What Should Schools Use To Report FWS Earnings In COD When Payment Periods Cross a Calendar Year?

The July 21, 2023 Electronic Announcement (CB-23-13) provides operational information on reporting to the Common Origination and Disbursement (COD) System using the Campus-Based XML schema version 1.0a. In the guidance provided by the U.S. Department of Education (ED), there are two methods schools may use to report earnings for their Federal Work-Study (FWS) students. Schools may report using:

1. Calendar Year Totals by Award Year, which requires two totals--one amount for the calendar year paid in award year 1 and the remaining amount for the calendar year paid in award year 2; or
2. Calendar Year Total Amount only, which only requires the sum for the full calendar year and no award year data is required.

The total gross amount of all FWS earnings (both federal and institutional share) must be reported to COD consistent with the requirements for reporting gross FWS earnings in Box 1 on the W-2. This includes any non-cash contributions which may include payments toward tuition or living expenses, except any non-cash payments made by a "federally approved Work College for work performed under the comprehensive work-service-learning program." Box 1 reflects gross earnings minus any retirement contributions.

Volume 4 of the COD Technical Reference Guide states:

"Per the IRS guidance, determining the amount of wages to include on the W-2 should be based on when the wages were paid out, not necessarily when the hours were worked. The IRS states the following: The entries on Form W-2 must be based on wages paid during the calendar year. Use Form W-2 for the correct tax year. For example, if the employee worked from December 17, 2023, through December 30, 2023, and the wages for that period were paid on January 2, 2024, include those wages on the 2024 Form W-2."

If reporting using method 1, calendar year totals by award year, see the example below from CB-23-13 of a student who was paid FWS earnings of $300 on each of the listed dates:

When using method 1 for 2022 FWS earnings, the school reports two separate FWS amounts of $900 and $600. The amounts paid in 2021 or 2023 are not reported.

If reporting using method 2, calendar year total amounts only, see the example using the same student: