Direct Loan EI% — System Process Flow

Section 1 — Three-Level Credit Tracking (Required Data Structure)

Level 1

Enrolled Credits

What the student registered for. Captured at packaging. Used for initial award calculation. Source: SIS registration system.

Level 2

Began Attendance Credits

Courses where student attended at least once — verified by faculty roster confirmation or LMS academic activity. Required before first disbursement can release.

⭐ Critical Missing Piece

Level 3

Census-Verified Credits

Official enrollment as of institutional census date. Used to calculate final EI% and identify overawards. Drives annual Pell and loan recalculation.

Section 2 — Disbursement Basis Formula (Determine at Every Disbursement)

Disb Date < Census Date

→

EXPECTED

Overaward possible at census if credits drop

Disb Date ≥ Census Date

→

ATTEMPTED

Actual census credits used; enrollment drop already resolved

Section 3 — Complete Process Flow (8 Steps · Click to Expand)

Fall Term

Aug 1

Packaging

Packaged

▼

Planned Credits

12 credits

Snapshot

PackagingSnapshot

Sub Award

$3,500

Unsub Award

$2,000

Student registers for 12 credits — store as Level 1 (Enrolled Credits)
Award calculated based on planned enrollment (full-time = 12 credits)
No attendance verification required yet — disbursement not yet triggered

Aug 15

Pre-Disbursement Check ⛔ Gate

Verify

▼

Required Check

BeganAttendance ≥ 6 credits

If Check Fails

BLOCK Disbursement

Query faculty roster confirmations and LMS academic activity logs
BeganAttendanceCredits = Level 2 — must verify each course individually
Valid attendance: physical class, academic assignment, exam, documented LMS activity
NOT valid: logging into LMS without academic activity; living in housing only
If student hasn't attended enough courses to reach half-time → block release, flag account

34 CFR 685.303(b)(2) — Must verify student "begun attendance" in half-time courses before first disbursement

Aug 20

Disbursement ⭐ Primary Data Capture

Disbursed + Locked

▼

Disbursement Date

Aug 20

Census Date

Sep 5

Basis Calculation

Aug 20 < Sep 5 → EXPECTED

Lock Status

IMMUTABLE after COD export

EnrolledCredits

BeganAttendanceCredits

EnrollmentStatus

FT (Full-Time)

Amount Disbursed

$1,750 sub / $1,000 unsub

Create immutable DisbursementSnapshot at COD export time — this is the primary record
Set IsLocked = TRUE immediately after COD export — no retroactive changes permitted
Link snapshot to COD Batch ID for complete audit trail
Any future enrollment changes update CourseEnrollment table only — not this snapshot

COD Tech Ref — Enrollment status required as of disbursement date; snapshot must match COD export batch

Aug 25

Student Drops 6 Credits Decision Fork

Decision Required

▼

Key question: Did the student attend those 6 dropped credits at any point?

NO — Never Attended

Apply § 668.21 → Return Funds

Student enrolled and was disbursed, but never attended the dropped courses. Return funds without any R2T4 calculation. This is NOT a withdrawal scenario.

YES — Attended, Then Dropped

→ Continue to Step 5 (Census)

DroppedAfterAttendance = 6. Wait for census to determine actual EI% and whether overaward exists. If student fully withdraws → § 668.22 R2T4 applies.

Attendance determination source: faculty first-attendance date or LMS first academic event date
Update CourseEnrollment table only — the locked DisbursementSnapshot (Step 3) must not change
Set NeverAttendedCredits = EnrolledCredits − BeganAttendanceCredits for each affected course

Sep 5

Census Date — EI% Calculation

Overaward Found

▼

Attempted Credits (Level 3)

6 credits

EI%

50% (6 ÷ 12 FT)

Disbursed Based On

12 credits (EXPECTED)

Fall Overaward

$875 sub + $500 unsub

Store CensusSnapshot: AttemptedCredits=6, EI%=50%, linked to DisbursementSnapshotID
Allowed fall sub: $1,750 × 50% = $875. Disbursed: $1,750. Overaward: $875
Allowed fall unsub: $1,000 × 50% = $500. Disbursed: $1,000. Overaward: $500
Overaward not collected now — carried forward and applied as reduction to spring disbursement
Create DisbursementAdjustments record with OverawardAmount and AppliedToTerm='Spring'

