Are Schools Required To Report Federal Work-Study Earnings To COD?

Award Year: 2024-25 KA-36470 Helpfulness Rating 8,683 page views

This guidance is specific to the 2024-25 award year and later.

This AskRegs Knowledgebase Q&A was updated on August 16, 2023 to include guidance from the U.S. Department of Education’s (ED’s) July 21, 2023 Electronic Announcement (CB-23-13). For additional information on reporting requirements, refer to Volume 4 of the COD Technical Reference.

Yes. Beginning with the 2024-25 award year, schools are required to report to the Common Origination and Disbursement (COD) System cumulative calendar year Federal Work-Study (FWS) Program earnings on an individual student basis. This means schools are required to report 2022 calendar year FWS earnings before the start of 2024-25 application processing cycle. After that, this will be an annual reporting requirement.

While reporting is mandatory for the 2024-25 award year, institutions may choose to report FWS data to COD beginning July 1, 2023 provided they are using schema version 1.0a.

Unlike most other Title IV reporting, FWS earnings will be reported for the calendar year and not for the award year. “Calendar year” means the school must report FWS earnings for January 1, 2022 through December 31, 2022--that is the tax year used as prior-prior-year income on the 2024-25 FAFSA. For example, even if the school's spring and summer terms fall in one award year, and the fall term falls in another award year, the school will report calendar year 2022 earnings, which will contain earnings from two award years. Schools should already have processes in place to report calendar year earnings for tax purposes (i.e., W-2 reporting); this is the same wage information that will need to be reported to COD.

Under need analysis changes made by the FAFSA Simplification Act for the 2024-25 award year and beyond, excludable income will consist of only education tax credits, taxable grants and scholarships, and FWS earnings. Therefore, the new COD schema will only be collecting prior-prior-year (2022) FWS earnings so that those FWS earnings can then be excluded from income during the calculation of the 2024-25 student aid index (SAI).

COD includes a new campus-based schema making it possible for  the FAFSA Processing System (FPS, formerly the Central Processing System) to pull FWS earnings from COD into the FAFSA. The FWS earnings data will then be used in calculating the SAI and be reflected on the student’s Institutional Student Information Record (ISIR).

During the 2022 FSA Training Conference, ED provided answers to some of the many questions schools have about this new process, as follows (questions and answers are not direct quotes and have been updated with more recent guidance as noted above):

Question: What is the deadline for schools to report 2022 FWS earnings?

Answer: See AskRegs Knowledgebase Q&A, What Is the Deadline For Reporting 2022 FWS Earnings To COD For the 2024-25 Award Year? 

Question: What data must schools report?

Answer: Schools must report gross FWS wage earnings on a student-specific basis—that is, actual earnings before taxes and not the amount of the FWS award. The earnings amount that is reported will include the combined federal and institutional shares that make up those earnings. Only FWS earnings are reported—not institutional work-study, state work-study, cooperative education earnings, or other non-FWS earnings.

In addition to the total FWS earnings per student, the following data elements are required:

Additional optional information also may be reported. Refer to the COD Technical Reference, Volume 4.

Question: Will there be a process for schools to batch report student FWS earnings?

Answer: Yes, there will be a batch process much like other existing COD processes. Schools will submit batch FWS earnings data using the Campus-Based XML Schema version 1.0a, or via the COD website. EDExpress will also allow for batch reporting using the Campus-Based schema version 1.0a. There will not be an option to upload an Excel or CSV file.

Question: Will FWS wages be reported as they are earned throughout the year, or on a cumulative basis at the end of the calendar year?

Answer: Cumulative earnings will be reported one-time each year, before the release of the of the FAFSA to ensure that earnings information is available. Schools will have the option to report using one of two methods: “Calendar Year Totals by Award Year” or “Calendar Year Total Amount only”. Earnings will not be reported on a pay-period by pay-period basis. CB-23-13 explains the differences in reporting by calendar year versus award year.

Question: Why can't ED just retrieve FWS earnings directly from the IRS?

Answer: Although the IRS has a student’s wage information for all of his, her, or their jobs, the IRS does not have FWS-specific information. For example, if a student has both FWS earnings and other student employment earnings at your institution reported on the same W-2 as required, the IRS has no way to distinguish between the two; therefore, ED cannot pull FWS earnings from the IRS into the FAFSA.

Question: Our W-2 forms report the combined FWS and institutional work-study employment. Will we be required to separate the amounts?

Answer: Yes, you will have to separate the FWS wages for purposes of this reporting.

Question: What if a there is a change in a student’s FWS earnings that was not originally reported?

Answer: Schools will be able to submit corrections to previously reported FWS earnings data. Corrected data will be sent to other Federal Student Aid systems (e.g., FPS), and a new ISIR being pushed to the school, if applicable. COD will accept FWS earnings data and corrections for the 2022 calendar year until Sept. 13, 2025, the final date for 2024–25 FAFSA processing. 

Question: Will there be an award year tag in COD?

Answer: Yes. However, the “award year” field is only populated when reporting FWS wage information using the “Calendar Year Total by Award Year” method. Schools reporting calendar year totals only will not report the award year. 

Question: Will students be able to view their FWS earnings in similar to the way they can view their grant or loan history?

Answer: No, not at this time.

Question: For a decentralized university, will each location report FWS earnings separately or will the "main campus" report all students? We report them all on one FISAP.

Answer: Reporting for multiple locations will be allowed, based on the school’s current COD reporting structure. From CB-23-13: “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.” 

Question: What about Federal Supplemental Educational Opportunity Grant (FSEOG) funds? Will we be required to report FSEOG information?

Answer: No, not at this time. The infrastructure is being put in place within the schema in case ED decides to collect FSEOG data in the future (not for 2024-25).

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