Posted Date: November 21, 2014
Sue O'Flaherty, Service Director, Program Management, Federal Student Aid
Subject: 150% Direct Subsidized Loan Limit: Electronic Announcement #16 - Important Reminders About COD Reporting Responsibilities for 150% Calculations
This Electronic Announcement reminds schools participating in the Direct Loan Program of the importance of accurate and timely reporting of a student’s Direct Loan (Direct Subsidized Loan, Direct Unsubsidized Loan, and Direct PLUS Loan) information to the Common Origination and Disbursement (COD) System to ensure that the Subsidized Usage Period can be calculated correctly. It is equally important that schools update previously-reported loan information, including closed Direct Loan program years, as needed. Specifically, when a student’s situation changes, in addition to changing disbursement dates or reducing amounts, schools must also change key award information like award amounts, loan period dates, and academic year dates.
The following are some of the reasons that will likely require a school to update a student’s award and disbursement information:
The student requests that a loan, or a disbursement of a loan, be cancelled;
The student does not begin attendance, or does not begin attendance on at least a half-time basis, in a term/payment period that was included in the originally-reported loan period;
The school determines that the student is not eligible to receive all or a portion of a Direct Loan for a term/payment period that was part of the originally-reported loan period;
Summer is not a term in which students are generally expected to attend classes, and the student attends the summer term and requests a loan for the summer term; or
The student is enrolled in a non-term, clock hour, or non-standard term program that has terms that are not substantially equal to each other in length and are not at least nine weeks in length, and the student has failed to progress from one payment period to another as originally scheduled.
Below we summarize the actions needed to update a student’s award or disbursement information.
The following actions must be taken when inactivating (i.e., cancelling) a loan:
Reduce all actual disbursements to $0
Reduce the award amount to $0
Note: When the award amount is reduced to $0, the COD System will automatically reduce any remaining anticipated disbursements to $0.
If completely inactivating a loan, the loan period and academic year begin and end dates do not need to be modified.
The following actions must be taken when inactivating a disbursement (anticipated or actual):
Reduce the anticipated and/or actual disbursement amount(s)
Reduce the award amount to equal the sum of all remaining anticipated and/or actual disbursements
Update the loan period begin or end date
Update the payment period start date to be within the revised loan period
Note: A school can determine which anticipated disbursements have not been reduced to $0 or have not been updated to an actual disbursement by reviewing 1) the award and disbursement detail pages on the COD Web site or 2) the COD Action Queue. The COD Action Queue link can be found by clicking on the “Batch” tab in the top blue navigation bar on the COD Web site.
Note: In some cases, until spring 2015, schools may need to follow the workaround provided in an August 22, 2014 electronic announcement to avoid triggering COD Reject Edit 205 (Payment Period Start Date is outside the Award Begin and End dates).
In the attachment, we provide examples showing the impacts to Subsidized Usage Period and Remaining Subsidized Eligibility Period calculations when schools do not properly update all of a loan's previously-reported information.
If you have 150%-related questions or questions about determining the correct loan period and academic year dates, submit them to 150Percent-Questions@ed.gov and include the name of your school in the subject line.
If you have questions about how to make changes to award or disbursement information on the COD System, contact the COD School Relations Center at 800/848-0978 for Direct Loans. You may also e-mail CODSupport@ed.gov.