cod update for faas - lecture

Marie Fitzpatrick & Chuck Hirman | Dec. 2013

U.S. Department of Education

2013 FSA Training Conference for Financial Aid Professionals

COD Update for FAAs - Lecture

Session #5

Agenda

• COD Release 12.0 Recap• COD Release 12.1 Recap• COD Release 12.2 Grant Recap• COD Release 13.0 Update• COD Release 12.0 DL Recap• COD Release 12.2 DL Recap• Reporting of Loan Periods & Academic Years• COD Loan Fee Coding Modifications• COD Release 12.3 Recap• COD Release 12.4 DL Update• COD Release 13.0 DL Update• COD Technical Reference Updates

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COD Release 12.0 Recap

With Release 12.0, the COD System implemented the following functionality on March 22, 2013:

• Pell LEU Report in SAIG format, and no longer in Pell newsbox• Comma-Delimited Format• SAIG Message Class: PGLEYYOP • Example: PGLE14OP for Award Year 2013-2014

• Ability to Benefit (ATB) modifications • Applicable for all COD programs • New valid values for <AbilityToBenefitCode> tag

• 06 = High School Diploma

• 07 = GED

• <AbilityToBenefitCode> tag is required field for 2013-2014 and forward• Warning Edit 199 will be triggered if the <AbilityToBenefitCode> value does not

match the High School Diploma or equivalent value from the CPS Transaction Number

• Reject Edit 994 will be triggered if the <AbilityToBenefitCode> tag is not submitted on origination for any program

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COD Release 12.1 Recap

With Release 12.1, the COD System implemented the following functionality on May 3, 2013:

• Integrate Participation Management into the COD Web login • Access to the COD Web including User ID and passwords is now managed

through Participation Management, not COD

• The COD Web Home page, Login page, and User Information page were modified

• A new User Role List page was added for users with multiple active roles

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COD Release 12.2 Grant Recap

With Release 12.2, the COD System implemented the following Grant functionality on June 28, 2013:

• COD now returns a Reject Edit for Pell LEU 600% Limit• Applies to Award Years 2012-2013 and forward

• On the Disbursement Level during Origination and Maintenance for Pell award

• For correcting schools, the edit only updates the disbursements that are submitted

• Both correcting and rejecting schools may be subject to further de-obligation

• Reject Edit 201 is triggered

Note: COD Edit 177 and 178 were not modified

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COD Release 12.2 Grant Recap - Pell LEU

With Release 12.2, the COD System reduced the disbursements of flagged awards until the student’s LEU equals 600%.

• Occurs if the school has not submitted disbursement adjustments reducing the student’s LEU to 600% or lower within 30 days

• Award years 2012-2013 and forward• Negative Disbursement response will be sent to affected schools

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Edit #

Type Block Message Condition

201 Correcting/Reject

Disb Pell LEU Exceeds the limit of 600%

Pell LEU exceeds the Pell LEU Limit of 600.000% due to one or more of the following award or disbursement changes: Award Level Change: 1. Cost of Attendance 2. CPS Transaction Number

Disbursement Level Change: 1. Change to actual disbursement amount 2. New actual disbursement 3. Change to Disbursement Release Indicator

Note: For correcting schools, edit 201 will only update the disbursements that are submitted. Both correcting and rejecting schools may be subject to further de-obligation if there is no action taken within 30 days of the student’s LEU exceeding the 600% limit.

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To manage any Pell LEU discrepancies, a dispute process has been setup.

• Disputes should be utilized for situations where an adjustment would bring the student’s Pell Grant LEU to less than 600%

• Schools should contact the COD Contact Center to initiate the dispute process

• Documentation will be requested to support the dispute case• If the dispute is approved, FSA will systematically adjust the

student’s Pell LEU

For more Pell LEU Dispute Escalation information, reference the following IFAP postings:

Dear Colleague Letter 2013-2014, 5/16/2013Pell LEU Dispute Electronic Announcement, 6/27/13

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Adjustments for approved Pell LEU Disputes are

detailed on the student’s Pell LEU History

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COD Release 13.0 Update

The COD System’s Release 13.0 will be implemented the Spring of 2014. A portion of the scope will include:

• The Expected Family Contribution (EFC) field length expansion from 5 to 6 bytes will be incorporated into COD.

