COD System Changes to Comply With CARES Act Cause Headaches for Aid Offices

By Owen Daugherty, NASFAA Staff Reporter

As a disrupted fall semester full of uncertainties approaches, financial aid administrators learned recently that they will have to manually check boxes updating disbursement records directly in the Common Origination and Disbursement (COD) website for students who have withdrawn from school for COVID-19-related matters — a time consuming and inconvenient process for some.

The Department of Education (ED) announced COD system changes necessary to comply with reporting requirements outlined in the Coronavirus Aid, Relief and Economic Security (CARES) Act and to apply relief provided in the legislation to students who withdraw for coronavirus-related reasons in a July 30 Electronic Announcement. The functionality will be implemented in two phases — one immediately and the other planned for late September.

Wayne Kruger, executive director of financial assistance operations at St. Petersburg College in Florida, outlined just how laborious of a task this would be for his staff, estimating that it would take them a minimum of 200 hours altogether to manually enter the information for the nearly 650 students who dropped out at his institution in the spring semester.

“And that's just for spring term alone,” he said. “So you're looking at, with a 40-hour work week, if it's one person, it would take four to five weeks to enter all that data in.”

While a deadline for this reporting requirement has yet to be set, in the immediate phase, ED has implemented a “coronavirus indicator” — a disbursement-level checkbox whereby schools will indicate that a withdrawn student is eligible for one or more of the following benefits provided by the CARES Act: 

  • Cancellation of Direct Loan funds received for the period; 

  • Exclusion of the period from the student’s subsidized loan usage (SULA) for purposes of the 150% Direct Subsidized Loan Limit; and 

  • Exclusion of Pell Grant funds received for the period from the student’s Lifetime Eligibility Used (LEU)

Details on the location of the indicator and the circumstances under which it should be checked are included in the announcement.

The process that schools will use to check the coronavirus indicator is manual and takes place at the disbursement level, which can create a substantial amount of administrative burden at institutions with significant numbers of COVID-related withdrawals. NASFAA has engaged with ED staff to advocate for a streamlined, batch process.

In the second phase of implementation scheduled for September, to provide schools with a mechanism for reporting the amount of Title IV grant or loan assistance not returned due to the return of Title IV funds (R2T4) CARES Act provisions, ED plans to make changes to its R2T4 calculator in COD to allow schools to perform an RT24 calculation specifically for aid recipients who withdrew due to coronavirus-related circumstances. Although standing ED policy has been that use of its COD R2T4 calculator is optional, schools will be required to use the calculator for all aid recipients who withdrew due to COVID-19.

NASFAA has reached out to ED staff to express concern that this will greatly increase R2T4 administrative work. Institutions that elect to use their own internal R2T4 calculations will have to re-do their R2T4 calculations in the ED R2T4 tool, and institutions that have already completed R2T4 calculations in the ED tool will have to revisit their previously completed calculations once ED implements changes to the tool in September. 

Kruger said to accomplish the monumental task, it would require a massive effort from multiple staff members.

“I have one person dedicated to R2T4 at my institution,” Kruger said. “I'm going to have to pull in a team of four or five people because I can't just have them stop all the work for four weeks and enter all this data.”

The burden will vary for different schools, with community colleges and other two-year institutions likely facing a much more significant rate of dropouts due to the demographics of their student populations.

Christina Tangalakis, associate dean of student financial aid services at Glendale Community College in California, described having her staff manually entering all the data without a batch process as “not just burdensome, but quite impossible.”

“We already had to do a complete standstill and pivot when CARES money came, and that was two or three months of a heavy lift for us,” she said, noting that her institution saw more than 1,000 students withdraw in the spring. “So now we're behind the ball on that, and now we're going to be behind again due to this burdensome, manual process because they haven't built in a batch process.”

Both Tangalakis and Kruger expressed frustration at the lack of clarity from the department, particularly noting that August is one of the busiest times of the year for their offices.

“There used to be a civility or a camaraderie, some type of fellowship between [ED] and schools, and I feel like that's all breaking down,” Tangalakis said. “I feel like they're setting up impossible goals and then they're going to play ‘gotcha’ when we can't jump as high as they want us to jump, as fast as they want us to jump. All this is doable, it's just not doable right now.”

Kruger said he would take a wait-and-see approach until a firm deadline is announced and is hoping for a possible batch process option to come in the near future.

“I'm not pulling staff off the frontline right now. We're just starting to reopen our campus and we're seeing students and a lot of people hurting right now,” he said. “I'd rather hold off for a couple weeks on this, see if anything changes, and/or wait to see what the deadline looks like before we really start processing this.”


Publication Date: 8/11/2020

Julie A | 8/14/2020 11:47:43 AM

Yet another fine example of Financial Aid Administrators required to carry the burden with fewer and fewer resources.

Ahmed J | 8/11/2020 11:53:17 AM

On the other hand, ED has not announced anything on Coronavirus indicator process for Edexpress users.

Jeff A | 8/11/2020 10:22:28 AM

We are a year-round school with 12,000 students. WE CAN"T GET THIS DONE WITH A MANUAL PROCESS!!!!!!
Are you kidding?

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