Background

On July 6, 2012 President Obama signed into Public Law 112-141, the elimination of the subsidy on Direct Subsidized Stafford Loans when a “first-time borrower” enrollment exceeds 150% of the published program length (150% Direct Subsidized Loan Limit Electronic Announcement #1). The Department of Education has set a limit to the length of time a student may borrow subsidized funds.  Subsidized Usage Limit Applies, or SULA, is used to describe this new regulation and is measured in time, not dollar amounts.

SULA:

• Limits the length of time a student borrower may enjoy the subsidy on a Direct Loan
• Intent is to encourage students to progress through their academic programs in a timely manner
• Intent is to save money

Consequences

• Eligibility Loss:  After the borrower has received Direct Subsidized Loans for 150% of the current program length, borrower loses eligibility for additional Direct Subsidized Loans
• Interest Subsidy Loss:  Loss of interest subsidy on Direct Subsidized Loans the student already owns, if the borrower doesn’t complete the program and enrolls in a program of equal or shorter length.

First-time borrowers under SULA 

• A first-time borrower is defined as "A student who has no outstanding balance on a FFEL or Direct Loan when receiving a Direct Loan on or after July 1, 2013"
• Example:
  • Student has never borrowed before
  • Student enrolls in August 2013
  • Student receives a Direct Loan
  • Student is a first-time borrower
• Example 2:
  • Student received Direct Loans prior to July 1, 2013
  • Student paid off the loan in 2015
  • Student enrolls in 2017
  • Student receives a new Direct Loan in 2017
  • Student is a first-time borrower

25677758

Definitions and Calculations

Academic Year as defined for SULA/Title IV purposes:  The Academic Year Length for Direct Subsidized Loans is the number of days between and including the Academic Year Begin Date and Academic Year End Date submitted. Used to determine direct loan annual limits for BBAY and SAY.

Clock Hour:

Minimum of 900 clock hours and 26 weeks of instruction

Credit Hour: 

Minimum of 24 semester/36 quarter credit hours and 30 weeks of instruction.  

Note: R8 should use the Academic Year as defined in each program’s configuration

Program Length: Converting Months/Weeks to Years:  If the program’s published length is in months or weeks, ED will convert it to years or portions of years.

Month = 30 days

Week = 7 days

Used in 25677758 and 25677758

Loan Period as defined for SULA:  The Loan Period Length is the period of time between and including the Financial Award Begin and End dates. The Subsidized Usage Period for a DL Subsidized loan is a ratio between the Loan Period Length and the Academic Year Length, prorated by Enrollment Status. Changes to the Loan Period Length will cause a change to the Subsidized Usage Period.

Example:  A student has 3 DL Subsidized loans each with different and overlapping loan periods. The Loan Period Length will be calculated as follows:

Payment Period Length

For Direct Subsidized Loan awards that have enrollment statuses that vary across disbursements, it is necessary to calculate the payment period Subsidized Usage for each disbursement in order to calculate the Subsidized Usage Period for the entire Direct Subsidized Loan award.  (When a student’s enrollment is consistent across an award’s payment periods COD is able to calculate subsidized eligibility at the subsidized award level using Loan Period Length.) When the enrollment statuses vary across the award’s disbursements, the Actual Subsidized Usage Period is the sum of the payment period Subsidized Usage Periods.

Maximum Eligibility Period (MEP)

MEP is 150% of the published length of the student’s current or upcoming academic program.   Calculated by ED using school reported information of disbursement records and the published length of the student’s program. Measured in years.

Example 1:  A student receives 5 full years of Direct Subsidized Loans while enrolled in a 4-year BA program. 

MEP = 4 years x 1.5 =  6 years 

Example 2:  Student is enrolled in a 2 year program.  

MEP = 2 x 1.5 =  3 years

Subsidized Usage Period (SUP)

SUP is the total number of academic year’s, or portions of academic years, the student has received subsidized funds.  Calculated by ED 'loan by loan' and rounded up or down to the nearest tenth of a year.    

Credit Hour Example:  Semester-based program, scheduled AY includes the fall and spring semesters.  Student receives a one term loan for fall only. 

Subsidized Usage Period = 117/264 = .44 Years Rounded to .4 Years

Clock Hour Example:  600 clock hours and 20 weeks of instruction.  Scheduled AY is 900 clock hours and 26 weeks of instruction. Student receives a subsidized DL for the program.

Subsidized Usage Period = 140/182 = .76 years rounded to .8 years

There are two exceptions to the SUP formula above: Enrollment Status Exception and Annual Loan Limit Exception

SUP Calculation Exceptions

Enrollment Status: Enrollment Status is factored into the SUP calculation. Enrollment Status can be one of the following:

• • Full time = 1.00
  • ¾ time = 0.75
  • ½ time = 0.50
  • What about less than half time enrollment?  Would that be .25?  Or does the student have to be enrolled at least half time to be eligible for DL?
  • To receive subsidized funds, the student has to be at least half-time.

