150% Direct Subsidized Loan Limit

&

COD

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Wood Mason

U.S. Department of Education

Federal Student Aid

Atlanta, GA

770.383.9662

wood.mason@ed.gov

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Agenda

• Phase 1 of the Direct Loan Subsidized Loan Limit (SULA)

modifications to COD

Modifications to COD

• Phase 2 of the SULA modifications

SULA refresher

150% SULA tags and data

New edits

Real-time processing

New Schema 4.0a

The Law

MAP-21

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Public Law 112-141, or Moving Ahead for Progress in

the 21st Century Act (MAP-21), establishes a limit of

how many years a student may receive Direct

Subsidized Loans

• Tracking and enforcement of the Direct Subsidized Loan

Limitation will be accomplished by the COD system

Function of the data you report to COD

• Modifications to the COD system to meet the legislative

requirements have been implemented in two (2) phases

COD SULA Modifications

Phase 1

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In June of last year, COD implemented Phase 1 of the

system modifications necessary to accommodate the

legislation

• COD began to identify “first-time” borrowers for whom a

new “Subsidized Usage Limit Applies” (SULA) flag was to

be set

The flag was displayed as a non-editable date on the COD

Person Information screen

Warning edit #200 was returned as well in the Common Record

Response identifying that borrower as a “first-time” borrower

COD generated a report identifying “first-time” borrowers at your

school

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COD also made available an Excel utility that helped

you identify any 2013-2014 award year borrowers

that could have lost eligibility

AND

Provided a means to “track” those “first-time”

borrowers in a qualifying teacher certification

program for the 2013-2014 award year

SULA Refresher

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Maximum eligibility period is 150% of the published

length of borrower’s current or upcoming academic

program

• Varies by program

• Multiply published length of program by 1.5

• Two exceptions

• Measured in academic years or portions

• ED will calculate using school-reported information

DCL GEN 13-13 for the particulars

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Bachelor’s degree-completion programs will have a

Maximum Eligibility Period of 6 years

• Implemented by reporting program length as 4 years

• Definition:

• Only admits students who have completed

Associate degree or

Two years of prior undergraduate coursework

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Special admission associate degree programs will have a Maximum Eligibility Period of 6 years

• Implemented by reporting program length as 4 years

• Definition: Only admits students who have completed

Associate Degree

or

Two Years of prior undergraduate coursework

• Admits students on a competitive basis

i.e., no open enrollment

• Prepares students for occupation requiring licensure from state

Example: Nursing program

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150% limit is met and further

eligibility is lost when Remaining

Eligibility Period is zero (or less)

Maximum Eligibility Period (MEP) of the published

length of your borrower’s current, or upcoming,

academic program

• Varies by program

• Multiply published program length by 1.5

• Measured in academic years or portions of academic

years

• If your published program length is reported in months or

weeks COD will convert it to years or portions thereof

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A Subsidized Usage Period (SUP) is the period of time for which a borrower receives a Direct Subsidized Loan

• Calculated on a loan-by-loan basis

• Measured in academic years or portions thereof

• Rounded up or down to the nearest tenth of a year

• Included ONLY periods when a Direct Subsidized Loan is received

• COD will calculate using school-reported data

• There are two exceptions…

Enrollment Status

Single-term, full annual loan limit

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# days in the loan period

# days in the academic year Subsidized Usage Period

Accurate reporting of academic year and award start/end dates is vital to the accurate calculation of a SUP

• Award Year 2013-2014 and forward

All loans and all borrowers

• Schools MUST change the anticipated dates if they differ from actual attendance

• Loan periods should include ONLY those terms/payment periods in which the borrower receives funds

• Dear Colleague Letter (DCL) GEN 13-13 posted May 10, 2013, has the particulars

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Example… • Scheduled academic year

Fall/Spring…September 10, 2014-May 10, 2015 and a corresponding loan period

242 days in the loan period and 242 days in the academic year

= 1.0 YEARS

• But what is the borrower doesn’t return for the Spring Term?

The school updates the loan period to Fall only

Does NOT adjust the academic year

91 days for the Fall Term

Still 242 days in the academic year

The SUP is now 0.4 YEARS!

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Exception #1

Calculated

subsidized usage

period is prorated by

enrollment status

Proration occurs

before rounding

Full-time = 1.00

¾-time = 0.75

½-time = 0.50

Prorate Subsidized Usage Period based on enrollment status

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Exception #2…Only circumstance where dollars are considered is when a student receives a Direct Subsidized Loan in the amount of the annual loan limit

Exception #2 can only occur for standard-term programs or for

non-standard-term programs that are substantially equal and are each at least nine weeks in length

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When both Exception #1 and Exception #2 apply

Result is always the same as the proration factor used in the enrollment status exception - 0.5 or 0.75

Phase 2

Phase 2 of the 150% Direct Subsidized Loan Limitation

(SULA) brought…

• 150% SULA tags and data

• New edits

• Real-Time processing

New system generated response

• New Schema 4.0a

Full XML Common Record Schema validation

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New data tags for Award Year 2014-2015

• Award Block

<PublishedPgmtLentghYears>

<PublishedPgmtLengthMonths>

<Published PgmtLengthWeeks>

<WeeksProgramAcademicYear>

<SpecialPrograms>

<ProgramCredentialLevel>

• Disbursement Block

<PaymentPeriodStartDate>

<ProgramCIPCode>

<EnrollmentStatus>

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Reporting your Published Program Length in weeks or

months …

• COD will convert weeks and months to years or portions

• You can report ONLY one Published Program Length tag

in the award block of your Common Record

# days in the Program

# days in the Title IV Academic Year Program Length

Month = 30 days

Week = 7 days

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Reporting your CIP Code and Academic Year…

