COD Update

1. Session 14 COD Update Wood Mason and Marie Fitzpatrick | Nov.-Dec. 2017 U.S. Department of Education 2017 FSA Training Conference for Financial Aid Professionals

2. Contact Information Marie Fitzpatrick U.S. Department of Education Federal Student Aid Business Operations Grants Division Chicago, IL marie.fitzpatrick@ed.gov

3. Contact Information Wood Mason U.S. Department of Education Federal Student Aid Business Operations Federal Loan School Support Team Atlanta, GA wood.mason@ed.gov

4. Agenda • Recent Updates • Significant Enhancements – Summer 2017 • COD System Changes – Fall 2017 • Report Changes • Pell Restoration • Year-round Pell • COD Release for Award Year (AY) 2018-19

5. Recent Updates Heads-Up! Sequester mandated changes for FY 2018 are in place...

6. Recent Updates Direct loan origination fees have been reduced... • Direct Loan awards with an earliest disbursement date (EDD) on or after October 1, 2017, and before October 1, 2018 • The Direct Subsidized and Direct Unsubsidized Loan origination fee fell from 1.069% to 1.066% • The Direct PLUS Loan origination fee for Parents of Dependent students and Graduate/Professional students fell from 4.276% to 4.264% • COD modified code on June 18 to validate the new origination fee/EDD

7. Recent Updates Teacher Education Assistance for College and Higher Education (TEACH) Grant Awards and Iraq & Afghanistan Service Grant Awards with an EDD on or after October 1, 2017 and before October 1, 2018 require a reduction of 6.6% from the award amount for which the student would otherwise have been eligible

8. Recent Updates New interest rates for Direct Loans published in an Electronic Announcement dated 5/30/2017

9. Recent Updates New interest rates for Direct Loans first disbursed on or after July 1, 2017 and before July 1, 2018* • Undergraduate Direct Subsidized/Unsubsidized Loans • 4.45% • Graduate/Professional Student Direct Unsubsidized Loans • 6.00% • Parent and Graduate/Professional Student Direct PLUS Loans • 7.00% *Rate is “fixed” for the life of the loan

10. Significant Enhancements

11. Significant Enhancements • COD updated the Batch Search options to enhance search capability and search results pages • AY 2016-17 and forward • Entity ID searches • SSN searches • Date Range search window expanded from 60-days to 180-days

12. Significant Enhancements

13. Significant Enhancements

14. Significant Enhancements • COD streamlined the closeout process to align the Grant and Direct Loan Programs… • School Balance Confirmation and COD Web Closeout for ALL PROGRAMS for Award Year 2016-17 and forward • Re-open functionality for ALL PROGRAMS • New/Updated system-generated correspondence for ALL PROGRAMS • Balance notifications and reminders • Closeout or Re-Open award year • Additional correspondence

15. Significant Enhancements • COD performs a post “Program Year Closeout” reduction of Direct Loan awards • Will “clean up” awards not “caught” by current edits and those not adjusted by schools • Reduce anticipated disbursements to $0 • Reduce award amount to equal amount disbursed • Adjust the loan period to exclude payment periods reduced to $0 (Award Year 2014-15 and forward)

16. COD System Changes – Fall 2017 Fall 2017

17. COD System Changes – Fall 2017 • With the Fall 2017 Release COD modified way schools access and download COD Reports • COD “upgraded” the reporting platform • School Users now access COD reports via a new “COD Web Reporting Portal” • Electronic Announcement dated July 27, 2017 for complete details!