If the enrollment status is consistent across all the disbursements, the SUP can be calculated as follows:

Half-time enrollment example:

Program is semester-based. Scheduled academic year includes the fall and spring semesters. Student receives loan for both semesters while enrolled half-time for both semesters.

Subsidized Usage Period = 264/264 = 1.00 Year > Prorate > 0.50 Years (because the student is only half time).

If the enrollment status varied across multiple disbursements (Would these actually be AwardDisbursements in R8?  Do we mean PPs here?), we would have to calculate a SUP for each disbursement and then add them all up.  

Example:

A student is enrolled full-time at a 4 year program. AY length is 258 days and LP length is also 258 days. After the first AY, the student decided to convert to half-time and only attended AY2 as half-time.  At the beginning of AY3, what is the current lifetime SUP, and how much eligibility remains?

MEP = 4 x 1.5 = 6 years

AY 1 SUP = 258/258 * 1 = SUP of 1

AY2 SUP = 258/258 * .5 = SUP of .5

Lifetime Current SUP = AY1 SUP + AY2 SUP =  1.5

REP = 6 - 1.5 = 4.5 

This is a simple example, but if enrollment varied between disbursements it would be the same calculation, except for using PP lengths rather than LP lengths.

Annual Loan Limit Example 

This exception is applied to borrowers who received a Direct Subsidized Loan in the amount of the annual loan limit for a period of less than an academic year. A borrower has a Subsidized Usage Period of 1 year, even though the loan is received for a period of less than an academic year. 

If a borrower borrows the full annual loan limit and receives the funds over a time period that’s less than 1 AY, SUP will always be 1 year.

Borrow full annual loan limit  +  Received for less than 1 AY  =  Subsidized Usage Period of 1 year

*Note: Can only occur for standard-term programs or for non-standard-term programs with terms that are substantially equal and are each at least nine weeks in length.

Example: A borrower is enrolled in a standard-term credit hour program and received a Direct Subsidized Loan in the amount of $3,500 for one term as a first-year student. The borrower's Subsidized Usage Period is 1.0 years, instead of 0.5 years, because the borrower received the Direct Subsidized Loan in the amount of the annual loan limit for a period of less than an academic year.

Subsidized Usage Period = 117/264 = 0.44 Years (would be normally rounded up to .5 Years) à Annual Loan Limit à 1.00 Year (Final Result)

Example #2:  

• • REP is one half of an AY
  • Student attends a standard, 2 semesters per AY school and is always full-time.
  • We are packaging a new Fall/Spring AY and the student is a Senior
  • Student is SULA eligible for only half a year, so we package a Fall-only loan.
  • Need analysis shows unmet need of $5500 for Fall, so the student is eligible for a full GL 04 loan.
  • But, if we award the student a full annual limit for Fall, this counts as a full AY for SUP, and the student is not eligible for this.
  • We must award the student $5499 (one dollar less) so SUP can be .5 AY. If we award the full $5500, SUP will be 1 and our REP is only .5, so COD will reject the loan.
    
    

Note: If both exceptions are at play, they will BOTH apply.  First, the annual loan limit exception will be applied, and then the part time exception will be applied.  Clock hour and Non-term credit hour students are all considered to be full time for this purpose.

Example: A borrower was enrolled half-time in a standard-term credit hour program and received a Direct Subsidized Loan in the amount of $3,500 for one term as a first-year student, the borrower's Subsidized Usage Period would be 1.0 years, because of the annual loan limit exception. However, now we factor in the half-time status so the final result is SUP = .5 years.

Remaining Eligibility Period (REP):  Refers to how much eligibility a borrower has left under the 150% limit.  Calculated by ED using school reported information. Accounts for Direct Subsidized Loans received for all enrollment in all programs (except teacher certification programs). Eligibility is lost when REP is 0 or less. 

Example 1: Student receives 5 full years of Direct Subsidized Loans while enrolled in a 4-year BA program

Example 2:  Student receives 3 full years of Direct Subsidized Loans while enrolled in a 2 year program. Student then transfers to a 4 year program.

Example 3: Student receives 1 year of subsidized monies while enrolled in a 2 year program.  Student then transfers to a 1 year clock-hour program.  

       *Note:  Minimum loan period length in a clock hour program is lesser of the AY, the full program, or the final remaining period of study. School cannot disburse a subsidized loan to this student. 

Example 4: Student received 6 years of subsidized loans while enrolled in a 4 year program.  Student did not complete the program and enrolls for a 7th year.