• Further streamline the Pell LEU dispute process with a new Pell LEU Dispute portal on the COD Web

• Portal provides the ability to create, view, update, upload documentation for a Pell LEU dispute

• Pell LEU History page will display the Pell LEU dispute status

• Enforcing XML Common Record Schema validation

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COD Release 13.0 Update - Expanded EFC Length

Beginning with Release 13.0, COD will begin receiving EFCs of up to 6 bytes in length from CPS. The following reports will be updated to reflect this:

• The Pell Reconciliation Report• Pell Multiple Reporting Record• Pell Year-to-Date Record• Pell Lifetime Eligibility Used Report

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COD Release 13.0 Update - Pell LEU Dispute

Pell LEU Dispute portal will allow schools to enter

dispute information for Department of Education review

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On the Pell LEU Dispute portal, the required

dispute documentation should be uploaded 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.

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COD Release 13.0 Update - XML Validation

Beginning with Release 13.0, COD will perform full XML Common Record schema validation.

• New validation will be based on the Common Record XML schema version that is published

• Enforced: 3.0d, 3.0e, and 4.0a

• Retiring: 2.0e, 3.0a, 3.0b, and 3.0c

• Examples of common errors include general file formatting such as:

• Invalid character or invalid byte

• Content before the <?xml tag

• Opening tag exists but end tag is missing

Electronic Announcement, posted on 10/29/2013, provides details for the NEW

4.0a COD Common Record Schema

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With Release 13.0, a new temporary warning edit will be triggered to advise schools of a schema validation issue. The warning edit will be discontinued later next year.

With Release 13.0, a new reject edit will be triggered.

Edit Trigger

Warning 211 If the batch contains bad XML, but would have processed under previous schema validation rules

Edit Trigger

Reject 210 If the record failed schema validation (Returned on <DocumentID> tag)

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In May and November, Software Vendors received a set of reports outlining XML schema errors in common records created using their software.

• November reports were based on common records submitted in August 2013

• Reports included:• “Top 5 schools” by error

• A “collapsible” list of schools under a particular error

• Resolving these issues will get a School/Software Vendor closer to providing a clean common record XML

• The published 4.0a Common Record Schema should be utilized for all XML validation rules

For inquiries regarding XML schema enforcement contact:

[email protected]

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COD Release 12.0 – Direct Loan Recap

With Release 12.0 the COD System implemented the following functionality on March 22, 2013:

• Direct Loan and TEACH SAS Disbursement Detail available On- Demand

• Enhancements to the Direct Loan Origination Tool (DLOT)• Exit Counseling available on StudentLoans.gov• New Repayment Estimator Tool on StudentLoans.gov

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COD Release 12.0 DL Recap - SAS On Demand

COD now provides schools the option to request Direct Loan and TEACH School Account Statement (SAS) Disbursement Detail on an “On-Demand” basis.

• Grant Data Requests, DL Rebuild, and SAS Disbursement Detail on Demand have been combined on one COD Web page

• On the Batch tab under Report Requests link

• New message classes have been created for the data requested DL and TEACH SAS files

• Message classes are award year specific

• All message classes can be found in the COD Technical Reference (Volume II, Section 2 – Message Classes)

• For details about this report see the COD Technical Reference (Volume VI, Section 8 – COD Reports)

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COD Release 12.0 DL Recap - DLOT

Users of the Direct Loan Origination Tool (DLOT) will benefit from the following enhancements:

• DLOT filters have been redesigned and improved • Filters will identify and group together by SSN students without MPNs,

Entrance Counseling, or both

• The filter will now accurately check for an MPN that can be LINKED to the incoming loan

• The options to “Add a student” and “Remove a Student” have been moved to the top of the screen as well as the bottom of the screen

• COA and Award profiles are now numbered and will “roll over” to subsequent award years

• Ability To Benefit fields updated with new codes for HS Diploma (06) and GED (07)

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COD Release 12.0 DL Recap - Exit

Counseling

Exit Counseling was made available on StudentLoans.gov Entrance and Exit Counseling is now in a similar format to Financial Awareness Counseling

• New <CounselingType> value: ExitCounseling• Exit Counseling data is included in the COD Counseling Report

and COD Web Counseling Search• COD generates and sends to schools an acknowledgement of

completed Exit Counseling sessions• COD will NOT generate Exit Counseling detail reports … schools continue to

obtain Exit Counseling detail reports from NSLDS

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COD Release 12.0 DL Recap - Estimator Tool

A stand-alone Repayment Estimator was made available to borrowers on StudentLoans.gov.