18. COD System Changes – Fall 2017 • COD made changes to the format and delivery options of some reports • Some COD reports will remain available in currently downloadable formats, i.e., fixed length and comma-delimited w/headers • Pipe-delimited and comma-delimited without headers will no longer be available download formats for any report

19. COD System Changes – Fall 2017 • The format options for the School Account Statement (SAS) for all Programs have been updated • Comma de-limited w/headers • Fixed length • “Comma Delimited w/out Headers” and “Pipe Delimited” download formats are no longer available for any SAS

20. COD System Changes – Fall 2017 • COD Web reports are now available for download in comma-delimited w/headers format only • Some reports will be updated with additional data fields and will require “layout” change • COD will retire several reports

21. COD System Changes – Fall 2017 • The reports below were modified to include additional fields and values in a “new layout” • COD will add nine (9) new data elements to the Direct Loan Actual Disbursement List • COD will add your school OPE ID as a new data element to the Direct Loan Counseling Report • We will change the criteria to populate the data of the Duplicate Student Borrower Report

22. COD System Changes – Fall 2017 • Reports retired with the Fall 2017 COD Release • Direct Loan Booking Warning Report • Direct Loan Expired MPN Report • Direct Loan Inactive Loans Report • Direct Loan MPN Discharge Report • Direct Loan MPNs Due to Expire Report • Direct Loan SSN/Name/Date of Birth Change Report • Pell Grant SSN/Name/Date of Birth Change Report • TEACH Grant Inactive Grant Report • TEACH Grant SSN/Name/Date of Birth Change Report

23. COD System Changes – Fall 2017 • COD changed the format and display for dates in ALL reports delivered in comma-delimited w/headers format • Dates will be formatted and displayed as YYYY-MM-DD • This change will NOT apply to the School Monitoring Report or ANY fixed length report

24. COD System Changes – Fall 2017 • COD now generates a new weekly Master Promissory Note (MPN) Status Report • Replaces three retired MPN reports • Includes MPNs that became inactive within the past 30 days due to • Death, Unauthorized Signature, or Identity Theft • Linking a Direct PLUS Loan to an endorser • Expired, or will expire within the next 60 days, due to no award linking, or no actual disbursement on a linked loan, within one (1) year of the date of receipt at COD • 10 years have passed since receipt at COD • Includes MPNs Closedwithin the last 30 days

25. COD System Changes – Fall 2017 • To make importing numbers with leading zeros (0) easier, COD update several numeric fields in all comma-delimited w/headers reports • An equal sign (=) and quotation marks were added to the beginning of the field • The Social Security Number “000123456” will be displayed as =“000123456” • An equal sign (=) and quotation marks will be added to School ID fields • This change will NOT apply to any version of the School Account Statement (SAS) or any fixed length report

26. COD System Changes – Fall 2017 • For more information on the new COD Reporting Portal and Reports come to Federal Student Aid Training Conference Session #2 “New COD Reporting”

27. Fall Changes - Pell Restoration Pell Grant Eligibility Restoration for Students that Attended a Closed School

28. Fall Changes - Pell Restoration Sections • Resources • Process of determining eligibility for schools and students • FSA’s progress of implementation • COD Web changes • New Edit • Total Eligibility Used (TEU) Calculation Change

29. Fall Changes - Pell Restoration Resources: • December 21, 2016 EA --reinterpreted previous policy guidance so Pell Grant recipients who were unable to complete their course of study due to the closing of their school can now have their Pell Grant eligibility restored • April 3, 2017 EA– Introduced how FSA would operationally restore Pell recipients’ eligibility based on their attendance at a closed school • For a practical, operational perspective on Pell Grant restoration for students transferring from a closed school, consider attending conference Session #4 -- Pell LEU and SULA for Transfer Students from Closed Schools

30. Fall Changes - Pell Restoration Pell Grant eligibility restoration was completed in two phases. Phase I was a manual process which began in February 2017 and concluded in September 2017. Phase II was implemented with the COD 16.2 release and automated the restoration process where possible, but did not change how Pell restorations are communicated to schools.

