Disbursements and COD Business Process Analysis (BPA)

Introduction

This Business Process Analysis (BPA) and System Configuration document describes the functionality and configuration settings related to Export Student Transactions (EST) and COD Disbursements in Regent Award. 

This document defines the following associated with disbursements:

  • Expected and Actual EST

  • COD Logic

  • COD Web Response files

  • Pell and Direct Loan Reconciliation

  • Specifications for client-specific configuration of the following:

    • Data requirements

    • Communication

    • User Roles

    • Documents

    • Tasks

    • Additional Configuration

Process Overview

This section describes the default behavior of the Regent Award processes associated with disbursing Title IV and non-Title IV funds.

 

All funds in Regent Award must have a corresponding disbursement schedule, including non-disbursable funds.  Regent Award uses the disbursement schedule configuration criteria to determine the initial disbursement date for the fund when creating the student’s package.  Refer to the Funds BPA for additional information regarding Disbursement Schedules.

Regent Award includes a multi-step process for identifying scheduled disbursements, exporting disbursements to COD and posting to the student’s account. The following processes are described below:

  • Expected EST- Funds that are scheduled but not actually disbursed or paid.

  • Export COD- Origination and submission of funds to COD for approval.

  • EST for DRI- COD funds set to Disbursement Release Indicator (DIR) as true.

  • EST for AR- Paid disbursements to be posted to student accounts. 

Expected EST

Regent Award provides the ability to estimate the funds that could or should post to Student Accounts (AR) in the future. The Expected EST process allows the user to assume eligibility of all scheduled transactions (override eligibility checks) and to select an offset number of days to forecast cash flow. Non-disbursable funds can only appear on the Expected EST, and not on the output for other EST processes. This process does not make any changes to any disbursements, but the file may be used to post anticipated transactions to AR in an equivalent manner to actual transactions, if needed, to support Student Accounts business processes.

Disbursement Process Overview

Regent Award originates and disburses Federal funds via the COD Export/Import process and the EST process. The Regent Award EST process is as follows: 

  1. Run COD for origination process – this step originates COD awards via export to prepare for disbursement. 

  2. Run EST for DRI to set this flag to true – this step sets up awards to prepare the disbursement for export to COD, or to AR if the fund is not a COD fund.

  3. Run COD for disbursement process – this step exports COD fund disbursements to COD for acceptance and imports accepted records into Regent Award.

  4. Run EST for AR – this step marks the disbursement as paid and creates the EST XML for import into Student Accounts and includes all disbursable funds.

Step 1: Origination Process

Federal awards must be in accepted status to be selected for the origination process. Pell and Direct Loans may be selected for origination provided the configured origination date and enrollment criteria for the fund are met. Awards may be declined prior to origination, but once originated the award must be cancelled if the student elects to not accept the funds.

The COD origination and disbursement process can be executed manually from the Export Process menu or via the Saved Parameter Set and Scheduled Processes.  Both originations and disbursements can be selected when running the Export COD process and thus will produce one file.

Incoming response files from COD will be loaded directly into Regent Award via the Import Process menu by staff with appropriate permission or automatically using the Regent SAIG mailbox. If the response file contains accepted Master Promissory Note (MPN) and or Entrance Counseling indicators, Regent Award updates the status of documents configured with the corresponding document use type to ‘Satisfied’.

COD awards may disburse immediately after an accepted origination response is received, provided all other disbursement eligibility checks pass. However, a disbursement is not selected for processing until it passes eligibility checks listed in Step 2 below.  

Steps 2 – 4 of the EST processes should be performed as closely as possible to each other to mitigate a change in student information.

Step 2: EST for DRI Process

Regent Award requires all funds go through the DRI process, including non-COD funds such as FSEOG, Perkins and other non-Title IV disbursable funds. The EST for DRI process sets the DRI to true for the award, which allows the award to be disbursed in Step 3 and/or Step 4, depending on whether the award is a COD fund. 

A disbursement is selected for the EST for DRI process if the:

  • Award has been originated and accepted by COD.

  • Disbursement scheduled date is on or before the current date.

  • Paid disbursement has an increase, i.e. and the award Net Disbursement Amount is greater than the Paid amount (NOTE: When the award amount increases, the award update must be accepted by COD for this process to select the disbursement.)