• Allows signed-in users to view their estimated payments under various repayment plans

• Uses any loan information that can be retrieved from NSLDS • Estimates payments for a particular repayment plan based on

several factors:• Loan type

• Loan balance

• Income

• Family size

• Where you live

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COD Release 12.2 – Direct Loan Recap

With Release 12.2 the COD System implemented the following functionality on June 28, 2013:

• Evaluate borrowers for the new Subsidized Usage Limit Applies (SULA) Flag

• Entrance Counseling and 150% Direct Subsidized Loan eligibility• Loan Origination Fee increase due to Sequestration• Enrollment School Code added to the Direct Loan and TEACH

Rebuild Files

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COD Release 12.2 DL Recap - 150% Limitation

Phase 1 of the modifications to enforce a 150% limitation for Direct Subsidized Loans was implemented.

• COD evaluates borrowers for the new Subsidized Usage Limit Applies (SULA) Flag

• Flag set if the borrower has no outstanding loan balance at the time he/she receives a Direct Loan with an earliest disbursement date after June 30, 2013

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A new Warning Edit, edit code #200, will trigger on origination and notify schools that the borrower is a “first-time borrower” who is subject to the 150% Subsidized Usage Limit.

Edit # Type Message

200 Warning The borrower had no outstanding loan balance at the time a Direct Loan was received after June 30, 2013 and is subject to the 150% Subsidized Usage Limit.

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Schools also receive a new report displaying all students that that have received the Subsidized Usage Limit Applies Flag.

• Identifies borrowers with an Subsidized Usage Limit Applies flag set to ‘Y’

• If an award has been submitted for a student who has a Subsidized Usage Limit Applies flag set to ‘Y’, then the student will appear on the School’s report for 90 days

• Each borrower will appear only once per school report per Award Year

• Delivered via the School’s Newsbox on the COD Reporting Website weekly in CSV format

• If no borrowers meet the report generation criteria, the school will not receive a report for that week

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Entrance Counseling and the 150% Direct Subsidized Loan limitation

Schools were encouraged to supplement entrance counseling to include 150% Subsidized Usage Limit information for borrowers who already completed entrance counseling and who would be subject to SULA

With Release 12.2 borrowers completing entrance counseling in StudentLoans.gov were linked to supplemental entrance counseling material found in an attachment to electronic announcement dated 5/16/2013

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COD Release 12.2 DL Recap - Origination Fee

The COD System applied the new Sequestration-driven Loan Origination Fee percentage for loans with Earliest Disbursement Date (EDD) on or after 7/1/2013

Note: this was later modified when higher loan fees were mandated for EDD’s on/after 12/1/2013

Loan Type Prior Rate New Rate

Subsidized Loans 1.0% 1.051%

Unsubsidized Loans 1.0% 1.051%

Direct PLUS Loans 4.0% 4.204%

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COD Release 12.2 DL Recap - Rebuild File

Enrollment School Code was added to the Direct Loan and TEACH Rebuild Files.

• Disbursement Detail Records • Only populated for Award Years 2012-2013 and forward• Direct Loans: Only added for actual disbursements • TEACH: Added for both actual and anticipated disbursements

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Reporting of Loan Periods & Academic Years

• Dear Colleague Letter GEN-13-13• Posted on IFAP – 5/10/2013• Webinars conducted on 6/4 and 6/6/2013

• Critical to the implementation of the150% Direct Subsidized Loan time-limit is the proper reporting of loan period and academic year dates

• For 2013/2014 and forward, all loan types, all borrowers• Schools must update these dates if the actual attendance

differed from the anticipated• Loan periods should include only those terms/payment

periods in which the borrower receives funds

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COD Loan Fee Coding since 10/18/2013

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Sequestration-driven loan fee increase for EDD’s on/after 12/1/2013•If you submitted these loans after 10/18 you’re fine

• COD will have accepted them if the correct fees are associated with the proper EDD’s

• COD will have rejected them if the fees were not 1.072% or 4.288% (for EDD’s on/after 12/1/2013), depending on loan type

• When the actual disbursements are sent COD will process them

•If you submitted these loans before 10/18 they would only have been accepted using outdated loan fees so you will need to fix them

• Follow the instructions in the attachment of the 10/25/213 Electronic Announcement

• If you fail to either fix the original loan or submit a new correct loan - when the actual disbursements hit COD they will reject

Loan Origination Fee Editing Now at COD

Let’s summarize:

Earliest Disbursement Date (EDD) before 7/1/2013o Subsidized/Unsubsidized: 1.0%o PLUS: 4.0%

EDD 7/1/2013 thru 11/30/2013o Subsidized/Unsubsidized: 1.051%o PLUS: 4.204%

EDD 12/1/2013 thru 9/30/2014o Subsidized/Unsubsidized: 1.072%o PLUS: 4.288%

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Note: Calculation and truncation rules have not changed.

