Background for COD Processing

Effective 2026-27, the Department of Education requires schools to report enrollment intensity on every new Direct Loan disbursement through the <EnrollmentIntensity> tag. Enrollment intensity represents the school's reported enrollment status for the loan at the time of disbursement, expressed as a whole number from 0 to 100. The Department does not validate or reject based on the specific value submitted. Schools may report the actual enrollment proportion, a simplified binary signal (1 when a Less-Than-Full-Time reduction was applied; 100 when no reduction was applied), or any valid value from 0 to 100. The Department confirms that COD accepts any of these approaches.

Enrollment intensity for Direct Loans is new in this release. It is separate from the pre-existing Pell Grant enrollment intensity concept and handled by a distinct code path.

This tag applies to Direct Subsidized, Direct Unsubsidized, Graduate PLUS, and Parent PLUS loans. Parent PLUS is not subject to the Schedule of Reductions (SOR) proration; schools enter the appropriate Packaged Enrollment Intensity value on the Awards form for Parent PLUS loans, the same as for any other Direct Loan type. For more information, refer to Background for the Schedule of Reductions (SOR).

For term-based programs, the system exports the Packaged Enrollment Intensity value entered on the Direct Loan Awards form. For non-term programs (clock-hour and certain non-standard term configurations), the system always exports 100 regardless of the Awards form value. If Packaged Enrollment Intensity is blank, null, non-numeric, or negative, the system generates an internal validation exception and blocks the export before the file is submitted to COD. COD Reject Edit 994 fires when a 2026-27 Direct Loan disbursement is submitted without this tag.

The system always reads and exports the current Packaged Enrollment Intensity value from the Awards form at the time of each export. This applies to originations, origination changes, first disbursements (Seq 1), and all subsequent adjustment sequences (Seq 2 and beyond). There is no lock at first export - if the value on the Awards form changes between sequences, the updated value is exported on the next sequence.

In this release, Packaged Enrollment Intensity values above 100 generate an internal validation exception and block the export. In a future release, the system will silently cap values above 100 to 100 on export. Until that future release is available, schools with enrollment proportions above 100 should enter 100 in the Packaged Enrollment Intensity field.

The exported enrollment intensity value is visible in Processes > Financial Aid > Regulatory Process Results after export. The imported value from a COD Common Record response is visible in Processes > Financial Aid > Regulatory Process Results (response notification) after import. In Automated COD, the exported and imported values are visible in Configuration > Financial Aid > Automated Job Management > Job History.

Effective 2026-27, schools that apply institutional loan limits below the federal statutory maximums must report this through the <InstitutionalLimitApplied> tag on each applicable Direct Loan disbursement. The tag is informational - the Department collects this data for federal reporting and analytics. COD does not validate or reject based on this tag.

Schools configure institutional loan limits per fund source type and award year under Configuration > Financial Aid > Program Version. The tag applies to Direct Subsidized, Direct Unsubsidized, and Direct PLUS (including Graduate PLUS and Parent PLUS). When an institutional limit is applied, the Awards form shows Yes in the Institutional Loan Limit field for that fund source. The tag is exported only when the institutional limit applies (True). When no institutional limit is in effect, the tag is omitted from the export entirely.

For the first origination and first disbursement (Seq 1), the system reads the Institutional Limit Applied value from the Direct Loan Awards form, which is inherited from the Program Version configuration. For subsequent adjustment sequences (Seq 2 and beyond), the system uses the stored value from the most recent accepted disbursement sequence. Program Version configuration is not re-queried for subsequent sequences.

Institutional loan limits can be applied to grandfathered students. Loan Limit Exception status does not exempt a student from an institutional loan limit configured at the school.

Schools should be aware that when a student transfers to a new enrollment, the institutional limit policy from the new enrollment is not automatically inherited. If the transferred enrollment has a different institutional limit policy and the school wants that reflected on a new disbursement, the configuration must be updated manually or on the web before the new disbursement is exported.

*Legacy users must configure this in the Student Web App, but all functionality at the fund source level is available.

The OBBBA established new Direct Loan annual and lifetime limits effective 2026-27. Students who were already borrowing under prior loan limits and meet continuous enrollment requirements may qualify for a Loan Limit Exception that preserves pre-OBBBA limits. This determination is made by the Department's COD system, not by the school. COD returns the <LoanLimitException> indicator in Common Record responses. Schools do not submit this tag.

