Resources and References

• History Tab
• Direct Loan Annual and Aggregate Limits
• Program Setup Data Elements
  • "Apply SULA Calculations" is inheritable; see Institution Setup Data Elements and Campus Setup Data Elements.
• ED IFAP SULA FAQ

SULA Definitions and Concepts

What is SULA?

SULA is a time-based lifetime limit for a student. It restricts how many years a student can receive Direct Subsidized Loans. Subsidized Loan usage is measured in Academic Years, called Subsidized Usage Periods (SUP). A student can only receive a certain number of years of Subsidized loans. The maximum number of years is based on 150% of the student's current program length. For example, a student in a 2-year Associate's program may have up to three years of Subsidized loans (150% x 2 years = 3 years). If the same student later enrolls in a 4-year BS program, the student would be allowed up to six total years of subsidized loans (150% x 4 = 6 years), including all Subsidized loans previously awarded.  Some special calculations apply. For example, if the student is in a term or nonstandard term program, and the student does not have full-time enrollment and/or Subsidized loans for all terms in an Academic Year, they often will have less than a full year of SUP for that academic year.

COD tracks a student's lifetime total SUP. The student's total lifetime SUP is cumulative across schools and across programs. The lifetime SUP includes the years of Subsidized loans awarded at other schools or other programs; however, the student's current limits are still based on 150% of their current program. COD tracks and calculates the student's SUP. COD sends the values to schools whenever COD sends a Common Record COD response for a Subsidized loan.

The SULA limits do not apply to students who previously had federal student loans prior to July 1, 2013. ED determines whether a student is subject to SULA restrictions. ED sets the student's SULA flag to 'Y' (Yes, SULA applies) or 'N' (No, SULA does not apply).  If a student does not have any ED data source yet (such as an SBL loaded without an ISIR), Regent assumes SULA=Y until ED reports the student's SULA flag has a value of N (No, SULA does not apply.)

Many SULA details are available on the student's History tab, SULA sub-tab. See History Tab.

Program Characteristics

Subsidized Loan awarding is based on 150% of the length of the student's current active program. Regent's logic checks the student's total cumulative SUP against the MEP for the program in each enrollment (i.e., each term, or each nonterm Academic Year).  Schools may configure programs to not apply the SULA calculations for awarding purposes. See Program Setup Data Elements.

Regent starts with the Program's Published Program Length (PPL), as configured in Program Setup and converts to Years using ED calculation formulas.  Regent then calculates the program's Maximum Eligibility Period (MEP) for SULA, based on 150% of the Published Program Length in Years. For example, if the Published Program Length is 208 weeks and the AY length is 34 weeks, Regent calculates the program length at 6.116 years and MEP of 9.2 Years. See Program Setup Data Elements for more details on these fields.

SULA Student-Level Calculations

Regent calculates and tracks the student's total Subsidized Usage Period (SUP) during packaging. Regent uses the most recent SULA information from COD, NSLDS FAH, or ISIR data. First, Regent starts with the student’s Total Actual SUP value, in years, as reported by the official ED data source. Next, Regent subtracts any COD-calculated loan actual SUP values for current and future award periods. Then, Regent repackages and re-awards the Subsidized loans for current and future years. During packaging, Regent automatically tracks each loan’s SUP, as adjusted for term enrollment levels or maximum eligibility. Regent adds the loan’s SUP to the student’s total cumulative SUP calculated by Regent. When a student’s program is configured to apply SULA calculations to awarding, the system will stop awarding Subsidized loans when the student’s total SUP reaches 150% of the Published Program Length in years. The system also marks the final subsidized loan as being the last eligible Subsidized loan due to SULA restrictions.

Regent Award calculates SULA values for all students with the SULA flag = Y in the official ED data source. Schools can configure whether the SULA calculations will affect Subsidized loan awarding. The configuration setting is ‘Apply SULA Calculations' in Institution Setup, inheritable to Campus Setup and Program Setup. See: Institution Setup Data Elements, Campus Setup Data Elements, and Program Setup Data Elements.  Regent will continue to calculate student-level SULA for students with a SULA=Y, even when the program is ineligible for Subsidized loans (such as Graduate programs) or the program is configured with ‘Apply SULA Calculations’ set to 'No.'

Loan-Level SULA Calculations 

If SULA=Y, Regent calculates the SUP for each individual Subsidized loan. First, Regent adjusts the loan's amount, eligibility, loan period length, etc. as for normal awarding.; see /wiki/spaces/RNA/pages/7027689. Next, Regent calculates the individual loan's SUP. Regent adds the loan to the student's cumulative SUP.  The system calculates the Remaining Eligibility Period (REP), the difference between the program's MEP, and the student's total cumulative SUP.  For term-based students, if an individual loan's SUP is more than the student's MEP, the system first tries to shorten the loan and/or change the amount to achieve a lower SUP. For nonterm students with a full AY, the system cannot award the loan for less than 1.0 of an AY, so the system cannot award the Subsidized loan.