Spring Term

Dec 15

Spring Repackaging ⭐ Lookback Required

Adjusted

▼

Retrieve From Fall

DisbursementSnapshot + CensusSnapshot

Annual EI%

(6 fall + 12 spring) ÷ 24 = 75%

Annual Max Sub

$3,500 × 75% = $2,625

Annual Max Unsub

$2,000 × 75% = $1,500

Already Disbursed (Fall)

$1,750 sub / $1,000 unsub

Spring Allowed (After Adj)

$875 sub / $500 unsub

Must retrieve fall DisbursementSnapshot — confirm basis was EXPECTED and credits were 12
Must retrieve fall CensusSnapshot — actual credits = 6, overaward = $1,375 total
Recalculate: Spring available = Annual max − Fall disbursed − Fall overaward
Repackaging timing rule: preferred window is after fall census but before spring term start
If repackaging mid-fall: flag for re-review; census data not yet final

Jan 15

Spring Disbursement

Disbursed

▼

Re-run half-time attendance gate (Step 2 logic applies again for spring)
Store Spring DisbursementSnapshot — same structure as Step 3, locked at COD export
Disburse adjusted amounts: $875 sub / $500 unsub
DisbursementBasis: EXPECTED or ATTEMPTED — recalculate against spring census date
Link to Fall DisbursementSnapshotID and Fall CensusSnapshotID for complete AY audit trail

Feb 1

Spring Census — AY Complete

AY Complete

▼

Store Spring CensusSnapshot: AttemptedCredits, final EI%, linked to Spring DisbursementSnapshot
Recalculate final annual EI% with confirmed spring credits
Confirm no additional overaward from spring enrollment changes
All four snapshots now complete and linked: Fall Disb → Fall Census → Spring Disb → Spring Census
Award year reconciliation complete — all records locked, COD confirmed, audit trail intact

Section 4 — Enrollment Change Scenarios (Critical Routing Decision)

Never Attended

Attended: NO

§ 668.21

Return funds — no R2T4 calculation. Student enrolled and was disbursed but never attended the dropped courses. Return all aid attributable to credits not attended. This is not a withdrawal — do not run R2T4.

Attended Then Withdrew

Attended: YES

§ 668.22 (R2T4)

Perform R2T4 calculation. Student began attendance but ceased before completing the payment period. R2T4 determines earned vs. unearned aid based on percentage of payment period completed.

Attended, Failed

Attended: YES

SAP Only

No return required. Student attended the full payment period but earned failing grades. Aid is not returned. Applies to Satisfactory Academic Progress evaluation only. Credits count toward attempted hours.

Section 5 — Six Key Business Rules for Implementation

Capture at COD Export Time

The DisbursementSnapshot is the primary immutable record. Create it at COD export. Set IsLocked = TRUE. No retroactive changes permitted after this point.

Three-Level Credit Tracking

Track all three separately: Enrolled Credits (Level 1) → Began Attendance Credits (Level 2) → Census-Verified Credits (Level 3). All three are required database fields.

Attendance Verification is Mandatory

Must verify BeganAttendance ≥ half-time minimum before releasing first disbursement. Faculty roster or LMS academic activity are the acceptable sources.

34 CFR 685.303(b)(2)

Disbursement Basis Formula

If DisbursementDate < CensusDate → store "EXPECTED." If DisbursementDate ≥ CensusDate → store "ATTEMPTED." Calculate and lock this value in every snapshot.

Never Attended ≠ Withdrawal

Two completely different regulatory paths. Never attended → § 668.21, return without R2T4. Attended then withdrew → § 668.22, perform R2T4. The system must distinguish these at the course level.

Spring Requires Fall Lookback

When packaging spring disbursement, always retrieve fall DisbursementSnapshot and CensusSnapshot. Recalculate annual EI%. Apply any fall overaward as a reduction to spring disbursement amount.