  • Disbursement transaction type meets the parameters selected during the execution of the EST for DRI process (Positive Transactions Only, Negative Transactions Only, or All).

    • Disbursements with packaging blockers such as a blocking document will not get picked up during the EST process until those blockers are removed. 

    • When Negative Transactions are selected, all negative disbursements will be paid regardless of eligibility checks. 

Only accepted and canceled disbursements are selected for an EST transaction. Accepted disbursements are selected for disbursement as positive transactions. Disbursements that are canceled after they were paid are selected as negative transactions. 

Once a disbursement has been selected for processing via the EST for DRI process, it is validated against built-in eligibility checks based on Federal rules for disbursements. The table below lists all disbursement compliance checks supported by Regent Award.

Compliance Requirement

Configurable / Required

Regent Award Support

Loans

Pell

SEOG

School Status

C

SBL controls the student population sent to R8 as well as the student’s active status.  Inactive students are not disbursed.

N/A

N/A

N/A

Accepted Origination

R

A loan cannot be disbursed until it has been originated and origination response is accepted.

X

X

N/A

Originated prior to Withdrawal (W/D)

C, R

R8 does not initiate an origination if the student has no enrollment or a finalized R2T4.  If an origination was exported prior to W/D and the student W/D prior to the response, R8 will create a ‘Review Loans Originated after Withdrawal’ task to review the origination.

X

X

N/A

Pell Eligible (Graduate Program)

R

R8 does not award or disburse Pell to students in graduate programs or with a prior bachelor’s degree.

N/A

X

N/A

Bachelor Degree Required

R

R8 does not award or disburse Grad PLUS to students in a disqualified program (e.g. bachelor).

X

N/A

N/A

SAP Standing

R

Funds have been configured to require an eligible SAP status on file

X

X

X

Loan EC on File

R

Regent Award does not disburse without entrance counseling document in “Satisfied” status. (A Grad PLUS EC document requirement can be configured to facilitate process).

X

N/A

N/A

Loan MPN

R

Regent Award does not disburse without a linked MPN.

X

N/A

N/A

LTHT Enrollment

R

Regent Award does not award loans for Less Than Half Time (LTHT) enrollment and does not disburse loans on LTHT enrollment.

X

N/A

N/A

ISIR

C

Regent Award requires an ISIR to disburse Federal funds. The ISIR must be clean, i.e. no rejects, not selected, or selected AND verified.

X

X

X

Loan Default

R

Regent Award checks for default information in the ISIR and from NSLDS FAH files, if imported.

X

X

X

Aggerate Loan Limits

R

Regent Award checks for aggregate loan limits and makes award adjustments accordingly.

X

X

X

Pell Overpayment

R

Regent Award triggers a blocking task ‘Review Uncleared Pell Over Payment’ for POPs.

X

X

X

Pell LEU

R

Regent Award checks for Pell LEU and makes award adjustments according to percentage of LEU remaining.

N/A

X

N/A

Attendance

C

Regent Award requires attendance for Federal funds if disbursement is on or after the first day of the term.

X

X

X

 In addition to the above disbursement checks, Regent Award cannot release a disbursement that is blocked due to an open task or document configured to restrict disbursement for the associated scope (i.e. 2020-2021) in a status other than ‘Satisfied’ or ‘Waived’. Students queued for repackaging (i.e. student needs to be repackaged before EST), students on institutional or student-level breaks, and students with a pending ISIR correction will not be selected for EST.

If the disbursement passes all eligibility checks, the internal DRI release date is set and the disbursement can release to COD on the next COD export. This pre-validation process reduces the risk of a disbursement being rejected by COD.  Refer to the Customer Zone Knowledge Base for a full list of EST Validation Error Codes.

Step 3: Export Disbursement to COD Process

Once the disbursement has completed the EST for DRI process, the disbursement is ready to export to COD or post to AR (for non-COD funds). Non-COD awards can be posted to AR as soon as they have been set to DRI=true and are not included on the COD export file (see Step 4). The Export COD process for disbursements communicates the DRI flag to COD and should be performed as soon as possible after selecting the disbursement for DRI (Step 2). 