Example 5:  Student is enrolled in a 2 year program and received 3 years of subsidized loans.  Student enrolls for one more semester in the same program and then transfers to a 4 year program.

Example 6:  Student received 5 years of Subsidized Loans while enrolled in a 4-year program. Student completes the program and then enrolls in a 2-year program. 

When REP is < 1

Example: Student receives 5.5 year of Direct Subsidized Loans while enrolled in a 4-year program.  Student has always been a Part time student. This is a semester-based program. Can the school award Subsidized funds?

If REP is < 1, the answer is Maybe.

• • Is enrollment Half time, then Yes.  Must Originate with ½ Enrollment

  • Is enrollment ¾ time or Full time, then No for AY.  Only eligible for Unsub.

Example: Student receives 5.5 years of Direct Subsidized Loans while enrolled in a 4-year program.  Student is enrolled full time. This is a semester-based program. Can a school award Subsidized funds for another AY? The REP is .5

If REP is < usage in the semester the answer is Maybe.

Cannot award full Sub Amount or SUP = 1

In this example:

• • • Sub loan Fall only: Usage = .4  LP=Fall AY Fall/Spring
    •  Unsub loan for the Spring LP=Spring AY Fall/Spring

If a student has a REP that’s less than the minimum length of the loan period, the student cannot receive a Subsidized loan, but the school can originate an Unsubsidized loan for the full amount of the student’s eligibility – the base amount plus the appropriate additional Direct Unsubsidized Loan amount. This is similar to the circumstance in which a student who has reached his or her maximum aggregate subsidized loan eligibility and therefore is eligible for only Direct Unsubsidized Loans.

Minimum Loan Period

•  For credit-hour, standard-term or non-standard term SE9W programs, minimum loan period is a single academic term

•  For clock-hour, non-term or non-standard term NSE9W programs, minimum loan period is the shortest of the following three periods:

• The length of the student's program at the school
• The remaining portion of the program when the program exceeds the school's academic year
• The academic year as defined by the school

Special Programs

There are SULA-related exceptions when students enroll in certain coursework or special admission degree programs.

The following Special Programs are impacted (defined under Special Program field in Program Setup in R8)

• Non-Credential Teacher Certification Program (<SpecialProgram> = T in COD Export/Import)
• Preparatory Coursework Undergraduate Program (<SpecialProgram> = P in COD Export/Import)
• Preparatory Coursework Graduate Professional Program (<SpecialProgram> = U in COD Export/Import)
• Selective Admission Associate Degree Program – ED assigns a MEP of six years
  • Schools to report: Program length of four years and Special Programs Flag = “A”
• Bachelor’s Degree Completion Program – ED assigns a MEP of six years
  • Schools are to report: Program length of four years and Special Programs Flag = “B”

Teacher Certification Program

• Programs that do not lead to a degree/certificate at institution, but lead to State credential that is required for teaching
• Subsidized Usage Periods from non-teacher certification programs do not count against maximum eligibility period for teacher certification programs
• Subsidized Usage Periods from teacher certification programs do not count against maximum eligibility period for other programs

Borrower cannot lose interest subsidy by enrolling

• Loans received for other undergraduate enrollment do not lose subsidy upon enrollment in teacher certification program
• Loans received for teacher certification program can never lose subsidy, even upon enrollment in regular undergraduate program

Example: Thomas used six year of Direct Subsidized loan eligibility to complete 4 year program, and then he enrolled in a one-year teacher certification program. Is he eligible for more subsidized loans?

6 year MEP – 6 year SUP = 0 REP

1-year TC program results in a 1.5 MEP à Yes, school can award Subsidized Loan

Used in 25677758

Undergraduate Preparatory Coursework

• Subsidized loans received will count toward MEP for undergraduate program.
• MEP for undergraduate program is not extended.

Example: Jonah enrolled in one year of preparatory coursework and received a subsidized loan. After that he enrolled in 2-year undergraduate program.

UG Prep Coursework = 1 year SUP

At the start of the 2-year program = 3 year MEP – 1 year SUP = 2 year REP

Graduate Preparatory Coursework

MEP is based on length of most recent undergraduate program for which student received subsidized loans

Borrowers who exceed the MEP will:

• Not lose interest subsidy on previously obtained loans.
• Lose subsidized loan eligibility for remainder of current coursework

Example: Carla used six years of Direct Subsidized loan eligibility to complete a four-year program. After completion, she enrolled in graduate preparatory coursework.

6-year MEP – 6 year SUP = 0 REP

– No eligibility for subsidized loans; still may qualify for unsubsidized loans.

– No loss of interest subsidy on prior loans.

Subsidy Loss

Interest accrued before subsidy loss is ED’s responsibility, but new interest accrued after subsidy loss will be the borrower’s responsibility. This usually happens when a student enrolls in a new program without completing the prior program. Subsidy loss occurs based on enrollment, not borrowing or requesting aid and is effective on the date of the triggering enrollment.