COD Release 12.3 - Direct Loan Recap

With Release 12.3 the COD System implemented the following functionality on October 25, 2013:

• Spanish versions of Entrance, Financial Awareness, and Exit Counseling

• English and Spanish additions regarding the 150% subsidy limitation on StudentLoans.gov

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COD Release 12.4 – Direct Loan Update

With Release 12.4 the COD system will implement the following functionality on December 13, 2013:

• New Loan Consolidation application on StudentLoans.gov• Enhancements to StudentLoans.gov Repayment Estimator

• Available outside of login

• Spanish version

• Mobile version

• COD Web will provide more information on the Ability to Benefit code ‘07-GED’

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COD Release 12.4 DL Update - Consolidation

Loan Consolidation Application and Promissory Note will be made available on StudentLoans.gov.

The application will include the following features:• Allows a borrower to combine loans of different types held by

various servicers, into a single loan held by one servicer• Provides borrowers the ability to select a servicer• Pre-populates existing loans based on NSLDS data

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COD Release 13.0 – Direct Loan Update

With Release 13.0 the COD System will implement the following Direct Loan functionality in Spring 2014:

• Begin enforcing the 150% time limit for Direct Subsidized Loans• PLUS Endorser Code added to Endorser Addendum process in

StudentLoans.gov

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COD Release 13.0 DL Update - 150% Limitation

Phase 2 of the modifications to enforce a 150% limitation for Direct Subsidized Loans will be implemented.

• COD Common Record Schema and batch processing modifications

• New schema input fields

• New SULA edits

• New response for SULA calculations

• Reporting modifications• COD Web and DLOT to be updated to include the new SULA

input and response tags• New SULA Request and SULA Information pages on COD Web

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COD Release 13.0 DL – New Schema Input Fields

In order to enforce the 150% subsidy limitation, the COD Common Record Schema will be updated to include new SULA related tags, for award year 2014/2015 and forward.

Input Loan Info Award Block

<PublishedPgmLengthYears>

<PublishedPgmLengthWeeks>

<PublishedPgmLengthMonths>

<WeeksProgramsAcademicYear>

<SpecialPrograms>

<ProgramCredentialLevel>

Input Disbursement Block

<PaymentPeriodStartDate>

<EnrollmentStatus>

<ProgramCIPCode>

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The new award block tags are valid for:Direct Loan Subsidized, Unsubsidized and PLUS The new disbursement block

tags are valid for:Direct Loan Subsidized, Unsubsidized, PLUS, and TEACH

COD Release 13.0 DL Update – Special Programs

150% Subsidy limitation: The new <SpecialPrograms> tag will assist in validating the type and length of program.

Value Description

P Preparatory Coursework Graduate Professional Program

U Preparatory Coursework Undergraduate Program

T Non-Credential Teacher Certification Program

A TBD

B TBD

N Not Applicable

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COD Release 13.0 DL – Special Prog. GL Validation

150% Subsidy limitation: COD will validate the <SpecialPrograms> tag in conjunction with the Grade Level (GL) field on a Direct Loan origination. Below are examples of validation:

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COD Release 13.0 DL – Program Credential Level

150% limitation: the new <ProgramCredentialLevel> tag will assist in validating the type and length of program.

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 (Undergrad and Grad)

Doctoral degree 06 0-7 (Undergrad and Grad)

First Professional degree 07 0-7 (Undergrad and Grad)

Graduate/Professional certificate 08 0-7 (Undergrad and Grad)

Non-credential programs (preparatory coursework/teacher certification)

99 0-5 (Undergraduate)

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COD Release 13.0 DL Update – Award Level Edits

150% Subsidy limitation: new award record edits will be introduced with the updated COD Common Record schema.

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

Reject 208 DL Incorrect Student Level Code submitted

Reject 209 DL Invalid value submitted for Weeks Programs Academic Year

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

COD Release 13.0 DL – Disbursement Level Edits

150% Subsidy limitation: new disbursement record edits will be introduced with the updated COD Common Record schema.

