Pell Grant Reporting under the Common Origination and Disbursement (COD) System

1845-0039 – Affected Public – Proprietary Institutions 1/28/2021

Institutions are required to report student Pell Grant payment information to the Department electronically. Electronic reporting is conducted through the Common Origination and Disbursement (COD) system. The COD system is used by institutions to request, report, and reconcile grant funds received from the Pell Grant program.

The Department uses the information collected in the COD system to aid in ensuring compliance with fiscal and administrative requirements under the HEA for the Pell Grant program and under 34 CFR 690 for the Pell Grant program regulations.

The minimum reporting requirement is one record for origination and disbursement data per student, per grant award, per award year. Institutions may correct an accepted COD record as many times as they wish but are not required to submit changes unless the student’s award amount changes from the accepted origination amount originally established in COD.

For the 2020-2021 award year, the projected number of Federal Pell Grant recipients is estimated to be reduced by 2%. Based on the 6,744,343 unduplicated student recipients for the Federal Pell Grant program for 2019-2020, the number of unduplicated Federal Pell Grant recipients for 2020-2021 is estimated to be 6,609,456 multiplied by .07 hours per recipient for all institutions to enter data in the COD system for a total of 462,662 burden hours.

We estimate the burden costs to the institutions to be $21 per hour. The average burden cost estimate for an institution is $1,803 (85.84 hours X $21/hour). For the 5,390 institutions the total cost is $9,715,902.

1,717 Proprietary institutions

925,324 responses X .07 hours = 64,773 burden hours