60D Comment Response

Incoming Comment from 60-day comment period on 2022 Federal Work Study (FWS) Wages for Student Aid Index	Comment #	Commenter	FSA response
How often will we have to report FWS wages? We suggest it should be once at the end of the year. It should coincide with the time of year we submit the FISAP. Will we be able to upload the data or will this be completely manual? An upload process would be much appreciated.	4	jtb@berkeleycollege.edu	Yes, reporting will be required annually and the timing of the annual release will align with the FISAP release, enabling schools to report FWS wages for the prior calendar year in advance of the FAFSA release for the upcoming year. Schools will have the option to utilize the Campus-Based schema to submit their FWS data in batches, or manually via COD Web, but there will not be an upload option available at this time. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available). An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
The simplification of the FAFSA has led to greater administrative burden for Institutions of Higher Education, which now must provide ED with information no longer obtained by the FAFSA form. The requirement to submit FWS earnings for students is one such burden on already busy financial aid offices, most of which are understaffed. The late availability of the template on which the information must be provided makes reporting the information even more difficult. The FAFASA simplification serves only the filers, who will still be overwhelmed by the form, not anyone else involved in the administration of financial aid.	5	Anonymous	Thank you for your comment. We are bound to implement the law as mandated by the FAFSA Simplification Act. Only an act of Congress can change such requirements.
I am concerned with how this change will be implemented, and whether it will cause an undue administrative burden on the schools, at the same time extending processing times and inconveniencing students. Would the Department be sending the school individual requests for each student before the ISIR is generated? Would an additional document requirement be added to the student's file after ISIR generation, causing the students/schools additional work to complete the student file? How would a school access work study earnings from another school when a student transfers? Without a planned method of obtaining this information we could end up with students being unable to access aid.	6	Gina Wenzel-Garza / gina.wenzel-garza@arapahoe.edu	Schools will be required to report FWS wages on behalf of all of their students that earned FWS wages at their institution during the calendar year being requested. Reporting should occur in advance of the release of the FAFSA so that FWS data may be captured in the Student Aid Index (SAI) calculation upon FAFSA submission, limiting any delays to aid processing. In addition to the latest version of Volume 4 of the COD Technical Reference that was recently posted ((https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available)), an Electronic Announcement with further operational guidance will also be forthcoming this summer.
I think reporting FWS wages directly to the department from will be a big help to students, but the format and instructions on how this will be done needs to be expedited to not delay the FAFSA. It will take a considerable amount of time to work with our student information systems platforms and IT departments to accurately pull and report this information. I believe if we can't have at least 6 months to implement with final regulations and technical requirements, this needs to be pushed to a future aid year.	7	Dustin Zimmerman	Thank you for your comment. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available). An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
If the purpose is to more accurately determine the SAI, what about reporting income earned from other need-based employment programs and need-based employment portions of fellowships and assistantships? Some schools have State and/or Institutional work-study programs. Also, ideally, could these type of earnings be noted somehow on W2s, and therefore reported to the IRS? Then, schools would not need to report these earnings, and instead could be pulled from the IRS along with the other income information. I'm not sure what would go into this process, but it's worth exploring. Thank you.	8	Anonymous / craig.sandesron@mnsu.edu	Thank you for your comment. The HEA, as amended by the FAFSA Simplification Act, under Sec 483 stipulates what information may or may not be collected by the FAFSA form. Specific to work study wages, Sec 483(a)(2)(F) states: “With respect to an applicant who has received income earned from work under part C of this title, the Secretary shall take the steps necessary to collect information on the amount of such income for the purposes of calculating such applicant’s student aid index and scheduled award for a Federal Pell Grant, if applicable, without adding additional questions to the FAFSA, including by collecting such information from institutions of higher education participating in work-study programs under part C of this title.” The collection of other types of need-based employment is not required under the law.
