Last Friday, operational guidance was released by the Department of Education on how institutions are to report Federal Work-Study earnings using the Common Origination and Disbursement (COD) system. The electronic announcement (CB-23-13) can be found on the FSA website and is also below for reference.
POSTED DATE: July 21, 2023
AUTHOR: Federal Student Aid
ELECTRONIC ANNOUNCEMENT ID: CB-23-13
SUBJECT: Operational Information – Reporting Federal Work-Study Earnings to the COD System Using the Campus-Based XML Schema Version 1.0a
As noted in a March 6, 2023 Electronic Announcement, we will implement Common Origination and Disbursement (COD) System functionality and the Campus-Based XML schema version 1.0a. Implementation is planned for July 30, 2023. In this Electronic Announcement, we provide operational information to assist schools in the reporting of student-level earnings information for the Federal Work-Student (FWS) Program.
Information about other changes to be implemented with the COD System update on July 30, 2023, is provided in a separate Electronic Announcement.
Background
Under the FAFSA Simplification Act, we will use school-reported data for the FWS Program to accurately calculate the Student Aid Index (SAI) for aid recipients. We will begin collecting this data after Aug. 1, 2023, to be used in the 2024–25 Free Application for Federal Student Aid (FAFSA®) processing cycle.
Reporting FWS Earnings to the COD System
In the following sections, we provide information about reporting FWS earnings to the COD System.
What and Who Gets Reported – Student-Level Gross FWS Earnings
Schools must report, for each student, the total (both institutional and federal share, as applicable) gross amount of all FWS earnings for any portion of the applicable calendar year. Amounts reported in COD must be rounded to the nearest whole dollar. For the 2024–25 FAFSA processing cycle, schools will be reporting FWS earnings disbursed at their institution from Jan. 1, 2022, through Dec. 31, 2022.
FWS earnings amounts must be reported to the COD System in a manner consistent with the requirements for including such amounts on the W-2 (see General Instructions for Forms W-2 and W-3). Per the “Calendar year basis”, the amount of FWS earnings should include all amounts that were paid during the calendar year, from January 1 through December 31, even if the work was performed outside of the calendar year. In addition, any portion of a student’s FWS earnings that are paid in the form of non-cash contributions (e.g., payments toward tuition, room, or board, etc.), must be included in the total FWS earnings that are reported to the COD System, except when such non-cash payments are made by a federally approved Work College for work performed under the comprehensive work-service-learning program.
Schools must report for any student who received FWS earnings regardless of that student’s enrollment status at the school (i.e., a school will report FWS earnings paid even if the student is no longer enrolled at the school).
Because some students may attend different schools, there will be instances where more than one school is reporting FWS earnings for a particular student. The COD System will allow multiple schools to report for the same student. FSA will use the combined total of the student’s FWS earnings by all schools in the SAI calculation. Note: Schools will be able to view the total FWS earnings for each student (including other reporting schools and the respective amounts) on the COD website.
Reporting Options and Required FWS Data Elements
As explained in the COD Technical Reference, schools will report FWS earnings information via batch submission using the Campus-Based XML Schema version 1.0a or via the COD website. When reporting data, schools will be required to submit the following information:
Last name
- Date of Birth
- SSN
- CPS Transaction Number
- Total FWS Earnings
- Calendar Year
Additional data elements may be submitted. Full details about required and optional fields, valid values, and other business rules are in Volume 4 of the COD Technical Reference.
Note to EDExpress Users: We plan to post EDExpress for Windows 2023–24, Release 3.0 in July 2023 which will incorporate the Campus-Based schema version 1.0a and allow for reporting FWS earnings using EDExpress.
Note: The Campus-Based XML Schema 1.0a includes an additional reporting block for FSEOG-related data, but this data will not be collected upon implementation and will be reserved for future use, if needed.
Calendar Year vs. Award Year
As noted above, schools will report the total FWS for the calendar year, however, because the calendar year will overlap two different award years, schools will be able to report FWS data using two different methods:
- Calendar Year Totals by Award Year – school submits two totals, one amount for the calendar year portion paid in award year 1 and a second amount for the calendar year portion paid in award year 2.
- Calendar Year Total Amount only – school submits one total amount for the full calendar year and no award year information is included.