When COD returns <LoanLimitException> for a student, the value is stored in the Loan Limit Exception grid on the student's NSLDS tile. The grid accepts values from four sources:

• COD Response - Common Record response files from COD sent in reply to the school's submission

• COD Web Response - Web Response files from COD reflecting activity initiated through the COD website

• ISIR - Institutional Student Information Record loads that include the loan limit indicator

• NSLDS - National Student Loan Data System pre-screens and post-screens

Each import event appends a new row to the grid. No prior rows are overwritten. The grid provides a complete audit history of every Loan Limit Exception value received for the student from any source. The most recent row represents the student's current status.

The Department's initial 2026-27 COD release identifies grandfathered students based on the presence of a 2025-26 disbursement in COD history. Students who were continuously enrolled and qualify under statute but did not borrow in 2025-26 will not be automatically identified by COD in the initial release. For these students, schools should contact the School and Partner Call Center for manual handling. COD plans enhancements later in 2026 to broaden identification.

Grandfathering ends when a student transfers to a different institution, changes credential level, or breaks continuous enrollment. For undergraduate students at the same institution with the same credential level, a change of major does not break grandfathering. Undergraduate students transferring credits through an articulation agreement are no longer permitted to continue grandfathering - COD is targeting the June 2026 release to remove the related articulation-linked functionality that was not removed in time for the April 2026 release. Students simultaneously enrolled in both undergraduate and graduate programs may continue grandfathering under a dual-enrollment exception; COD does not have a systematic way to identify these students in the initial release. Schools should contact the School and Partner Call Center for dual-enrollment cases until COD adds systematic support in the next year's enhancement.

If COD has not flagged a student who the school believes qualifies, the school should award based on the applicable OBBBA limits using available NSLDS and COD visibility, then contact the School and Partner Call Center to request manual review of the exception.

After import, <LoanLimitException> values are visible in Processes > Financial Aid > Regulatory Process Results (response notification) for award year 2026-27 and forward. In Automated COD, values are visible in Configuration > Financial Aid > Automated Job Management > Job History.

*Legacy users will only see the latest Loan Limit Exception status saved to the database, but a full history of all records imported can be seen in the Student Web App. Also, the Web App allows for a Loan Limit Exception status to be manually added with specific NSA permissions.

The OBBBA created a new Pell Grant eligibility pathway for students enrolled in qualifying short-duration workforce programs effective July 1, 2026. Schools that participate designate eligible programs through state approval and ED certification. When a student is enrolled in an ED-approved workforce program, COD returns the <WorkforcePellEligible> indicator in Pell Grant responses. Schools do not submit this tag - COD makes the determination and returns it.

A Workforce Pell Eligible check box has been added to the Pell Grant Awards form. This check box is editable and allows FA administrators to update the indicator proactively before a COD response is received. Schools typically learn of a student's Workforce Pell Eligible status through the FPS transaction before COD returns a Common Record response. By selecting the check box on the Awards form based on the FPS indicator, schools can include the Workforce Pell Tuition and Fees tag on origination and disbursement exports without waiting for a COD response. This is important because COD may already have the student recorded as Workforce Pell Eligible, and submitting a Pell origination or disbursement without the Workforce Pell Tuition and Fees tag in that scenario would trigger COD Warning Edit 230. The check box on the Awards form serves as the gate for Workforce Pell Tuition and Fees export.

Schools configure workforce Pell eligibility at the program level in the Student Web App under Configuration > Academic Records > Program. When a program is configured as workforce Pell eligible for an award year, the Workforce Pell Eligible option on the Pell Grant Awards form is checked automatically. The check box can be cleared manually by the user if needed.

When a student is enrolled in a qualifying workforce program, the system bypasses the standard restriction that blocks Pell for students who already hold a bachelor's degree.

When COD returns <WorkforcePellEligible> in a response, the import updates the Workforce Pell Eligible check box on the Pell Grant Awards form. After import, the value is visible in Processes > Financial Aid > Regulatory Process Results (response notification) and on the Job History for Automated COD users for award year 2026-27 and forward.

*Legacy users must configure this in the Student Web App, but all functionality at the fund source level is available.

When a student is Workforce Pell Eligible, the school must include tuition and fees for the student's workforce program in the Pell Grant export through the <WorkforcePellTuitionAndFees> tag. Schools configure the tuition and fees amount per program version and award year in the Student Web App under Configuration > Financial Aid > Program Version > Workforce Pell Tuition and Fees tab. The field accepts a single total full-time, full-year direct cost amount. The Awards form displays the configured amount as a read-only field on the Pell Grant fund source.

The Workforce Pell Eligible check box on the Pell Grant Awards form is the export gate. When the check box is selected, the system includes the tuition and fees amount in the export for each evaluated CIP code node. When the check box is cleared, the export proceeds as a standard Pell export with no tuition and fees tag.