Actual vs. Anticipated SUP

If a loan is completely unpaid, the loan's SUP is Anticipated. Once the loan has any paid disbursement, the entire loan's SUP is counted as Actual SUP.

For example, if a loan with 1.0 SUP is in Regent with Offered or Estimated status, that loan would not have yet been sent to COD. The unpaid loan's calculated 1.0 SUP is Anticipated SUP.  The unpaid loan stays at 1.0 Anticipated SUP when it is accepted and originated at COD.  Later, once the loan has been partially paid for the first term or payment period (a positive disbursement is Accepted at COD with DRI=true), then both Regent and COD count the entire loan's 1.0 SUP as 1.0 Actual SUP.  The loan's Anticipated SUP changes to 0 when DRI=True.

Term-Based Loan SUP Calculations

In general, if a Subsidized loan has full-time enrollment in every term in a full Academic Year, the loan has 1.0 years of Subsidized Usage (1.0 SUP.)

Term-based loans may be shorter than one full AY, but must always be at least one term in length. If a term-based loan is shorter than a full AY, or included in another loan period's dates and SUP, or the enrollment level is not full-time, the loan's SUP might be reduced. The system can also reduce Regent's calculated SUP depending on the loan period length, the maximum annual limit amount, or the enrollment levels in each term. 

Loans Contained in Another Loan Period

Term-based students might have multiple Subsidized loan periods in an AY. For example, a student might have both a $3500 loan that covers the full AY, and an additional $1000 loan for only part of the AY at a higher grade level. COD does not double-count SUP for multiple loans covering the same terms.  If a student has a shorter loan period that consists of terms that are fully contained in another award period's SUP, Regent marks the shorter loan as having 0 years of SUP.

Loan Period Length

For term students, when a Subsidized loan does not cover all the terms in the AY, the SUP is evaluated proportionally. Note, the loan might still be affected by the Maximum Amount Exception; see below.

If a loan has the same enrollment level in every term in the loan period, the system calculates SUP using the following formula:

   (Loan Period End Date  - Loan Period Start Date + 1)           x 1.0 years  x  (term enrollment-level multiplier)   =   Adjusted SUP 
(Academic Year End Date - Academic Year Start Date + 1) 

Maximum Amount Exception: Sub Loans at the Annual Maximum Limit for Loans Shorter than 1 AY

ED has a special amount-based rule that applies to shorter, term-based loans when the loan period contains fewer terms than a full Academic Year. For example, a SAY student might have a $5500 Sub loan in a SAY AY with Fall, Spring, and Summer terms. If the student has no Fall enrollment but the student has Sub loans in the Spring and Summer terms only, the loan period is shorter than the AY length.  Normally, the shorter Loan Period would be a lower SUP (less than 1.0 years). However, a special SULA exception applies when a Sub loan amount is for the full maximum Subsidized annual limit for the student's grade level (i.e., $3500, $4500, or $5500). If the Sub loan is at the maximum annual amount, the loan will be initially set to 1.0 SUP regardless of the  loan period length.  Then, if the student has less-than-full-time enrollment in any terms in the loan period, the system can potentially reduce the loan's 1.0 SUP by the enrollment level multipliers.

Term-based Enrollment Level Multiplier

ED makes an additional adjustment for a student's enrollment level.  If a term-based student does not have full-time enrollment in every term in the loan period, the Term-based loans are adjusted based on the enrollment levels in each portion of the AY (each "segment".) The enrollment level multiplier values are:

• FT, Full-Time: 1.0
• TQT, Three-Quarter Time: 0.75
• HT, Half-Time: 0.5

If a term-based loan has the same enrollment level and the loan covers all terms in the AY, ED and Regent calculate the loan's SUP as (1.0 SUP  x the enrollment multiplier), then round to the nearest 0.1 (tenth) of a year. For example, if a student has a 3-term BBAY that has a 3-term loan period, and all the loans are at Half-Time enrollment, the loan's 1.0 SUP is multiplied by the HT enrollment-level multiplier (0.5), resulting in a loan SUP of 0.5 years.

Segment Length

The system uses a more complex calculation when a student has different enrollment levels in different terms within the same loan period. The reason is that COD knows the start date of each payment period, but COD does not know the break periods or terms' end dates. So, the system has to calculate the length of each segment in the loan period, in calendar days. 

