Posted Date: August 21, 2019

Author:  Federal Student Aid

Subject: Information about Subsidized Usage Limit Applies (SULA) Calculation Updates Made in the COD System July 26-28, 2019

During the period July 26-28, 2019, we implemented additional Common Origination and Disbursement (COD) System functionality that supports the Campus-Based programs and the processing of Federal Pell Grant (Pell Grant), Iraq and Afghanistan Service Grant, Teacher Education Assistance for College and Higher Education (TEACH) Grant, and William D. Ford Federal Direct Loan (Direct Loan) awards for the 2019–20 Award Year. Information about this implementation was posted in an attachment to a July 19, 2019 Electronic Announcement.

In the posted attachment, we noted that the implementation included changes to the SULA calculations. In this announcement, we provide additional information about this change.

With the implementation, we made changes to how the COD System uses information from the National Student Loan Data System (NSLDS®) for the SULA calculations; these changes improve the accuracy of the calculations.  Although the revised calculations resulted in little to no change in subsidized eligibility for the majority of borrowers, we wanted to make schools aware should they notice slight increases in the number of system-generated Subsidized Usage (CRSU) responses.

  • If the updated usage resulted in increased subsidized eligibility, schools are encouraged to reallocate all or a portion of a borrower’s Direct Unsubsidized Loan to a Direct Subsidized Loan as appropriate.

  • If the updated usage resulted in decreased subsidized eligibility and the borrower is now over his or her maximum eligibility, schools should follow their existing process of obtaining a borrower’s consent before reallocating funds from a Direct Subsidized Loan to a Direct Unsubsidized Loan.

Schools can review borrower eligibility using the information in the CRSU responses from the COD System. Schools can also download their Subsidized Usage Change Reports to help identify students who may have changes in subsidized eligibility.

Additionally, schools may see increased activity as explained below.

  • NSLDS Postscreening and Updated Institutional Student Information Records (ISIRs) – As part of day-to-day processing, when Subsidized Usage information changes on Direct Subsidized Loan awards, the updated information is passed from the COD System to NSLDS. NSLDS performs postscreening on the updated information and if a change in the student’s eligibility results, an updated ISIR is generated and sent to the school. Schools may receive an increased number of updated ISIRs resulting from the additional NSLDS postscreening. Schools can identify the updated ISIRs by reviewing the records for the following identifiers and data element values:

    • The ISIRs are sent under the IGSG19OP and IGSG20OP message classes.

    • The Transaction Data Source/Type Code equals 5N (NSLDS Postscreening).

    • The ISIRs may include certain NSLDS postscreening codes:

    • Reason Code 25 (change to SULA Flag status): The SULA Flag displays a value of “Y” when SULA applies and “N” when SULA does not apply. If the value of the flag changes, Reason Code 25 will display. When the SULA Flag is set to “Y,” the ISIRs include SAR comment code 267.

    • Reason Code 27 (decrease in subsidized usage period): The NSLDS Postscreening Reason Code field displays “Decrease in the Subsidized Usage Period” on the FAA Info page in Student Inquiry on the FAA Access to CPS Online website. The ISIRs include SAR comment code 004.
  • Student Aid Reports (SARs) – Similar to the updated ISIRs described above, borrowers will receive updated SARs with certain SAR comment codes. As a result, schools may see an increase in questions from borrowers who receive an updated SAR.

    • SAR comment code 004: “This SAR has been produced due to a change in your financial aid history information in the National Student Loan Data System (NSLDS) that may affect your eligibility for federal student aid.”

    • SAR comment code 267: “There is a limit to the total amount of subsidized Federal student loans that you may receive. Visit and select Types of Aid/Loans for more information.”

Contact Information

If you have questions about this announcement, contact the COD School Relations Center at 1-800-848-0978. You may also email


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