorser will need to provide the new Direct PLUS Loan Endorser Code and the borrower’s last name

OR

The Direct Loan ID AND the Direct PLUS Loan Request borrower’s last name

• Borrowers receive a PLUS Endorser Code and unique URL via their confirmation e-mail to provide to their endorser

If a borrower does NOT have an e-mail address on the system the Endorser Code can be obtained from his or her completed Direct PLUS Loan Request on the StudentLoans.gov website

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Just a heads-up…StudentLoans.gov will require

existing users to reconfirm their e-correspondence

preferences when they first log on after the COD

Release 13.0 implementation

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Pell Grant Modifications

The Expected Family Contribution (EFC) field length on

all COD website screens, and on the Pell Grand

documents noted below, will be expanded from 5 to 6

bytes to conform to a CPS change

• The Pell Grant Reconciliation Report

• The Pell Grant Multiple Reporting Record (MRR)

• The Pell Grant Year-To-Date File

• The Pell Grant Lifetime Eligibility Used (LEU) Report

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COD 13.0 Release will further streamline the Pell

Grant LEU dispute process with a new Pell Grant LEU

Dispute portal on the COD Web

• The Portal provides the ability to create, view, update,

and even upload documentation for a Pell LEU dispute

• Pell LEU History page will display the Pell LEU dispute

status

• Schools will no longer have an option to escalate a Pell

Grant LEU dispute via the COD School Relations Center

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The Pell LEU

Dispute portal

allows schools to

enter dispute

information for

Department of

Education review

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The new Create Pell

LEU Dispute page

will collect

information about

the current and

former schools,

reason for the

dispute,

documentation,

comments, and

much more

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On the Create Pell

LEU Dispute page,

the user must

upload the

required dispute

documentation

directly to the COD

Web

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After a dispute

has been

approved, the

student’s Pell LEU

History page will

provide details of

the dispute and

adjustment

COD Release 13.1

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COD Release 13.1 is scheduled for early Summer, 2014

• The plan is to…

Update Master Promissory Notes (MPNs)

Expiration date and SULA text

Add a bit more SULA information to the StudentLoans.gov website

Implement a central communication “portal” on the COD website for uploading school specific documents to eliminate the transmission of customized e-mail attachments to schools

Update the TEACH Grant guide to include the SULA information

Sequester Changes FY 2015

Sequester required changes for TEACH Grant and Iraq-

Afghanistan Service Grant from the award amount for

which the student would otherwise have been eligible…

• First disbursement takes place on or after October 1,

2014 and before October 1, 2015

A TEACH Grant requires a reduction of 7.3%

An Iraq-Afghanistan Service Grant requires a reduction of

7.3%

Maximum Federal Pell Grant award amount for the relevant

award year

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Direct Loan origination fees will increase for loans with an Earliest Disbursement Date (EDD) on or after October 1, 2014 and before October 1, 2015

• Direct Subsidized and Unsubsidized Loan origination fees will rise from 1.072% to 1.073%

• Direct PLUS Loans for parent and graduate/professional students will rise from 4.288% to 4.292%

• COD has been modified to validate the EDD against the loan origination fee on incoming loan origination records (LORs)

Loans with an EDD on or after October 1, 2014 and before October 1, 2015 with an origination fee other than 1.073% are rejected

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If you have already originated a Direct Loan with an

incorrect origination fee you need to correct it now…

• Much easier to do with anticipated disbursement data

than with actual disbursement data

• Dear Colleague Letter DCL GEN 14-10 posted May 2,

2014 has the particulars

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Reminders…

In late January, 2014, FSA posted to the COD website

“report readers”

• An Excel spreadsheet utility that provides a simplified way

to import and view…

Pell Grant Year-To-Date File

Pell Grant Reconciliation file

Direct Loan Disbursement Detail on Demand Report

• Reconciliation aid

Request the files in a “fixed-length format”

• No need to login – access via the “Today’s Update” link

• EA posted January 28, 2014 has the particulars

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EdExpress Software Release v3.0 that will transmit 150% subsidized loan limit data to COD will not be available until June 23, 2014

• EdExpress v. 2.0 will be released April 14, 2014 and will have full functionality, but you should NOT originate Direct Loan awards in v. 2.0

• If you MUST originate and disburse prior to the release of EdExpress v. 3.0 you can do so via the COD website

Enter borrowers and awards individually or via the Direct Loan Origination Tool, a utility embedded in the COD website

Direct Loan Tools will be released in late June and will allow you to build a resident EdExpress database with a “Direct Loan Rebuild File”

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The Program Year Closeout deadline for 2012-2013 is Thursday, July 31, 2014

• You’ll receive “Remaining Balance” and “Zero Balance” communications via e-mail beginning 30-days after your last disbursement date for that program year

• After your last SAS reflecting an Ending Cash Balance (ECB) of $0, you’ll shortly thereafter receive your “Zero Balance” communication at which time the Balance Confirmation screen will become active on the COD website

Electronic closeout

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Beginning January 1, 2015, you will no longer be able to return or refund Direct Loan funds via paper check

• You should begin to update your processes to enable you to refund cash electronically via the G5 website

Prior to January 1, 2015, the COD School Relations Center will process paper checks for Direct Loan refunds of cash

Beginning January 1, 2015, the COD School Relations Center will not process paper checks for Direct Loan refunds of cash and will return them to the sender

This change will NOT impact the funding information screens on the COD Web site or the G5 Web site

Note: If a school is required to refund cash as part of a liability assessed in an audit or program review, it must follow the instructions provided by the issuing office

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