What does NOT cause Subsidy Loss?

• Enrollment in preparatory coursework necessary for enrollment in a graduate or professional program
• Enrollment in a teacher certification program where the school does not award an academic credential

Subsidized DL that has lost subsidy is still considered a subsidized loan

• • Does not become an unsubsidized loan 
  • Important for calculating aggregate DL limits

Because subsidy loss affects the repayment side, not the awarding/disbursing side, R8 does not need to be concerned with subsidy loss.

SULA Data availability timeline

Please see a sample the SULA ISIR COD & NSLDS timeline

Can RNA award subsidized funds?

Get Program Length (PL) 25677758

MEP = PL * 1.5

At the start of packaging:

Sum Actual SUPs will be some non-zero value from an ISIR/NSLDS/COD file

Sum Anticipated SUPs will be = 0 at the start of packaging. 

Calculate REP: REP = MEP – ( Sum Actual SUPs + Sum Anticipated SUPs) 

Is REP > 1 ?

If REP >= 1,  Yes, award sub for a full AY. Sum Anticipated SUPs is now increased by 1.

Else if REP > 0 And REP < 1 (less than a full AY of REP remains).

Need to calculate Anticipated SUP for all remaining future loan periods in this AY.

Break down each future loan period into separate payment periods and calculate SUP for each PP. Check to see if any exceptions apply first.

Anticipated SUP for the payment period = Enrollment Status x (Payment Period length in days /Academic Year length in days)

Round up/down (Standard Rounding?) to the nearest tenth of the year ((Payment Period days / AY days) * Enrollment Status) Yes, Standard Rounding - .44 will be rounded to .4, .45 will round to .5

Add Anticipated SUP for this PP to the Sum Anticipated SUPs and go to the next payment period

If Anticipated SUP <= REP

   Award sub for the payment period but not for the full AY. Check unsub eligibility and award unsub for the next payment period

Else

           Cannot award sub at all. Check eligibility for unsub and award unsub

End

Else Rep <= 0, No, check unsub eligibility and award unsub

Repeat until end of program has been reached.

Example:

• Student is enrolled in a program that is 2 academic years in length.
• Academic Structure is BBAY2 with 3 quarters per BBAY
• 150% of program is MEP of 3 academic years.
• Student previously received DL Subsidized for calculated SUP of 1.5 years and SULA applies.
• Student may receive FT DL Subsidized for only 1.5 additional academic years.
• First year at our school is 100%
• 50% of a year remains.
• Student may borrow for one quarter (term) of the second BBAY, as a loan period cannot end in the middle of a term.
• Student's second BBAY would be DL Sub for 1 quarter, and Unsub for 2 quarters. 
• As for the amount of the Sub in the second BBAY:
  • If a full annual award is made in a single term, that counts as a full AY, Therefore if REP is < 1, we cannot award the full annual amount, but we CAN award $1 less.
  • Example:
    • Need analysis shows unmet need of $5500 for Fall, so the student is eligible for a full GL 04 loan.
    • But, if we award the student a full annual limit for Fall, this counts as a full AY for SUP, and the student is not eligible for this.
    • Award $5499 for Fall, as it will calculate as half a year

RNA Packaging step-by-step workflow

The files will come in this order: ISIR first, followed by FA history file (NSLDS) and then finally COD responses. Once we start receiving COD responses we will continue using the Actual SUPs value from the COD responses going forward. 

When SUP = 0 -  student has never borrowed subsidized funds, or has borrowed funds and paid them off (first-time borrowers)

• First time borrowers (25677758) are identified by the ‘Subsidized Usage Limit Applies Flag’ (SULA) Flag. This flag indicates which students are subject to the new regulations limiting the maximum period of time (measured in academic years) that a student can receive DL Sub loans.
• The SULA flag displays the value Y for Yes or N for No. SULA Flag can be found
  • 15-16 ISIR field position 436 
  • 14-15 ISIR field position 444
• Prior to awarding DL Sub funds, RNA will check the ‘Subsidized Usage Limit Applies’ Flag on the ISIR   
• If the student is subject to SULA and has never received subsidized funds, the SUP value on the ISIR will be = 0.
•   If SULA flag is set to "Yes", RNA will calculate awarding of subsidized funds in the following way:  

1. 1. Take the Program Length (in years) from Program Setup and. This value is listed under "Program Completion" in Program Setup in R8. 25677758 
   2. Calculate the student's MEP = Calculated Published Program Length in Years x 1.5 Note: Check if the 25677758exception applies (that would impact the MEP calculation)
   3. ISIR file contains a value for the SUP. SUP is found on the 15/16 ISIR in field position 437
   4. The SUP value for first-time borrowers should be 0, so RNA is allowed to package the students with subsidized funds all the way through their program of study.
   5. For each payment period the student is expected to attend, calculate the SUP. At the end of the program add all this SUPs together - this is the calculated anticipated total SUP.
   6. Update MEP, REP and SUP on SULA history tab - see REGENT-4930 - Getting issue details... STATUS . Update the actual SUP with the value from the ISIR. 

