Another FAFSA® Simplification Requirement for 2024-2025: Federal College Work Study Reporting to COD

Melissa Maichle .

The delay in the availability of the 2024-2025 FAFSA® will certainly cause complications for many campuses, but for some it is a blessing in disguise since there’s extra time to make the many changes that will be required before students begin to file. One of these is the new Federal College Work Study (FCWS) earnings reporting to the Common Origination and Disbursement system (COD).

FCWS earnings need to be deducted from total earned income for needs analysis purposes and through the 2023-2024 award year, students self-reported the information. Since this information can be collected from the institution administering the FCWS program, the question has been removed from the FAFSA®. Here is what you need to know about the reporting requirements…

Q: For whom must FCWS data be reported?

A: Any student that earned money or received non-monetary compensation (like free room and board, for example) except when the non-monetary compensation is made by a federally approved Work College for work performed under the comprehensive work-service-learning program. Data for students no longer enrolled at your institution must be included. Since students may have worked under FCWS at more than one college during the reporting period, it is possible for a single student to have multiple reports for the same period.

Q: What earnings must be reported?

A: The total (both institutional and federal contributions) gross amount paid or value of non-cash compensation provided to the student during the calendar year used as the base year for FAFSA® filing. So, for 2024-25, it will be calendar year 2022. It does not matter when the student did the work, just when they were paid.

Q: What other data needs to be reported along with the FCWS amount?

A:  Last name, date of birth, Social Security number, CPS transaction number and calendar year

Q: What are the options for submitting the data to COD?

A: One option is via batch submission using the Campus-Based XML Schema version 1.0a. The ability to use batch submission was incorporated into EdExpress for Windows 2023-24, Release 3.0, which was made available in July. Data can also be entered via the COD website directly.

Also, it is recognized that many institutions may store FCWS information by award year rather than calendar year, so there are two options for reporting the total gross earnings. Once a reporting method has been selected, all awards must be reported in the same way going forward. To change methods, all the awards already reported need to be zeroed out and resubmitted using the other method.

  • One total amount for the calendar year
  • Two amounts from the appropriate timeframes within the two award years that comprise the calendar year. For example, a student earned $500 during the 2021-2022 award year during the timeframe January 1, 2022 – June 30, 2022, and $500 during the 2022-2023 award year during the timeframe September 1, 2022 – December 31, 2022.

Q: What if there were errors in our submission?

A: There will be a correction process for award related data that can be processed either via the campus-based schema submission (batch process) or by directly updating COD. Any correction to the student information (name, date of birth, or social security number) must be made via COD common record batch or on the COD website. Corrections to calendar year 2022 data can be submitted up until the final processing date for 2024-25 FAFSA ® processing — September 13, 2025.

Q: Will we be notified of records that are not accepted?

A: Yes. Many of the existing COD reject edits will be modified to apply to campus-based records and there will be two new ones:

  • COD Reject Edit 300 – New FWS Award Submitted using Different Calendar Year or Award Year Reporting Method than Previously Accepted (results when a school changes reporting methods without previously zeroing out awards)
  • COD Reject Edit 301 – Award Received After the End of the FAFSA Processing Year (results when data is submitted too late for processing)

In response to the changes listed above, there will be some changes to the COD website:

There will be new Campus-Based Person, Award and Batch search screens. These screens can be accessed from the existing “Person Search,” or via the Campus-Based System homepage using the new “CB Person Search” link. Campus-Based awards will not be displayed on the existing “COD Award Detail” pages. Campus-Based batches will only be searchable using the new “Campus-Based Batch Search” page. Any user currently enrolled in COD will be able to access this new search functionality.

If you haven’t already, we encourage you to take advantage of the FAFSA ® Simplification resources on the FSA Training website and, of course, follow the Higher Education Assistance Group blog for a deep dive into every facet of the transition. If you need assistance, please contact us at