If schools are going to be required to submit information to COD in an XML format, nobody will be able to manually create such files due to their complexity. Schools will have to rely on their student information system, and vendors will need more lead time in order to create and test a new process to produce these files. I hope another method of submitting the required information, such as a website application or a flat file, will be considered.	9	Anonymous	Thank you for your comment. Schools will have the option to utilize the Campus-Based schema to submit their FWS data in batches, or manually via COD Web, but there will not be an upload option available at this time. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
While ED is obligated to comply with the FAFSA Simplification Act, it needs to make a concerted effort to partner with institutions to discern what is readily available and achievable. This process should be focused, streamlined, and also take into account that, for federal aid purposes our systems are largely designed around award years.The needs of data for FWS for CPS extraction, conversely, fall in line with the data handled specifically for payroll, and while these systems by necessity have some overlap, in many systems that is not particularly robust because it has never needed to be and may prove a significant barrier in accurately combining and peeling those data layers. If, as seems to be the case, ED is proposing to design its collection in line with the https://fsapartners.ed.gov/sites/default/files/2023-03/2324CODTechRefVol4.pdf draft, we are starting out the conversation in a very challenging place. The vast majority of these fields seem extraneous for this purpose. There are 95 listed fields, and while it appears 26 of them are optional, that still leaves 69 mandatory fields per student. Even items ED may legitimately have curiosity about, like institutional/federal share, will be more complicated for many institutions to pull because it may not even exist or not utilized as a field in their SIS which may require manual manipulation of the extract or other workarounds to incorporate. More pertinent here, it's not even necessary information for ED's current purposes to comply with the FAFSA Simplication Act, and it's not entirely clear what value it holds as aggregated data. Clearly the purpose is significantly more expansive, and thus also complicated, than stated, but at least for the near term should be dialed back to enable ED and schools to meet the statutory need in a reasonably timely and accurate matter. This significant expansion of reporting is a risk for all parties to meet necessary timelines. In terms of burden, realistically this is going to be significantly more than 3-4 hours for most schools. There will be many institutions where this will require significant manual work in the same way GE did. As one simple issue, the SEOG information (again, not required for the current statutory need at all) is based on Award Year, whereas FWS is based on calendar year, which suggests at least two reporting windows per year, and also the potential for those submissions to conflict with each other and cause rejects, which then becomes an even more significant time commitment to resolve. For their immediate need, ED needs to really significantly strip back to only the data elements required to comply with current law: SSN/Name/DOB, Calendar Year, FWS earned in said calendar year, and the handful of fields needed to mark the institution and report tracking. If, as this document suggests, ED's intent is really to expand out into a much more robust Campus-Based reporting well beyond the bounds of what the law requires, they should take the time to really survey a broad range of schools to see what data is reasonably available (not to mention meaningful) and how it would be reported most effectively and with a more reasonable amount of administrative burden. Here the ask is very expansive, doesn't serve a clearly stated purpose, and seems likely to me to run into logistical problems by serving both as calendar year reporting for FWS and award year reporting for SEOG. Other early commentors focused heavily on administrative burden, and I don't disagree with them, though from prior experience know that's not received as a compelling argument. But here ED should take it seriously because they seem intent to move far beyond what current law requires for no clear purpose, and in a manner that I think many schools will significantly struggle to comply with, and may also create unforeseen issues for COD. This creates real challenges for all parties in meeting required timeframes and increases the risk of inaccurate or unreliable data being transmitted.	10	Peter Goss / peter.goss@pcc.edu	Thank you for your comment. While the Campus Based schema is being built with consideration for possible future data needs, no information is being requested as part of this collection that is not required under the FAFSA Simplification Act or for the purposes of matching student records in the COD System and the FAFSA Processing System. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