Program Change
Our MEP calculation should use the program length of the NEW program. For example, if a student was enrolled in a 2-year program and transferred to a 4 year program, their MEP will change from 3 years to 6 years.

Example: 
A full-time student enrolled in a 4 year program would have 6 years of MEP and will be packaged for 6 AYs of DL Sub on the Academic Plan.

After packaging has been completed, RNA should update the calculated values for MEP, REP & SUP, for this student on the SULA history tab - see  REGENT-4930 - Getting issue details... STATUS . 

When SUP is not equal to 0 -  student already received subsidized funds and is subject to SULA

• Prior to awarding subsidized funds, RNA will check the ‘Subsidized Usage Limit Applies’ Flag on the most recent COD RS or SU file response. If the student is subject to SULA and has received subsidized funds, RNA will calculate awarding of subsidized funds in the following way:
• The SULA flag displays the value Y for Yes or N for No.
  • COD RS, SP, SU responses - <SubsidizedUsageLimitApplies> at the <Student> level, 3rd element in the <Response> block
    
    • The COD system calculates SUP, MEP, REP when at least one disbursement for the award is submitted or stored with DRI = ‘True’ (once there is an actual loan disbursement)
      1. Check the value of the SULA flag from the most recent COD file import. If SULA flag is set to "Yes":
      2. If a COD RS or COD SU file has been received, extract the < SumActualSubUsagePeriods> value = SUP and update the Sum Actual Subsidized Usage Period field for this student. 
      3. Take the Program Length (in years) from Program Setup. This value is listed under "Program Completion" in Program Setup in R8. 
      4. Calculate the student's MEP = Calculated Published Program Length in Years x 1.5 Note: Check if the Teacher Certification exception applies (that would impact the MEP calculation)
      5. The <ActualSubUsagePeriod> is the subsidized usage for the loan, while the <SumActualSubUsagePeriods> is the total subsidized usage for the student's lifetime. It includes both disbursements that are DRI = true AND DRI = false.
      6. We have to calculate future SUP starting with the NEXT loan - which is the loan period that comes after the end date of the loan period we just received in the COD response. We know that the response references a specific loan (in the <FinancialAwardID> tag), so our calculations for future eligibility need to start at the start date of the next loan period.
      7. When calculating remaining eligibility, we will need to add the actual sum SUPs value from COD to the Anticipated SUP (or the future SUP) calculated by R8 when calculating sub eligibility into the future. This way we will keep track of both the actual and projected subsidized usage. At the start of the algorithm, the Sum of Anticipated SUPs will be 0 and this number will be updated as RNA progresses through each PP.
      8. Is MEP – (Actual + Anticipated SUPs) > 0?
         • Yes, REP = 1. 
           • Calculate Anticipated SUP for 1 AY. Check for exceptions (enrollment status, annual loan limit)
           • Package the student for a full AY of sub
           • Add +1 to the Sum of Anticipated SUPs. Go to the next LP.
         • Yes, but REP is < 1
           • Check for exceptions (enrollment status, annual loan limit) and calculate anticipated SUP for this PP only. Round up or down to the closest tenth of the year
           • Is Anticipated SUP <= REP?
             • Yes
               • Package the student for sub, only for this PP
               • Add the Anticipated SUP for this PP to the Sum of all Anticipated SUPs and go to the next PP.
             • No, Ancipated SUP for this PP exceeds REP.
               • Cannot package sub for this PP. Only eligible for unsub. The REP has to cover the entire duration of the PP.
         • No, REP is 0 or less, or Anticipated SUP > REP
           • Only eligible for unsub. Do not package sub

Repeat until end of program is reached.

If calculated REP <= 0, do not award subsidized funds. Check eligibility for unsubsidized loans and package unsubsidized funds.
After packaging has been completed RNA should update the calculated values for SUP (sum actual + anticipated SUPs), MEP, REP for this student on the SULA history tab - see  REGENT-4930 - Getting issue details... STATUS .