If a disbursement is rejected by COD, Regent Award will trigger a “Review COD Reject” task for the rejected COD record, the disbursement DRI is set back to false, and the disbursement is not selected for EST for AR. The issue preventing the disbursement from being accepted at COD must be resolved and the disbursement re-exported starting at Step 2. The process reduces the risk of drawing down funds that are not accepted by COD and enables the COD export process to occur daily.

If a negative transaction needs to be updated at COD that transaction will be picked up for export to COD after the transaction has gone through the EST for AR process.

Step 4: EST for AR

The EST for AR process sets the disbursement status as “Paid”, updates the “Paid Amount” and populates the “Release Date” of the disbursement. The disbursement is not considered “Paid” in Regent Award until this step is complete. 

As stated in Step 3, rejected disbursements are not picked up for AR. A disbursement must be accepted by COD to proceed to this step and be pulled into the EST for AR file.  NOTE: There is no additional eligibility check between Step 3 and Step 4, so these steps should be executed as closely together as possible to preclude student changes. To process negative transactions, the negative transaction type must be included in the selection criteria “All or Negative Transactions Only” running the process. The resultant EST for AR export file contains the transaction date and transaction paid = true flag for posting to AR.

If the import fails for any reason and needs to be re-imported on a different day than it was produced, the file can be updated from the process log to reflect the actual posting date for the DRI date on all disbursements associated with that EST for AR export.

This process updates the disbursement release date in Regent Award for each student in the file selected.  Once the disbursement release date is updated, the student will be re-exported to COD (with the next Export to COD process run) with the updated release date. When importing the EST for AR file back into student account system, the date of the actual import will be used as the transaction date for all students in the file.

Non-Disbursable Funds

Non-disbursable funds have a blank disbursement schedule and are not included on the EST for AR export file. However, there is an option to “Include Non-Disbursable Funds” when the Expected EST transactions process is run, which allows for the selection of funds setup as “non-disbursable.” Non-disbursable funds selected for inclusion in this file are included if the award expected disbursement date falls within the selected date parameters.

Disbursement During Breaks

Regent Award provides the ability to restrict disbursement of funds to students that are on breaks of specified types (see Breaks section in the Academic Structure BPA). When this restriction is set for the specified break type and a student is on a break of that type, Regent Award does not disburse funds to the student until the break period is determined to be over. The configuration does not apply to Post Withdrawal Disbursements (PWD) and negative disbursements, which always release when ready.

Disbursement Override

Regent Award provides the ability to override disbursement validation enabling the release of a disbursement that would otherwise not release. Overrides are an exception to the Disbursement Process and are only able to be performed manually on a student-by-student and fund-by-fund basis for users that have the correct permissions.  This functionality permits the immediate release of a disbursement in cases where incorrect data may be holding it up. 

When a disbursement fails validation, Regent Award provides a complete list of the validation errors that would prevent the disbursement from being paid.  Regent Award also provides the option to override those validations, forcing the disbursement to be paid. The user is presented with the option to override any or all validation errors and is required to enter comments regarding the overridden validations for auditing purposes.  After selecting the validation errors to override and correcting other issues for which override is not desired (if any), the disbursement process that failed may be re-run for the award. This action forces the disbursement to be “Paid.” An activity log entry is created with a description showing the disbursement paid because of one or more overrides of specific validation checks, and includes the comments entered by the user. 

Several options exist for the disbursement validation override of an individual award and correspond to the Disbursement Process steps described above permitting override at any point in the process:

  • Run EST for DRI (Step 2)

  • Export to COD (Step 1, Step 3) – enabled only on COD funds

  • Run EST for AR (Step 4)

  • Bypass COD & Run EST for AR – used when Regent Award thinks a disbursement needs to be accepted by COD, but the disbursement is managed directly at COD on the Web.

Disbursement Options

The COD Export process provides the user the ability to select which transactions to send to COD. The user may choose to send only Originations, Disbursement Records, or Negative Transactions Only.  Any or all of these options may be selected. The COD Export process is typically run with both ‘Originations’ and ‘Disbursement Records’ options.

The Export EST process provides several options for student selection as well.