While I understand the need to provide this information so as to ensure the correct FAFSA filing information, I believe the Department is underestimating the complexity for institutions of higher education, and is overstepping the need for information with the schema provided. First, most financial aid systems operate on a Fiscal year basis and usually from July 1 to June 30. Wages for FWS jobs are collected within these systems are are totaled by academic year, not by calendar year. This new report will require institutions to segment out the wages earned for two academic years (from January 1 which is usually Spring of the previous academic year through December 31 which is usually Fall of the subsequent academic year). This data collection adds a level of complexity since reporting will likely be required through two different award years. While HR departments (and particularly payroll) will have the calendar year earnings (as this is required for tax reporting), they will NOT likely have the information to distinguish between wages earned in a Federal Work Study job and any wages earned in other ways by the student during the calendar year at the institution. It is increasingly the case that students who earn FWS wages also have other wages earned at the institution, and therefore segmenting out just the FWS wages will be difficult at best. This complexity means that any additional non-required fields represent a significant burden. Adding additional fields in the schema (just as job start date, Federal Share, Institutional Share, etc.) is not needed for this process and should not be included. The Department is overreaching here by essential requiring unit level data on campus based awards. This is unnecessary and should not be part of this implementation.	11	Daniel Barkowitz / dbarkowitz@miami.edu	Thank you for your comment. While the Campus Based schema is being built with consideration for possible future data needs, no information is being requested as part of this collection that is not required under the FAFSA Simplification Act or for the purposes of matching student records in the COD System and the FAFSA Processing System. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
Given short timelines and that there is so much change happening now, strongly recommend that only the minimum information required to calculate the SAI be collected from the calendar year 2022 in support of 2024-2025 Student Aid Index (SAI) calculation. Details such as the institutional/federal shares and individual payment period dates and amounts can be added in subsequent years as necessary. Both institutional staff and software vendors will need more time to efficiently and effectively support the more detailed reporting.	12	Sharon Clough / sharon.clough@regenteducation.com	Thank you for your comment. While the Campus Based schema is being built with consideration for possible future data needs, no information is being requested as part of this collection that is not required under the FAFSA Simplification Act or for the purposes of matching student records in the COD System and the FAFSA Processing System. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
I agree with schools providing FWS earnings to the Dept as I found often times the student would misreport or forget to report their FWS earnings, especially now that the FAFSA uses prior-prior year earnings and no one seems to keep their tax returns or W-2s. I do not agree with the Dept asking for more data points than what is required by the FAFSA simplification legislation. Start date and end date doing make sense when the earnings data is half from one aid year and half from a second aid year. Which start date and end date should be used? The other data is simply a waste of time if it is not required by legislation and therefore not being used for any purpose at this time. I find the constant slicing and dicing of data by demographical data to be stepping toward segregation and not stepping away from it. Please do not implement the additional data elements that are not required by the FAFSA Simplification Act.	13	Melinda Fedeler / melinda.fedeler@dsu.edu	Thank you for your comment. While the Campus Based schema is being built with consideration for possible future data needs, no information is being requested as part of this collection that is not required under the FAFSA Simplification Act or for the purposes of matching student records in the COD System and the FAFSA Processing System. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
I am gravely concerned about the reporting requirements and the administrative burden that the updated information indicates there will be. I urge DOE to only request the FWS data that is needed to calculate the student's SAI and nothing more. I work in a very small college, and we have used a third-party processor for the past several years. We are trying to move in-house to better serve our students. We have a very small financial aid team. I am concerned that reporting this data may take time that will affect our ability to work with our students directly. Please consider the wide breadth of types of colleges and staffs and ensure that ONLY the minimum amount of data is collected and not arbitrary data for purposes not related to computing the SAI. Thank you.	14	Anonymous / holly.swanson@cbshouston.edu	Thank you for your comment. While the Campus Based schema is being built with consideration for possible future data needs, no information is being requested as part of this collection that is not required under the FAFSA Simplification Act or for the purposes of matching student records in the COD System and the FAFSA Processing System. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