31. Fall Changes - Pell Restoration Steps in Pell eligibility restoration (both Phase I & II): 1. Identify closed schools • “officially” closed Main schools, not closed or ineligible locations • Department has finished closeout audits with the school • all final disbursements submitted to COD and enrollment data to National Student Loan Data System(NSLDS) 2. Identify Pell recipients eligible for restoration • Received Pell Grant Funds at a closed school • Did not complete program at the closed school (Enrollment status ≠ G-graduated in NSLDS) • Valid enrollment status in NSLDS with date within 2 years of closure

32. Fall Changes - Pell Restoration 3. Restore Pell Eligibility • Pell Lifetime Eligibility Used (LEU) is adjusted in COD by amount received at the closed school. Updated LEU is also sent to NSLDS. 4. Send most affected students a targeted email • Had an LEU > 500% prior to restoration or had restored eligibility in the most current AY. • Adjusted LEU < 600% • No existing award in COD at Grade level 6 or 7 (graduate)

33. Fall Changes - Pell Restoration 5. Affected current (open) schools receive • Edit 221 in response when any award is submitted for a student with restored eligibility • Targeted email & FileShare if disbursed any financial aid to the student in the current AY or the one prior, OR school listed on the highest CPS transaction in the three latest AYs • LEU Adjustment Type captured on the Pell LEU History page as “Closed School Restoration”

34. Fall Changes - Pell Restoration A new “reverse arrow” icon will appear to the left of the Adjustment # if there is more than one adjustment made for that student, for that AY, for that closed school.

35. Fall Changes - Pell Restoration The Adjustment # hyperlink with the reverse arrow from the LEU History Page displays a pop-up with the student’s Closed School Restoration History for that AY at that school.

36. Fall Changes - Pell Restoration Person Level Warning Edit 221-- Pell LEU Restoration Due to Closed School Student has undergone a restoration of a portion of their Pell LEU due to their attendance at a closed school. This may appear in a response for any Pell Grant, TEACH Grant, or Direct Loan. There is nothing that needs to be done to resolve this edit. It is for informational purposes only.

37. Fall Changes - Pell Restoration Review of the distribution of adjusted LEUs • Pell LEU is updated in the COD system • Displayed on appropriate COD Web screens for active students • Carried on all Pell Common Record responses, and reports if there is Pell activity for the student in an operative AY • Adjusted LEUs are sent to NSLDS • Updated LEUs in NSLDS are sent to the CPS ISIR is generated is dependent on pre/post screening rules outlined in the ISIR Guide

38. Fall Changes - Pell Restoration Altered Total Eligibility Used (TEU) Calculation The TEU is the amount of Pell a student has received across all schools in one AY. Usually capped at 100%. The TEUis the maximum amount that COD edits against, with additional student-specific qualifiers based on circumstances. Closed School Restoration Adjustments are one of those circumstances. So TEU for a student with a Closed School Adjustment is calculated as follows: TEU = 100% + |Net of Closed School Adjustments for AY|

39. Fall Changes- Year-round Pell Year-round Pell

40. Fall Changes- Year-round Pell Sections • Resources • General Guidance • Additional Eligibility Indicator (AEI) • Total Eligibility Used (TEU) Calculation Changes • Changes to Origination and Disbursement Edits • COD Web Changes for AEI • Common Record Layout for AEI

41. Fall Changes- Year-round Pell Resources • DCL GEN-17-06– Provides policy guidance on calculating additional Pell eligibility for the 2017-18 AY and forward • June 20, 2017 EA -- provides preliminary COD System implementation information and school processing timeline • Updated 17-18 COD Technical Reference –posted 8/30/17 • October 4, 2017 EA – The COD 16.2 Implementation documentation • For a more in depth perspective on Year-round Pell consider attending conference Session #19 -- A Guide to Year-Round Pell Grants

42. Fall Changes- Year-round Pell Some General Information • Applies to AY 2017-18 and forward • Must be otherwise eligible to receive Pell Grant funds for the payment period • Must be enrolled at least ½-time in the period(s) for which the student receives the additional 50% Pell Grant • Additional Pell Grant will be included in the calculation of Pell LEU • The Year-round Pell guidance also allows for increased eligibility for the Iraq & Afghanistan Service Grant for the 2017-18 AY and forward, minus any amounts subject to sequestration