If the Workforce Pell Eligible check box is selected but the tuition and fees amount is missing, zero, or invalid for the primary CIP code node (CIP 1), the system generates an internal validation exception) and blocks the export before the file is submitted to COD. This applies in both Processes > Financial Aid > COD Export and Automated COD Export. In Processes > Financial Aid > COD Export Schools with students concurrently enrolled in multiple workforce programs can enable evaluation of CIP code nodes 2 and 3 through the setting at Settings > System > General > COD Export CIP Codes 2 and 3. When this setting is enabled, the system evaluates CIP code nodes 2 and 3 in addition to CIP code node 1. If the tuition and fees amount is missing, zero, or invalid for CIP code node 2 or CIP code node 3, the system skips the tag for that specific node rather than generating a validation exception - the record continues to export with the tuition and fees tag included only for the nodes that have valid amounts configured. Only CIP code node 1 triggers an exception and blocks the record.

For originations, origination changes, and first disbursements (Seq 1 with DRI=True), the system checks the Workforce Pell Eligible option and looks up the tuition and fees amount first from the value on the Awards form, if not found, then from the Program Version for CIP code node 1. For CIP nodes 2 and 3, the system will look at Program Version only. For subsequent adjustment sequences (Seq 2 and beyond), the system skips the check box check entirely and uses the stored tuition and fees amount from the most recent accepted disbursement sequence. Program Version is not re-queried, and no validation exception check runs for subsequent sequences.

COD Warning Edit 230 is triggered when a Workforce Pell-eligible student is submitted without the tuition and fees tag, or when a Workforce Pell-ineligible student is submitted with the tag. Anthology's pre-export controls prevent both conditions from reaching COD through the standard export paths. If Warning Edit 230 is returned from COD, it surfaces in Processes > Financial Aid > Regulatory Process Results. In Automated COD, there is no warning edit provision for this edit.

The exported tuition and fees value is visible in Processes > Financial Aid > Regulatory Process Results after export. In Automated COD, the value is visible in Configuration > Financial Aid > Automated Job Management > Job History. When multiple CIP code nodes export with tuition and fees in the same record, the values appear as a comma-separated list.

*Legacy users must configure this in the Student Web App, but all functionality at the fund source level is available.

For award year 2026-27 and forward, graduate and professional students are reported to COD using new two-character Student Level Codes. The prior codes (6 and 7 for Graduate/Professional) are retired for 2026-27 forward. The new codes are:

• 8 (GNP - Graduate Never Professional)
• 9 (GwP - Graduate was Professional)
• 10 (PNG - Professional Never Graduate)
• 11 (PwG - Professional was Graduate)
• 12 (GCE - Graduate Concurrent Enrollment)
• 13 (PCE - Professional Concurrent Enrollment)

Undergraduate codes 0 through 5 are unchanged for all award years. Codes 6 and 7 remain valid for prior award years. COD Reject Edit 208 fires for any 2026-27 record submitted with Student Level Code 6 or 7.

Schools that process TEACH Grants for graduate students should verify that TEACH processing aligns with the new codes. The TeacherExpertIndicator, which triggers TEACH Grant expert teacher agreement requirements, is now set when a student's level in college is one of codes 8 through 13 for award year 2026-27 and forward. For 2025-26 and prior, the indicator was set for codes 6 and 7.

*Legacy users must award fund sources that require the grade level 08-13 for graduate and professional students within the Student Web App. We will have Legacy updated in Anthology Student 26.2.0, which allows the new grade levels to be awarded and saved.

Automated Awarding users cannot award funds with the grade levels 08-13 in Legacy or Student Web App. We will be working to get this resolved in the Regulatory US release ASAP.

When COD Web Response files (message class CRWB27OP) are imported, the system processes and stores all OBBB tag values returned by COD for 2026-27 actual disbursement records.

Loan Limit Exception values in COD Web Response files are appended to the Loan Limit Exception grid on the student's NSLDS tile, consistent with the behavior described in the Loan Limit Exception section above. Workforce Pell Eligible values in the COD Web Response files update the Workforce Pell Eligible check box on the Pell Grant Awards form. Enrollment Intensity and Institutional Limit Applied values from COD Web Response files are stored for the corresponding Direct Loan disbursement records and displayed in Processes > Financial Aid > Regulatory Process Results after import and in Configuration > Financial Aid > Automated Job Management > Job History.