Partition Records into Separate Files

This option allows the user to parse the EST output into separate files partitioned per campus, per FAY, per transaction type, and per configured fund group. The resultant output files will contain only one campus (not site), one FAY, one transaction type and one fund group each. For example, if there are two campuses and the process is run with this option for 16-17 and 17-18 with both positive and negative disbursements, the process would produce 8 output files:

  • 16-17, positive disbursements

  • 17-18, positive disbursements

  • 16-17, negative disbursements

  • 17-18, negative disbursements

  • 16-17, positive disbursements

  • 17-18, positive disbursements

  • 16-17, negative disbursements

  • 17-18, negative disbursements

COD WB Reconciliation Process

Regent Award allows institutions to import paid disbursements from COD WB (Web) Response files and export via the regular EST for AR process or the COD WB Reconciliation Process.  This feature applies to institutions that do not have an external reconciliation process to update their Accounts Receivable (AR) system when disbursements are paid via COD on the Web.  

Institutions can utilize the COD WB Reconciliation Process to determine if each imported disbursement record should or should not be exported on the EST for AR process file.  The EST for AR can be executed from COD WB Reconciliation process by users with applicable permissions.  These disbursements will not undergo any of the normal EST validation checks, and they will always be permitted for export when specified.

Regent Award also includes an Auto Authorize Option for institutions that wish to automate the COD WB Reconciliation process.  This option requires no user intervention to authorize a disbursement record for inclusion in the EST for AR process.  Regent Award will automatically authorize the disbursement transactions for export during the EST for AR process.

COD Web Response Review Queue

The “COD Web Response Review Queue” allows schools to identify all awards imported via a COD Web Responses (WB files.)  Users with the appropriate permissions can view successful and unsuccessful as well as select and reprocess failed WB files.
An Activity Log Entries (ALEs) will display on the student’s “Activity Log” for all WB files imported. Regent will note when a WB file is received and if it has been successfully processed.

Refer to the Customer Zone Knowledge Base for addition information on the COD Web Response Review Queue.

Pell and Direct Loan Reconciliation

An automated approach will automatically present schools with exceptions as data from specific COD reposts are imported into Regent Award. The main Direct Loan Student Account Statement (DL SAS) report is compiled monthly and sent to schools automatically, but some schools want to reconcile on a more frequent (weekly) basis. The Disbursement Detail section of the monthly SAS report can be requested from COD as often as desired by the client as the Direct Loan SAS Disbursement Detail On Demand (DL SAS DD) report.  The Pell reconciliation file (PGRC) can also be requested via COD and imported into Regent. 

Regent will provide a summary of information of the number of records and number of exceptions for reconciliation purposes. Regent will generate a task when there is an exceptions/ difference in the value.  Refer to related Tasks and Task Triggers in this document.

Related Tasks for Disbursements

Refer to the Customer Zone Knowledge Base for a full list of Tasks and Task triggers.  In addition, schools should also review their Task Template for all active tasks related to disbursement.

Configuration

 The initial configuration of disbursements and disbursement schedules will be configured by Regent Education and subsequently maintained by the school post go-live.

 Data Requirements

There are no Data Requirements related to the Disbursement BPA.

Communications Template

There are no Communications related to the Disbursement BPA.

Users & Roles Template

Refer to the school’s UserRoles_Setup_Template for configuration details related to disbursement permissions.

Documents Template

Refer to the school’s Document_Setup_Template for configuration details for the following standard documents for disbursement restrictions.

Tasks Template

Refer to the school’s Task_Setup_Template for configuration details for the following standard Tasks for disbursements.

Pell COA Template

There are no Pell COA configurations related to the Disbursement BPA.

Funds Template

Refer to the school’s Funds_Setup_Template for configuration details for disbursements schedules.

COA Template

There are no COA configurations related to the Disbursement BPA.

Programs and Terms Template

Refer to the school’s Programs_Terms_Setup_Template for configuration details for disbursements.

Breaks Template

Refer to the school’s Break_Setup_Template for configuration details for disbursements.

SAIG Template

Refer to the school’s SAIG Setup Template for configuration details for the following standard SAIG message classes for COD.

Additional Configuration

Institutional Settings

The institution setup in Regent Award is configured with default setting for disbursements by primary type (most frequent) offered by the institution. Refer to the school’s Enterprise_Setup_Template for default setting selected by the school.