I do believe that the Department is severely underestimating the complexity for institutions of higher education to provide this information. We are an institution that offers the ability to work to every undergraduate student on our campus. While only part of what is funded comes from FWS, it will be difficult for students to understand where their funds are coming from -- federal or institutional dollars -- and I fear will do a lot of impact their financial aid outcome. Additionally, as mentioned in other comments, colleges and their operating systems use Fiscal year, not calendar year and wages for FWS jobs are collected as part of the fiscal year. This new reporting requirement will require institutions to separate out the wages earned for two academic years (from January 1 which is usually Spring of the previous academic year through December 31 which is usually Fall of the subsequent academic year). This data collection adds a level of complexity since reporting will likely be required through two different award years and will be difficult for payroll offices to comply with. Human Resources and Payroll will have a difficult time sussing out this information in a format that will be required by ED for our students.	15	Karen Hart Bucher / kbucher@su.edu	Thank you for your comment. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
While the accuracy of FWS reported will increase with schools reporting the data, there has to be systems in place. This will take time, much more than the 4 hours estimated. With all of the extra data fields requested, we will have to have our developers do some customization between different systems. I estimate that this will take closer to 250 hours to complete. This is in addition to all of the other changes schools have to do with the FAFSA Simplification Act to their communications, website, systems. All of this and we no longer have federal trainers to contact, nor in person training. The administrative burden is placed on the schools, yet you call us partners.	16	Anonymous	Thank you for your comment. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
Federal Work Study reporting to COD & Housing Removal from 2024-25 FAFSA. I am sure I speak for many aid administrators that are burdened by the numerous changes that FSA has made during the pandemic. In your effort to oversimplify the process for students, you have buried us in more work than we can handle. You have our aid offices implementing multiple complicated, labor intensive, time consuming processes one on top of the over. Our institutions cannot just hire additional staff members when they are dealing with reduced budgets, lower enrollment and no longer have access to HEERF funding.	17	lowreyp@gtc.edu	Thank you for your comment. We are bound to implement the law as mandated by the FAFSA Simplification Act. Only an act of Congress can change such requirements.
Please consider simplifying the data being reported for FWS earning. I work at a large public two year and would need to coordinate with several departments to collect the data being requested. This would create a very large administrative burden for our office at an already busy time. In addition, like many schools, we are facing budget shortages and are understaffed and under resourced. Also, I am concerned that we will not have sufficient time to create such a sophisticated report by the reporting deadline. As an alternative, could FWS earning be reported on a W2?	18	Sarah Loepker / sarah.loepker@pcc.edu	Thank you for your comment. Please see the complete and updated Volume 4 of the COD Technical Reference (https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-05-23/2023-2024-cod-technical-reference-may-2023-update-now-available) for clarity on the required fields within this collection, and the reporting methods being made available. An additional Electronic Announcement with further operational guidance will also be forthcoming this summer.
If a student submits a FAFSA using the Data Retrieval Tool, but later needs to make any sort of correction, they are unable to do so without a paper SAR due to an issue with the Student or Parent Financials tab(s). It generates an alert that states they must enter their tax information on that page, but the fields where DRT info was used is greyed out and the student is not able to proceed due to the abovementioned alert. My hope is that the new digital FAFSA form will be programmed so that it recognizes previous DRT involvement and allows the student to proceed beyond the affected financials tab.	19	Kendra Rathbone / rathbone@uidaho.edu	Thank you for your comment. We will share your concern with the appropriate office for further consideration.
As a federally-recognized Work College, our FWS funds are distributed as grants. Our students do not receive a W-2, and their AGIs (if any) should already exclude FWS earnings. Will Work Colleges still be required to report this information to COD? It seems doing so would exaggerate the amount of excludable income.	20	Anonymous / sprya@berea.edu	Thank you for your question. This question will be addressed in a Electronic Announcement this summer that will provide further operational guidance on reporting FWS wages to the Department.
Like many others, I am gravely concerned about the FWS reporting requirement and the increased amount of administrative burden on our staff. We are a very small school, and our small staff has to administer all the federal programs, state programs, veteran's affairs, HEERF, etc. These are already very complicated to administer; adding more reporting requirements is going to place an untenable strain on our staff. We don't have an easy way to gather FWS earnings data, and our I.T. staff is also under-resourced. Please reconsider this requirement at least for the upcoming award year.	21	Anonymous	Thank you for your comment. We are bound to implement the law as mandated by the FAFSA Simplification Act. Only an act of Congress can change such requirements.