As an example, the table below shows information about Student A who was paid FWS earnings of $300 on each of the listed dates.
|
Award Year
|
FWS Payment Dates ($300 each)
|
Total FWS Award Year Compensation Paid
|
Total 2022 Calendar Year for Award Year
|
|
2021–22 |
10/1/2021 |
$1800 |
$900 |
|
2022–23 |
10/1/2022 |
$2400 |
$600 |
In this case, for reporting method 1, the school would report two separate FWS amounts of $900 and $600. Alternatively, for reporting method 2, the school would report one FWS amount of $1500. In either option, the amounts paid in 2021 or 2023 would not be reported.
Important Note: A school cannot change the reporting method it chooses after records have been accepted, without first zeroing out all accepted records and starting over. For example, if a school submits a record for the 2022 calendar year with the amount paid during the 2021–22 award year, and it is accepted, a subsequent record that denotes the 2022 calendar year only (but no award year is provided) will be rejected.
Reporting for Multiple Schools
The ability for one campus to report on behalf of its locations and/or other main campuses with which it is affiliated is driven by the reporting and attending relationships established in the COD System. These relationships will be set up in accordance with existing relationships between main campuses and their locations, as well as the FISAP reporting structure currently utilized by schools. If your school has an issue with its reporting and attending relationships as established in the COD System, it may submit a request to change them via the FSA Partner and School Relations Center.
Reporting Deadline for FWS Earnings for Calendar Year 2022
To ensure accurate SAI calculations at start-up, it is strongly recommended that schools plan to complete the submission (and COD System acceptance) of FWS earnings for the 2022 calendar year by December 2023, as data must be on file before the release of the 2024–25 FAFSA form. Timely advance reporting will also help limit unnecessary subsequent Institutional Student Information Record (ISIR) transactions.
Going forward, future calendar year FWS reporting deadlines will be no later than the annual release of the FAFSA form, generally October 1 of each year.
Corrections to Reported FWS Earnings
If circumstances require a correction to previously submitted data, schools can submit a new record with the updated information. Once the corrected information is processed, it will be sent to other Federal Student Aid systems and, if applicable, will result in a subsequent ISIRs.
Note: Corrections to a student’s SSN or Date of Birth (DOB) must be done through a COD common record batch or on the COD website. Student data will not be updated through the Campus-Based schema submission.
While the initial deadline for reporting FWS earnings is December 2023, FWS earnings data and corrections, when necessary, for the 2022 calendar year will be accepted by the COD System until the final date for 2024–25 FAFSA processing of Sept. 13, 2025.
Summary of COD System Changes
In the sections below we provide a high-level summary of the changes made to the COD System and website.
COD Website Updates
There will be new Campus-Based Person, Award and Batch search screens. These screens can be accessed from the existing “Person Search,” or via the Campus-Based System homepage using the new “CB Person Search” link. Campus-Based awards will not be displayed on the existing “COD Award Detail” pages. Campus-Based batches will only be searchable using the new “Campus-Based Batch Search” page.
We will automatically expand access to these pages for existing COD school and third-party users with view and/or update access. No additional enrollment actions need to be taken.
COD Edits
Many existing COD Reject edits will be modified to apply to Campus-Based records. These edits will trigger under similar conditions as they do for COD records. For example, COD Reject Edit 100 (Sender does not have reporting permission for the School identified in the Reporting School Entity ID), will also apply to Campus-Based records.
There will be two new Campus-Based specific edits introduced with this implementation.
- COD Reject Edit 300 (New FWS Award Submitted using Different Calendar Year or Award Year Reporting Method than Previously Accepted) – As noted above, schools must use the same reporting method when submitting FWS information. A school will receive this edit when it submits FWS information without the same level of detail as a previous submission.
- COD Reject Edit 301 (Award Received After the End of the FAFSA Processing Year) – A school will receive this edit if it sends FWS data after the FAFSA processing year has closed.
Detailed information about the edits for Campus-Based records are in Volume 4, Section 4 of the COD Technical Reference.
Campus-Based Schema File and 2023–24 COD Technical Reference Information
As a reminder, for technical information about the Campus-Based schema, schools and third-party software providers can refer to the Campus-Based XML Schema Version 1.0a and the 2023–24 COD Technical Reference documents posted on the Knowledge Center.
Contact Information
If you have questions, contact the FSA Partner and School Relations Center at 1-800-848-0978. You may also email CODSupport@ed.gov