 SULA information in R8 - wireframes

Case 1: Student is eligible as of last packaged date

Case 2: Student is not eligible as of last packaged date

Determining the correct SULA information source

Originally, we thought to always use SULA information from COD responses if one was available, because once we start receiving COD responses for a student, those COD files will always have the latest subsidized eligibility information. However, in case of re-entry students, if a student leaves a school on R8 and attends other schools using other financial aid software and then comes back, the latest COD file that we would have on file for that student in R8 would be out of date (because the student could have received awards at other schools). The new ISIR/NSLDS files that are generated when the student returns to the R8 school will have more up to date SULA data. The other exception to the rule are students in schools that are switching to use R8 from other financial aid software - we would have a set of rebuild files with the student's financial history which are going to be more current than the ISIR.

• Student receives loans in R8, leaves the school and gets loans elsewhere, and then returns to the R8 school.  The ISIR SUP may include loans not included in the last COD SUP.
•  Rebuild loans – is there a SUP in the rebuild file?  If not, until we process a loan to COD from R8, we’ll have to use ISIR/NSLDS information – I think we can assume that any loans with the first disbursement before the ISIR process date or the NSLDS file date are included in the SUP.
• The odd loan that is processed completely outside the system – perhaps a refund/truncation for a prior FAY loan processed from a legacy system – these should be very few/far between…don’t know if there is a solution other than to wait for the first/next R8 COD Response file.

Scenario: Regular student - NSLDS file is available
Student enrolls in an R8 school and files a FAFSA. We receive an ISIR, then an NSLDS file, and then finally a COD file.

Scenario: Regular student - no NSLDS file
Student enrolls in an R8 school and files a FAFSA. We receive an ISIR, and later a COD response file.

Scenario: Rebuilds
A new school adopts R8. All the students at the school have rebuild files for this school allowing R8 to reconstruct their financial aid history. We will always have the ISIRs for those student, but the rebuild data in almost all cases will be more recent than the ISIR data when it comes to current and historical awards during the rebuild/conversion process. The rebuild file only has loans from the specific school.

Scenario: Re-entry student
Student attended an R8 school for 2 years, then left and went to another school. The student filed a FAFSA, borrowed a couple subsidized loans, and used up 5 years of subsidized eligibility. The student returned back to the R8 school and signed up for a 2 year program. If we use SULA data from the old COD response it would be incorrect. We have to use the student's newly generated ISIR or NSLDS file. We cannot rely on the inevitable COD rejection because the student should be packaged correctly in order to know whether they can even afford to attend the R8 school. This re-entry scenario is very common

Before we can start calculating Sub eligibility we will first need to determine the correct SULA file source: 

1. For regular active students that start out and remain in R8....
   • Use the data from the COD response if one is available
   • If not, use either the ISIR or NSLDS (whichever is the most recent - going by file generated date, and NOT the date the file was loaded into R8).
   • Once a COD response has been received, always use SULA data from COD responses when packaging that student
2. For rebuild students....
   • If we have a rebuild file (meaning the student received loans from the school before the conversion to R8), we can use SULA data from the rebuild file until we receive a newly generated COD response.
   • Once a new COD response has been received, keep using COD responses going forward
   • If ISIR/NSLDS files are available for rebuild students, they will not be as current as the rebuild data.
3. For re-entry students....
   • If a student has been identified as a re-entry student ( as defined in REGENT-9200), we will use the most recent file source (ISIR, NSLDS, COD) we have on file for them. We may already have an older COD response, but because for re-entry students ISIR/NSLDS data will be more current we need to use the most recent file going by the file generated ate, and NOT the date the file was loaded into R8.

Using SUP values from ISIR files

Prior to awarding subsidized funds, RNA will check the ‘Subsidized Usage Limit Applies’ Flag:

1. If SULA flag is set to "Yes", RNA will calculate awarding of subsidized funds in the following way:
   • Extract the SUP value: the ISIR file contains a value for the SUP - "Subsidized Usage Period" (SUP).
     • SUP is found on the 15/16 ISIR in field position 437
   • Extract the ISIR file date value: This is the value of the ISIR Transaction Process Date field stored in the ISIRRecordData.TransactionProcessedDate column.
   • Check the value of the SUP. If the ISIR SUP is 0 - meaning the student has never borrowed subsidized funds, or has borrowed funds and paid them off....
     • Then the student can be packaged with subsidized loans (if they are eligible) until the end of their program according to the rules in REGENT-9267.
   • If the SUP is not 0, indicating that the student has outstanding subsidized loans....
     • Assume that any loans in R8 with the at least one disbursement (DRI = true) before the ISIR Transaction Process Date (the file date of the ISIR) are included in the SUP from the ISIR file
     • RNA will start calculating projected future SUPs for loan periods with first disbursement AFTER the ISIR Transaction Process Date from the ISIR file.
     • Then package the student according to the 150% rule according to the rules in REGENT-9269, using the SUP value from the ISIR and the ISIR file date.
2. If SULA flag is set to "No" or there is no SULA information in the system...
   • Then package the student without accounting for the 150% subsidized eligibility rule.
   • Wipe out data from the SULA columns:
     • Set the SULAEligibilityStatus to NULL
     • Set the SULASubsidizedEligibilityExpirationDate to NULL
     • Set the remainingEligibilityPeriod to NULL
   • Hide the "SULA at a glance" section on the History tab