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

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COD Release 13.0 DL Update – SULA Responses

150% limitation: SULA usage will be communicated in two ways:

1. Response File 2. System Generated Response

• Origination of awards• Maintenance on awards

• Activity on another loan for a student at your school

• Changes in enrollment status• Changes to Non-Credential

Teacher Certification Program data• Discharge of a loan• Payment to Servicer

• New Message Class: CRSUMYOP for person, award, or disbursement level

• Schools can not opt-out of receiving SULA related response• Upon implementation, schools will receive a “blast” of System

Generated Responses containing all borrowers’ SULA calculations

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COD Release 13.0 DL – SULA Tags in Responses

150% limitation: responses will also include new SULA tags.

DL Subsidy Usage

SubsidizedUsageLimitApplies

SumActualSubUsagePeriods

CalculatedPublishedPgmLengthYears

MaxSubEligibilityPeriod

AcademicYearLength

LoanPeriodLength

ActualSubUsagePeriod

AnticipatedSubUsagePeriod

SumAnticipatedSubUsagePeriods

RemainingActualSubEligibilityPeriod

RemainingAnticipatedSubEligibilityPeriod

Teacher Certification Usage

SumActualNonCredTeacherCertSubUsagePeriods

ActualNonCredTeacherCertSubUsagePeriod

AnticipatedNonCredTeacherCertSubUsagePeriod

RemainingActualNonCredTeacherCertSubEligibilityPeriod

RemainingAnticipatedNonCredTeacherCertSubEligibilityPeriod

SumAnticipatedNonCredTeacherCertSubUsagePeriods

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COD Release 13.0 DL Update - Reporting

Phase 2 of 150% Direct Subsidized Loan time limit will include several COD reporting modifications.

• Direct Subsidized Loan Usage Limit (SUL) School Report to be discontinued

• New Direct Loan Subsidized Usage Change report• Display Subsidized loans when change to borrower’s SULA calculated values

• Generated weekly and delivered on the COD Reporting website in CSV format

• New SULA fields in the Origination and Disbursement records of the Direct Loan Rebuild File

• New SULA fields in the Duplicate Student Borrower Report • For both the SAIG and CSV versions

•Enrollment status for 2013/2014 loans (EA #3 8/30/2013)

•Teacher Certif. Programs for 13/14 loans (EA #4 10/25/2013)

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COD Release 13.0 DL – Existing COD Reports

150% limitation: SULA calculations will be included in the Rebuild as well as new fields for existing COD Reports, including:

Direct Loan Rebuild File Origination Record

Direct Loan Rebuild File Disbursement Record

Duplicate Student Borrower Report

Published Program Length Years

Payment Period Start Date Actual Subsidized Usage Period

Published Program Length Months

Program CIP Code Actual NCTCP Subsidized Usage Period

Published Program Length Weeks

Enrollment Status

Special Program Indicator

Program Credential Level

Weeks Programs Academic Year

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COD Release 13.0 DL Update – New Web Pages

150% Subsidized limitation: to assist schools, two new web pages will be added to COD Web.

1. Subsidized Usage Limit Applies Request page• Allow a user to request the most recent SULA information via a new

system-generated acknowledgement

• Reachable via the left navigation panel under the Batch tab

• Search by borrower SSN and associated Entity ID

2. Subsidized Eligibility Information page• Accessible via a link on the Person Direct Loan Information page

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COD Release 13.0 DL – SULA Request Page

150% limitation: Subsidized Usage Limit Applies Request Page

COD Release 13.0 DL – Subsidized Elig. Info

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150% limitation: Subsidized Eligibility Information Page

COD Technical Reference Updates

Date Technical Reference Updates

Late November 2013

New schema is targeted for publication

December 2013 Includes Implementation Guide

Note: COD Technical Reference Common Record Layout was redesigned for the

Fall 2013 publication

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Related FSA Conference Sessions

Session # Session Title

3 Pell Grant Duration of Eligibility Limitation

4 Loan Counseling Tools

6 COD Hands-On

8 Title IV Reconciliation: What You Need to Know

9 PLUS Processing A to Z

11 Direct Loan Processing Tips & Troubleshooting

28 What FAAs Must Know About 150% Direct Subsidized Loan Limits

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Contact Information

We appreciate your feedback and comments.

Grants: Marie Fitzpatrick

Phone: 312-730-1549

E-mail: [email protected]

Direct Loans: Chuck Hirman

Phone: 206-615-3643


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Contact Information

COD School Relations Center

Grants: 1-800-474-7268

Direct Loans: 1-800-848-0978

Applicant Services: 1-800-557-7394

Foreign Schools: 571-392-3737


URL: http://www.cod.ed.gov

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QUESTIONS?

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