Common Origination and Disbursement Update Session Highlights

By Tiffany Gibbs, Compliance Products Manager

The U.S. Department of Education’s (ED) Common Origination and Disbursement System (COD) session covered a number of topics. Highlights appear below.

General: No schema changes for this year and there are no longer common record receipts, only responses.

Subsidized Usage Limit Applies (SULA): ED is still seeing issues and reminding schools to do the following:

  • Reduce remaining anticipated disbursements to zero if no funds will actually be disbursed;
  • Reduce (if applicable) the award amount to match the amount actually disbursed;
  • Adjust the loan period when required;
  • Ensure the academic year matches the loan period on a single-term loan; and
  • The academic year begin and end dates do not match the reported “weeks” in a school’s academic year length.

COD will also include a new correcting edit in its fall release, which should take place in October. Applicable to the 2016-17 and beyond, SULA Warning Edit #219 will correct an award amount down to equal the sum of the actual and anticipated disbursements on a maintenance submission when the loan amount exceeds the sum of the disbursement amounts. Schools will receive a record of the changed loan amount in the response file.

Existing edit #046 will be modified for the 2016-17 award year and forward to trigger when a school’s submitted academic year start and end dates do not equal at least 26 weeks.

New SULA Warning Edit #220, Zero Disbursement Inside Loan Period, covers the 2014-15 award year and forward. It will have two trigger points:

  • When a disbursement is reduce to zero, but the payment period state date remains within the loan period; and
  • When the award begin and/or end date is changed so a disbursement reduced to zero has a payment period start date that remains within the loan period.

The “Zero Disbursement Exception Logic” will also be modified so when a disbursement is reduced to zero and has a payment period start date outside of the loan period, COD will exclude the disbursement from the subsidized usage calculation. The “Loan Limit Exception Logic” will modified to consider a student’s highest grade level The TEACH Agreement to Serve (ATS) website will be integrated into the website will the fall release. The website will also be made “mobile responsive” so the website and components will be fully accessible through cellphones or tablets.

If schools elect not to participate in a process on such as signing of the Master Promissory Note, for example, the school’s name will not display in dropdowns for students to select.

There will also be a Direct PLUS Loan borrower default status check on the PLUS Request Response. The status will be determined from NSLDS data. The existing <Default Overpay> tag will be used to report it in the response file. New value of “E” will be added to the tag which indicates that COD could not obtain a status for the borrower. Schools will have the option to check the COD website directly as well. This will be in place for both Parent PLUS and Grad PLUS borrowers.


Publication Date: 8/1/2016

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