To calculate the Calendar Days in each segment:  ((Date range's End Date) - (Date range Start date) + 1).  For example, March 1 through May 31 is 92 days.  Note: When calculating the difference in days using subtraction in a tool such as Microsoft Excel, remember to add 1 day to account for the starting day.

Calculating Loan SUP with Different Enrollment Levels in Each Term

Steps to calculate a loan's SUP when a loan has different enrollment levels in the different terms in the loan period:

1. Package the loan, adjusting the loan amount, loan period dates, and enrollment levels. 
   1. Example: A term student has a 3-term Subsidized loan with Fall FT, Winter TQT, Summer HT
2. Identify the start and end dates of each part (each segment) in the loan period.
   1. The segments are contiguous, calendar days that cover all the days from the loan period start date through the loan period end date.
      1. The system does not consider term end dates or break days in the date-based length calculations. As a result, even if all term lengths are identical and have identical instructional days, the student's calculated days for SULA purposes might result in different values.
      2. The date range for the first segment starts with the loan period's start date. The date range for the last segment ends with the loan period's end date. 
      3. For multi-term loans with 3 or more terms, the first segment starts with the first term's start date, then continues until 1 day before the start date of the next term in the loan period. The second segment starts with that second term's start date and continues until 1 day before the next term's start date, or (for the last segment) ends with the loan period's end date.
   2. In our 3-term example student:
      1. Term dates: Fall 2021 is 8/23/2021 to 12/19/2021, Spring 2022 is 1/17/2022 to 5/15/2022, and Summer 2022 is 5/16/2022 to 8/21/2022.
      2. Days in each segment are calculated as follows:
         1. Segment 1, Fall term:   (1/16/2022 - 8/23/2021 + 1) = 147 days
            The calculation is: (1 day before Spring term's start date) - (Fall term's start date) + 1.
            Note, this segment includes the holiday break between Fall and Spring terms.
         2. Segment 2, Spring term:  (5/15/2022 - 1/17/2022 + 1) = 119 days
            The calculation is: (1 day before Summer term's start date) - (Spring term's start date) + 1.
         3. Segment 3, Summer term: (8/21/2022 - 5/16/2022 + 1) = 98 days
            The calculation is: (Loan Period end date) - (Summer term's start date) + 1
3. Determine the enrollment level for each segment, and multiply each segment's days by the enrollment level multiplier.
   1. Note, the enrollment level is the COD Enrollment Level for the term.  Once a term has a paid disbursement, the term's COD Enrollment Level is frozen at the enrollment level when the initial, first disbursement in the term was paid (Accepted as DRI=true at COD, and EST'd.) If a student has multiple disbursements in a term, and the student changes their registration after the initial disbursement for the term is paid, then the new enrollment level in that term will not affect the COD Enrollment Level. If a term does not have any paid disbursements yet, the system does apply the term's current enrollment level. 
   2. In our 3-term example student:
      1. Segment 1, Fall term, FT, multiplier 1.0.  Calculation:  (147 days) x (1.0) = 147 days
      2. Segment 2, Spring term, TQT, multiplier 0.75.  Calculation:  (119 days) x (0.75) = 89.25 days
      3. Segment 3, Summer term, HT, multiplier 0.5.  Calculation:  (98 days) x (0.5) = 49 days
4. Add up all the adjusted day values from the individual segments in the loan period.
   1. Example total days: 147 + 89.25 + 49 = 285.25
5. Determine the total days in the Academic Year. 
   1. Calculation:  (AY End Date) - (AY Start Date) + 1 = AY days
   2. In the 3-term example AY:  8/21/2022 - 8/23/2021 + 1 = 364 days in AY
6. Divide the (Total Adjusted Days) by the (Total Academic Year length) and multiply by 1.0 years to get the loan's Subsidized usage, in years.
   1. Example:  (282.25 days / 364 days) x (1.0 years)  = 0.7754 years
7. Round the total loan SUP to the nearest 0.1 (tenth) of a year.
   1. Example: 0.7754 rounds to 0.8 SUP
8. The system saves the loan's SUP. If the loan is unpaid, the loan's full SUP amount is the Regent Loan Anticipated SUP. If the loan has any paid disbursements, the full loan's SUP amount is the Actual SUP value. If the loan is the student's final loan for SULA, the system also marks the loan as the Final loan for SULA. 
   1. In our example, the loan would have 0.8 Anticipated SUP and 0.0 Actual SUP until at least one disbursement is paid. When the loan has a disbursement paid, the system will change the loan SUP to 0.0 Anticipated SUP and 0.8 Actual SUP.