COD Web Response files follow the same COD-defined disbursement sequencing rules as standard response files. A web response disbursement with DRI=False and Disbursement Sequence Number (DSN) 1 is valid and expected - this is an anticipated disbursement. DSN=1 with DRI=True represents the first actual disbursement for that disbursement number, even when delivered in a web response file. COD-assigned sequences (DSN 66 through 90) appear in web response files for system-generated adjustments and web-submitted activity. A web response file delivering DSN 66 or higher without a prior DRI=True DSN=1 baseline in COD history is not rules-compliant. The system does not rely on DSN ordering alone for processing orders - each disbursement is keyed on award year, program, disbursement number, DSN, and DRI.

For subsequent adjustment exports that follow a web response import, the system uses the stored values from the most recent accepted disbursement sequence for ILA and WPTF. For Enrollment Intensity specifically, the system always re-derives from the current Packaged Enrollment Intensity on the Awards form, regardless of whether the prior sequence came from a web response import.

For award year 2026-27, COD enforces a stricter relationship between Program Credential Level (PCL) and Student Level Code (SLC). The system validates the PCL/SLC combination before export and blocks submissions where the combination is invalid for the award year. This validation runs before the export file is submitted to COD.

The valid PCL/SLC combinations for 2026-27 are:

• PCL 01 through 04 and PCL 99 (undergraduate credential levels): Student Level Codes 0 through 5 only. Graduate and professional Student Level Codes (8 through 13) are not valid for these credential levels.

• PCL 05 through 08 (post-baccalaureate through doctoral credential levels): Student Level Codes 0 through 5 and 8 through 13. Student Level Codes 6 and 7 are not valid for any credential level for 2026-27.

In Processes > Financial Aid > COD Export, an invalid PCL/SLC combination generates a pre-export validation error, and the record is excluded from the export. In Automated COD export, CODEXPRT0078 fires for records with an invalid combination, and the exception appears in Configuration > Financial Aid > Automated Job Management > Job Management History. To resolve this exception, correct either the Program Credential Level in Program Version configuration or the student's Student Level Code so that the combination is valid for 2026-27, then re-export.

COD Reject Edit 208 enforces these combinations on submission as an additional safeguard.

The <ProgramAttendanceBeginDate> tag exists in Common Record Schema 5.0d but is not implemented in this release and should not be configured or tested. The only confirmed use case for this tag was supporting articulation agreement grandfathering, which was eliminated in April 2026 by the Department. The Department confirmed that <ProgramAttendanceBeginDate> has no remaining valid use case for 2026-27. The Department's COD system was not able to remove the related functionality in time for the April 2026 release and is targeting the June 2026 release for full removal. Anthology Student does not export this tag.

However, please note that we plan to use Program Attendance Begin Date – date picker field – as an override option for the Enrollment Status Effective Date in the next Regulatory US implementation.

The OBBBA changed Direct Loan annual limits effective July 1, 2026, for students who are not grandfathered under the Loan Limit Exception. Anthology Student submits what is awarded; COD enforces the new limits through reject edits.

Key changes for 2026-27 non-grandfathered students:

• Graduate PLUS loans are eliminated. COD Reject Edit 150 fires for non-grandfathered graduate and professional students whose award begin date and earliest disbursement date are both on or after July 1, 2026.

• Parent PLUS loans are capped at $20,000 per dependent student. COD Reject Edit 039 enforces this limit.

• Professional Unsubsidized loans increase from 20,500 to 50,000.

• Graduate Unsubsidized loans for students who have never been in a professional program remain at $20,500.

• Undergraduate loan limits are unchanged.

For grandfathered students (Loan Limit Exception = Y), prior-rule annual loan limits continue to apply. Grandfathered students are still subject to the Schedule of Reductions proration and to any institutional loan limits the school has configured.

The new lifetime maximum for combined Direct Subsidized, Unsubsidized, and Graduate PLUS borrowing (including FFELP loans) is $257,500 for non-grandfathered borrowers. This maximum does not include Parent PLUS loans or consolidation loans. Amounts that have been repaid, forgiven, canceled, or discharged do not restore borrowing eligibility against this ceiling. The authoritative source for remaining aggregate and lifetime maximum eligibility is the NSLDS website.

For students simultaneously enrolled in graduate and professional programs, the system cannot automatically determine the applicable non-professional limit ceiling before COD submission. Schools that believe a student qualifies for the higher $50,000 Professional Unsubsidized cap should contact the School and Partner Call Center for manual handling.

Message Classes Supported in Regulatory US 26.5 and Student 26.1.1

All Common Record response files and all system-generated response files are supported in this release for both Processes > Financial Aid > COD Import and Configuration > Financial Aid > Automated Job Management > COD Import. These are the files COD returns to schools in reply to school submissions and as system-generated activity. All files for 2026-27 use Schema 5.0d.