Using SUP values from NSLDS files

Prior to awarding subsidized funds, RNA will check the ‘Subsidized Usage Limit Applies’ Flag:

1. If SULA flag is set to "Yes", RNA will calculate awarding of subsidized funds in the following way:
   • Extract the SUP value: the NSLDS file contains a value for the SUP - "Subsidized Usage Period" (SUP).
     • SUP can be found in the 'NSLDS_TMSFAHType1AggregatePerkins' table, 'subsidizedLimitEligibilityUsed' field (and is found in field position 467 of the TSM Alert/FAH Detail Record Type 1 - Aggregate, Perkins, Flags Record)
   • Extract the NSLDS file date value: This is the value of the NSLDS_TMSFAHHeader.alertOrFAHDate column
   • Check the value of the SUP. If the NSLDS SUP is 0 - meaning the student has never borrowed subsidized funds, or has borrowed funds and paid them off....
     • Then the student can be packaged with subsidized loans (if they are eligible) until the end of their program according to the rules in REGENT-9267.
   • If the SUP is not 0, indicating that the student has outstanding subsidized loans....
     • Assume that any loans in R8 with the at least one disbursement (DRI = true) before the NSLDS file date are included in the SUP from the NSLDS file
     • RNA will start calculating projected future SUPs for loan periods with first disbursement AFTER the NSLDS File date from the NSLDS file.
     • Then package the student according to the 150% rule according to the rules in REGENT-9269, using the SUP value from the NSLDS file and the NSLDS file date.
2. If SULA flag is set to "No" or there is no SULA information in the system...
   • Then package the student without accounting for the 150% subsidized eligibility rule.
   • Wipe out data from the SULA columns:
     • Set the SULAEligibilityStatus to NULL
     • Set the SULASubsidizedEligibilityExpirationDate to NULL
     • Set the remainingEligibilityPeriod to NUL
   • Hide the "SULA at a glance" section on the History tab

Using SUP values from COD files  (RS, WB, SU)

1. If SULA flag is set to "Yes", RNA will calculate awarding of subsidized funds in the following way:
   • Extract the SUP value: Lifetime SUP is found in the 'CODStudent' table, 'responseSumActualSubUsagePeriods' field
     • <SumActualSubUsagePeriods> tag on COD RS, WB and SU response file types) - This tag is in the student-level response block, NOT in the award-level response block
   • Extract the COD file date. This will be located in the "Process Date" on the COD response.
   • Check the value of the SUP. If the COD SUP is 0 - meaning the student has never borrowed subsidized funds, or has borrowed funds and paid them off....
     • Then the student can be packaged with subsidized loans (if they are eligible) until the end of their program according to the rules in REGENT-9267.
   • If the SUP is not 0, indicating that the student has outstanding subsidized loans....
     • The <SumActualSubUsagePeriods> is the total subsidized usage for the student's lifetime. It includes both disbursements that are DRI = true AND DRI = false (loans that have at least one paid actual disbursement).
     • RNA will start calculating projected future SUPs for loan periods with first disbursement AFTER the Process Date from the COD response file.
     • Then package the student according to the 150% rule according to the rules in REGENT-9269, using the SUP value from the COD response file and the start date of the next future loan period not included in the COD SUP value.
2. If SULA flag is set to "No" or there is no SULA information in the system...
   • Then package the student without accounting for the 150% subsidized eligibility rule.
   • Wipe out data from the SULA columns:
     • Set the SULAEligibilityStatus to NULL
     • Set the SULASubsidizedEligibilityExpirationDate to NULL
     • Set the remainingEligibilityPeriod to NUL
   • Hide the "SULA at a glance" section on the History tab

Using SUP values from Rebuild files 

COD

Each time the school submits an origination or disbursement record COD will:

• Calculate Subsidized Usage Periods, including the new loan

• Inform school of borrower’s Maximum Eligibility (MEP), Subsidized Usage (SUP), and Remaining Eligibility (REP) periods

• COD will also inform the borrower in a disclosure statement

SME meeting 3/10/2015 followup

• Decided to always use the Actual SUP value from a file source when calculating REP. The files will come in this order: ISIR first, followed by FA history file (NSLDS) and then finally COD responses. Once we start receiving COD responses we will continue using the Actual SUPs value from the COD responses going forward.  
• SUP values are located: 
  