• “Classification of Instructional Program” (CIP) Code

Provides a taxonomic scheme, or classification into

ordered categories, that supports the accurate tracking

and reporting of fields of study

http://nces.ed.gov/ipeds/cip2010

• Your Academic Year is school-defined

Minimum of 30-weeks of instruction and 24 semester (36

quarter) credit hours for a credit-hour based program

No hour minimum for a graduate level program

Minimum of 26 weeks and 900 clock-hours of instruction

for a program measured in clock-hours

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Value Description

A Selective Admission Associate Program

B Bachelor’s Degree Completion Program

N Not applicable

P Preparatory Coursework Graduate Professional Program

T Non-Credential Teacher Certification Program

U Preparatory Coursework Undergraduate Program

The new <SpecialPrograms> tag will identify borrowers in those programs

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Special Programs Tag Value Valid Grade Levels

Sel Adm Assoc Prgm A TBD

Bach Deg Completion Prgm B TBD

Not Applicable N No G/L Validation

Tag Not Submitted N/A No GL Validation

Prep Graduate Prgm P 5

Non Cred Tchr Cert T 5

Prep Undergraduate U 1 & 0

COD will validate the <SpecialPrograms> tag against

Grade Level on an incoming Loan Origination Record

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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 (Graduate)

Doctoral degree 06 0-7 (Graduate)

First Professional degree 07 07 (Graduate)

Graduate/Professional certificate 08 0-7 (Graduate)

Non-credential programs (preparatory coursework/teacher certification)

99 0-5 (Undergraduate)

The <ProgramCredentialLevel> tag will be validated

against Grade Level as well…

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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

Warning 207 DL Sub Maintenance to this tag may have caused the Remaining

Subsidized Eligibility Period to drop below zero for this award

Reject 208 DL Incorrect Student Level Code submitted

Reject 209 DL Invalid value submitted for Weeks Programs Academic Year

New award level edits

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

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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

New disbursement edits

Phase 2 will also bring “real-time” processing to COD

• Subsidized Usage Period calculations

SUP will be returned per award via the Common Record

Response

• Normal and routine program and COD editing

The Subsidized Usage Limit Applies (SULA) tag will be

returned at the Person level for award year 2014-2015

Warning Edit #200 will continue to be returned on award

year 2013-2014 awards

The COD website will continue to display the SULA date on

the View Person Information screen

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Phase 2 will also bring a new SULA notification via a

new system generated response

• Generated each night after daily SULA processing is

complete

• Sent to schools reflecting a student’s changed SULA data

and the change was NOT initiated by the receiving school

Schools cannot opt out

COD sent a “blast” to all attendant schools after the

implementation of Cod Release 13.0

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Schema 4.0a

For award year 2014-2015 and forward COD will

perform 100% (Full) XML Common Record Schema

validation

• Based on the published Common Record XML schema

COD will enforce 100% full schema validation on schemas

3.0d, 3.0e, and 4.0a

COD will retire schemas 2.0e, 3.0a, 3.0b, and 3.0c

An electronic announcement (EA) dated October 29, 2013,

provides schema 4.0a details

• Examples of errors has been provided to software vendors

and “IT” shops

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A new “temporary” Warning Edit #211 will be triggered

and returned to indicate a schema validation issue

• On inbound XML Common Records that do not meet 100%

schema validation but would have been accepted under

prior year rules

Tags out of order

Blank tag that cannot be blank

Will be discontinued at a yet-to-be-determined later date

• Warning Edit #211 will be discontinued at a yet-to-be-

determined date

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A new Reject Edit #210 will be triggered and returned

for malformed XML documents

• Failed 100% schema validation

Missing value

Invalid value

• The edit is returned at the <DocumentID> tag

Batch level reject

• COD School Relations Center will communicate with the

school via an e-mail when malformed XML is submitted

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Phase 2 COD Website

Enhancements

Phase 2 of the 150% Direct Loan Limit modifications to

COD will include enhancements to the COD website

• A new SULA report

• The COD website will be updated to include, and display,

all of the new SULA data

• New SULA Request and SULA Information screens will be

implemented on the COD website

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The currently produced Direct Subsidized Loan Usage

Limit School Report will be discontinued

• A new Direct Loan Subsidized Usage Change report will be

created and implemented

Posted weekly in your school NewsBox

CSV format

Option to receive the report of not

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The currently produced Direct Subsidized Loan Usage

Limit School Report will be discontinued

• A new Direct Loan Subsidized Usage Change report will be

created and implemented

• The new report will display subsidized loans when a

change to a calculated SULA value occurs

• The new report will be posted in your school NewsBox

Weekly

CSV format

Option to receive the report of not

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COD will update screens to display SULA data

• View Person Information screen

Redesigned

Pop-up on Personal History events give additional

information

• Disbursement History Information screen will display

additional SULA data

Enrollment Status

Program CIP Code

Payment Period Start Date

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COD will implement and display two (2) new website

screens

• Subsidized Usage Information Screen

Accessible via a hyperlink on the Person Direct Loan

Information screen

• Subsidized Usage Request

Allows a user to request the most recent SULA data via the

new system generated response

Accessed via the Batch tab

Search by SSN or Entity ID

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Thank you for

attending…

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