Common Record response files (document type RS):

• COMRECOP - Common Record Response (non-program-specific, non-award-year-specific)
• CRAA27OP - Common Record Response (award-year-specific)
• CRPG27OP - Common Record Pell Grant Response (award-year-specific)
• CRPGMYOP - Common Record Pell Grant Response (multi-year)
• CRDL27OP - Common Record Direct Loan Response (award-year-specific)
• CRDLMYOP - Common Record Direct Loan Response (multi-year)
• CRTH27OP - Common Record TEACH Grant Response (award-year-specific)
• CRTHMYOP - Common Record TEACH Grant Response (multi-year)

System-generated response files:

• CRBN27OP - Booking Notification
• CRND27OP - Negative Disbursement
• CRPS27OP - Payment to Servicing
• CRPN27OP - MPN Response
• CRAT27OP - ATS Note Acknowledgement
• CRAC27OP - TEACH Grant Counseling Acknowledgement
• CRWB27OP - COD Web Response
• CRSP27OP - Direct Loan PLUS Application Response
• CRECMYOP - DL Entrance Counseling Acknowledgement (multi-year)
• CROF27OP - Origination Fee and Interest Rebate Percentage Response
• CRCS27OP - Credit Status Response
• CRIB27OP - Informed Borrowing Confirmation Response
• CRCO27OP - Credit Decision Override
• CRRC27OP - Receipts from COD System to School

Message Classes Not in Regulatory US 26.5 - Planned for a Future Regulatory US Release

The following message classes are not supported for 2026-27 in this release and are planned for a future Regulatory US release. In Processes > Financial Aid > COD Import, these message class families will not appear in the award year 2026-27 filter. This is intentional - the associated report layout changes are not yet implemented. Schools should not attempt to import these files for award year 2026-27.

Pell Grant SAS, reporting, and statement files:

• PGPE27OP - Pell Pending Disbursement List
• PGPR27OP - Pell Grant POP Report
• PGYR27OP - Pell Grant Year-to-Date Record
• PGAS27OP - Pell Grant Electronic Statement of Account
• PGRA27OP - Pell Grant Data Request Response
• PGMR27OP - Pell Grant Multiple Reporting Record
• PGRC27OP - Pell Grant Reconciliation Report
• PGSA27OP - Pell Grant School Account Statement (Disbursement Summary)
• PGSM27OP - Pell Grant School Account Statement (Monthly)
• PGSY27OP - Pell Grant School Account Statement (Year-to-Date)
• PGVR27OP - Pell Verification Status Report
• PSOM27OP - Pell Grant SAS Disbursement Detail (Month-to-Date)
• PSOR27OP - Pell Grant SAS Disbursement Detail (Date Range)
• PSOY27OP - Pell Grant SAS Disbursement Detail (Year-to-Date)
• PGLE27OP - Pell Lifetime Eligibility Used Report
• MPNSTAOP - MPN Status Report

TEACH Grant SAS and reporting files:

• THSM27OP - TEACH School Account Statement (Monthly)
• THSY27OP - TEACH School Account Statement (Year-to-Date)
• THMR27OP - TEACH Grant Multiple Reporting Record
• THRB27OP - TEACH YTD Rebuild
• ATSDISOP - ATS Discharge for TEACH

Direct Loan SAS, rebuild, and reporting files:

• DSDF27OP - Direct Loan School Account Statement (Fixed-Length, Disbursement Level)
• DSLF27OP - Direct Loan School Account Statement (Fixed-Length, Loan Level)
• CODRBFOP - Direct Loan Rebuild File
• SCHMONOP - COD School Monitoring Report

In Daily > Financial Aid > COD Import (legacy interface), the following rebuild files are not supported for award year 2026-27:

• CODRBFOP - Direct Loan Rebuild File
• PGYR27OP - Pell Grant Year-to-Date Record
• THRB27OP - TEACH YTD Rebuild

At a Vendor Focus Group held on May 7, 2026, the Department announced that <EnrollmentStatusEffectiveDate> will be required for all 2026-27 Direct Loan originations submitted after June 28, 2026. This tag is currently designated as for future use in the Direct Loan schema and is being activated by the Department for 2026-27. Direct Loan originations submitted without this tag after June 28, 2026 will be rejected by COD with Reject Edit 996.

The enrollment status effective date should reflect the most recent enrollment date corresponding to CIP code node 1 (the primary CIP code). In Anthology Student, this maps to the most recent enrollment date for the student's primary enrollment - area of study, program version, or program, in that order of precedence.

No COD Technical Reference update has been published for this requirement as of the May 7, 2026 VFG. Anthology is working to include support for <EnrollmentStatusEffectiveDate> in a future release. Schools should watch for further communications on timing and implementation guidance.