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

Award Year: 2024-25 KA-36598 Helpfulness Rating 385 page views

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

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:

Award Year

FWS Payment Dates ($300 each)

Total FWS Award Year Compensation Paid

Total 2022 Calendar Year for Award Year

2021-22

10/1/2021

11/1/2021

12/1/2021

1/1/2022

3/1/2022

4/1/2022

$1800

$900

2022-23

10/1/2022

11/1/2022

2/1/2023

2/15/2023

3/1/2023

3/15/2023

4/1/2023

5/1/2023

$2400

$600

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:

FWS Payment Dates ($300 each)

Total 2022 Calendar Year for Award Year

1/1/2022

3/1/2022

4/1/2022

10/1/2022

11/1/2022

$1500

Again, the amounts paid in 2021 and 2023 are omitted, and the school would only include the total the student was paid during the 2022 calendar year.

See AskRegs Knowledgebase article, Are Schools Required To Report Federal Work-Study Earnings To COD? (Award Year: 2024-25) for additional information.

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