  • ISIR:  "Subsidized Usage Period"  (SUP).  SUP is found on the 15/16 ISIR in field position 437
  • NSLDS: 'NSLDS_TMSFAHType1AggregatePerkins' table, 'subsidizedLimitEligibilityUsed' field (and is found in field position 467 of the TSM Alert/FAH Detail Record Type 1 - Aggregate, Perkins, Flags Record)
  • SUP is found in the 'CODAward' table, 'responseActualSubUsagePeriod' field    (<SumActualSubUsagePeriods> tag on COD RS and SU response file types) 
• Decided to compare our MEP & REP values to the values from COD. If they do not match, create a task for the user to go and review the student. They can adjust enrollment status/loan period dates if they believe that COD data is incorrect.
• Decided to do the SUP calculation on the payment period level, rather than the LP level.
  • All LPs that are not DRI= true count against future sub eligibility when packaging. Each LP will be broken down to payment periods and we will do the SUP calculation for each payment period.
    
• 3 outstanding questions:
  
  • Does <SumActualSubUsagePeriods> from COD only include disbursements with DRI = true?
  • If COD recalculates SUP based on data from R8 (for example, the loan period is truncated due to R2T4) will the response hold the recalculated SUP?
  • If student is in a non-term school, and has less than a full AY eligibility remaining (.5 REP), can we award them a full AY amount? If a full AY amount is awarded in a single term that makes SUP = 1 so that would be rejected by COD. Should RNA award them 1 dollar less than the full AY eligible amount?

Ian's answers to the questions 3/12/2015

• REP is one half of an AY
• Student attends a standard, 2 semesters per AY school and is always full-time.
• We are packaging a new Fall/Spring AY and the student is a Senior
• Student is SULA eligible for only half a year, so we package a Fall-only loan.
• Need analysis shows unmet need of $5500 for Fall, so the student is eligible for a full GL 04 loan.
• But, if we award the student a full annual limit for Fall, this counts as a full AY for SUP, and the student is not eligible for this.
• Should we award $1 less than the full AY amount so the SUP will be calculated as one half of a year? Correct.  
• Also – if unmet need is only $5499 for Fall, we assume we can award this with no problem as it will calculate as half a year - -correct? Correct.   

SULA Calculator

On 03/29/2015, COD published a SULA calculator on COD online.

A user can get to the COD SULA calculator in more than one way:

1. Through the Applicant search
2. The student’s Direct Loans under Person Search
3.  View Person Details 
4. Click Subsidized Usage Search

5. Click Add Award

6. This will not really add the award to the student but you can add a loan/disbursement to see what the usage would equate to

A user can export the results of the COD SULA calculator.xls

1. The top information will show the student detail
2. It will show the calculated usage
3. In the loan detail section the first rows depict if the COD data was added/ or if existing COD loans were adjusted

Test scenarios

1. A COD RS/WB/SU file is received for an existing student with an accepted response for an existing award in the <DLSubsidized> block, containing <SubsidizedUsageLimitApplies> = false
   1. The student is packaged as normal without taking the 150% rule into account.
   2. Show the "Program Information Reported to COD"
   3. Hide the "SULA at a glance" section
   4. Show the SULA Data Sources section - we should see a "No" in the SULA flag column
2. No COD/ISIR/NSLDS files have been received for this student. We don't know whether SULA applies
   1. The student is packaged as normal without taking the 150% rule into account.
   2. Show the "Program Information Reported to COD"
   3. Hide the "SULA at a glance" section
   4. Show the SULA Data Sources section - we should see a "No" in the SULA flag column
3. A COD RS/WB/SU file is received for an existing student an accepted response for an existing award, containing <SubsidizedUsageLimitApplies> = true and <SumActualSubUsagePeriods> = 1.0
   1. The SULA Information grid should be updated with the new values for SULA flag, SUP, REP & MEP from the COD file
   2. The SULA information section should always have the current value for MEP - (Program Completion in years X 1.5)
   3. The "Last packaged on" date will only change after the student has been packaged
   4. During packaging, RNA will compute whether student is eligible for subsidized loans, the eligibility cut off date and update the SULA information section
   5. The academic plan of the student should be updated and should reflect the cutoff date and the student should not be packaged for subsidized loans after the sub eligibility cut off date
4. A COD RS/WB/SU file is received for an existing student an accepted response for an existing award, containing <SubsidizedUsageLimitApplies> = true and <SumActualSubUsagePeriods> = 0
   
   1. The SULA Information grid should be updated with the new values for SULA flag, SUP, REP & MEP from the COD file 
   2. The SULA information section should always have the current value for MEP - (Program Completion in years X 1.5)
   3. The "Last packaged on" date will only change after the student has been packaged
   4. During packaging, RNA can package the student with subsidized loans until the end of the program (if they are eligible). The eligibility cut off date will be the end of the student's program. This information should be updated on the SULA information section.
   5. The academic plan of the student should be updated