As noted in a June 10, 2026, Electronic Announcement, we will implement Common Origination and Disbursement (COD) System functionality to enable schools to begin reporting Federal Work-Study (FWS) earnings for the 2025 calendar year. Implementation is planned for June 28, 2026. In this Electronic Announcement, we provide operational information to assist schools in the reporting of student-level earnings information for the FWS Program.
Under the FAFSA Simplification Act, we will continue to use school-reported data for the FWS Program to accurately calculate the Student Aid Index (SAI) for aid recipients. FWS data reported for the 2025 calendar year will be used in the 2027–28 Free Application for Federal Student Aid (FAFSA®) processing cycle. In the following sections, we provide information about reporting FWS earnings to the COD System.
Schools must report, for each student, the total gross amount (both institutional and federal share, as applicable) of all FWS earnings for any portion of the applicable calendar year, rounded to the nearest whole dollar. For the 2027–28 FAFSA processing cycle, schools will be reporting FWS earnings disbursed at their institution from Jan. 1, 2025, through Dec. 31, 2025.
Schools must report FWS earnings amounts to the COD System in a manner consistent with the requirements for including such amounts on the W-2 (see General Instructions for Forms W-2 and W-3). Per the calendar year basis, the amount of FWS earnings should include all amounts that the school paid the student during the calendar year, from Jan. 1 through Dec. 31, even if the student performed the work outside of the calendar year. In addition, any portion of a student’s FWS earnings that the school paid in the form of non-cash contributions (e.g., payments toward tuition, room, or board, etc.), must be included in the total FWS earnings that the school reports to the COD System, except when a federally approved Work College makes such non-cash payments for work performed under the comprehensive work-service-learning program.
Schools must report for any student who received FWS earnings regardless of that student’s enrollment status at the school (i.e., a school will report FWS earnings paid even if the student is no longer enrolled at the school).
Because some students may attend different schools, there will be instances where more than one school is reporting FWS earnings for a particular student. The COD System will allow multiple schools to report for the same student. FSA will use the combined total of the student’s FWS earnings in the SAI calculation. Note: Schools will be able to view the total FWS earnings for each student (including other reporting schools and the respective amounts) on the COD website.
As explained in the COD Technical Reference, schools will report FWS earnings information via batch submission using the Campus-Based XML Schema version 1.0b or via the COD website. When reporting data, schools will be required to submit the following information:
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last name
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date of birth
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SSN
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FPS transaction number
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total FWS earnings
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calendar year
Schools may submit additional data elements. Full details about required and optional fields, valid values, and other business rules are in Volume 4 of the COD Technical Reference.
Note: The Campus-Based XML Schema version 1.0b includes an additional reporting block for Federal Supplemental Educational Opportunity Grant Program-related data, but we will not collect this data and will reserve it for future use, if needed.
As noted above, schools will report the total FWS for the 2025 calendar year. However, because the calendar year will overlap two different award years, schools will be able to report FWS data using two different methods:
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Calendar year totals by award year – the school submits two totals, one amount for the calendar year portion paid in award year 1 and a second amount for the calendar year portion paid in award year 2.
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Calendar year total amount only – the school submits one total amount for the full calendar year and includes no award year information.
As an example, Student A earned $1,800 in the 2024–25 award year ($900 in 2024 and $900 in 2025), and $2,400 in the 2025–26 award year ($600 in 2025 and $1,800 in 2026).
In this case, for reporting method 1, the school would report two separate FWS amounts of $900 and $600. Alternatively, for reporting method 2, the school would report one FWS amount of $1,500. In either option, the amounts paid in 2024 or 2026 would not be reported.
Important Note: A school cannot change the reporting method it chooses after COD accepts the record without first zeroing out all accepted records and starting over. For example, if a school submits a record for the 2025 calendar year with the amount paid during the 2024–25 award year and COD accepts it, COD will reject a subsequent record that denotes the 2025 calendar year only.
The ability for one campus to report on behalf of its locations and/or other main campuses with which it is affiliated is driven by the reporting and attending relationships established in the COD System. The COD System will set up these relationships in accordance with existing relationships between main campuses and their locations, as well as the Fiscal Operations Report and Application to Participate reporting structure currently utilized by schools. If your school has an issue with its reporting and attending relationships as established in the COD System, you can submit a request to change them via the FSA Partner and School Relations Center.
To ensure accurate SAI calculations at start up, we strongly recommend that schools plan to complete the submission and COD System acceptance of FWS earnings for the 2025 calendar year prior to the release of the 2027–28 FAFSA form. Timely advance reporting will also help limit unnecessary subsequent Institutional Student Information Record transactions.
If you have questions, contact the FSA Partner and School Relations Center at 1-800-848-0978. The contact center is open from 10 a.m. to 6 p.m. Eastern time, Monday through Friday. You may also email CODSupport@ed.gov.