43. Fall Changes- Year-round Pell Other COD System Changes • Iraq & Afghanistan Service Grant will also be updated on the COD Web to accommodate for the AEI flag • School Reports continue to display the AEI • Pell Grant Multiple Reporting Record (MRR) (position 449) • Pell Grant Reconciliation Report Record (position 97) • Pell Grant Year-to-date Record (position 251) • Pell POP Report (column V in new CSV format)

44. Fall Changes- Year-round Pell There are 4 main components of Year-round Pell project • Additional Eligibility Indicator (AEI) • Adjusted Total Eligibility Used (TEU) calculation • Origination & Disbursement Edits • COD Web Screen Updates

45. Fall Changes- Year-round Pell • Additional Eligibility Indicator (AEI) • Schools may submit the AEI, an optional tag, that will indicate eligibility for up to 150% Scheduled Federal Pell Grant (SFPG) • If a school submits an AEI = True, the total awarded Pell should equal an amount > 100% of the student’s SFPG • FSA will be monitoring schools that submit the AEI=True for students not awarded or disbursed Pell over the 100% SFPG. Any school suspected of such practices will be referred to Program Compliance for review and sanctioning if not corrected

46. Fall Changes- Year-round Pell • TEU Calculation • The TEU is the amount of Pell a student has received across all schools in one AY, usually capped at 100% TEU = 100% + |Net of Closed School Adjustments for AY| • The TEU is the maximum amount that COD edits against, with additional student-specific qualifiers based on circumstances. An AEI = True is one of those qualifiers. • For the Year-round Pell project, the TEU will be modified if • the AEI= “true” AND • actual disbursement amount > $0 TEU = 150% + |Net of Closed School Adjustments for AY|

47. Fall Changes- Year-round Pell Origination & Disbursement Edits • The COD System will modify the edit logic for Pell Awards in the 2017-18 Award Year and forward when the AEI is equal to ‘true’ for the following: • Disbursement Warning Edit 65 • Disbursement Warning Edit 68 • Award Level Rejecting/Correcting Edit 172 • Award Level Rejecting/Correcting Edit 173 • Award Level Warning Edit 174 • Award Level Warning Edit 175

48. Fall Changes- Year-round Pell Edit 65 Condition -- Disbursement Level Warning Edit 65 triggers if the disbursement amount is decreased but the Pell award is still in POP or Negative Pending Situation. It shall trigger if all the following are true: • Disbursement Amount is decreased or corrected downward, AND • Disbursement Release Indicator (DRI) is submitted as ‘true’, AND EITHER • Actual approved disbursement amount is > award amount, OR • AEI= ‘false’ and TEU > 100% + |Net of Closed School LEU Restorations for that AY|, OR • AEI= ‘true’ and TEU > 150% + |Net of Closed School LEU Restorations for that AY|

49. Fall Changes- Year-round Pell Edit 68 Condition (POP Edit) Disbursement Level Warning Edit 68 triggers if the TEU exceeds the limit across more than one school and all of the following are true: • Disbursement is not rejected • Another Pell award(s) for the current AY exists at different school(s) • Total amount disbursed for any other Pell award(s) is > 0 AND • AEI = ‘false’ (or never submitted/blank) and TEU > 100% + |Net of Closed School LEU Restorations for that AY| OR • AEI= ‘true’ and TEU > 150% + |Net of Closed School LEU Restorations for that AY|

50. Fall Changes- Year-round Pell Edit 172 -- Award Level Rejecting/Correcting will trigger when all of the following are true: • AY is 2017-18 and forward • Pell award is submitted with, or already contains, an AEI = 'true', AND • The Pell Award Amount submitted is > (1.5 X SFPG) This edit is similar to Edit 39, except it is for awards with an AEI = True. It lets schools know the award is over the approved amount.