information,	as	reported	by	the	schools	to	the	COD	System,	for	the	schools	involved.
Pell	Potential	Overaward	Process
A	student	may	receive	disbursements	from	more	than	one	school	during	an	award	year.	When	more	than	one	school
reports	disbursements	for	a	student,	the	COD	System	checks	to	make	sure	the	student	has	not	received	more	than	100%
(or	150%	if	qualifying	under	<Year-round=	Pell)	of	the	student9s	eligibility	for	a	Pell	Grant.
If	the	COD	System	receives	disbursement	information	that	will	cause	a	student	to	receive	more	than	100%	(or	150%	if
qualifying	under	<Year-round=	Pell)	of	the	student9s	<total	eligibility	used=	or	TEU,	the	student	has	entered	a	potential
overaward	(POP)	situation.	Remember,	to	certify	eligibility	for	the	<Year-round=	Pell	provision,	the	Additional	Eligibility
Indicator	(AEI)	must	be	submitted	for	disbursements	exceeding	100%	of	the	Scheduled	Award	to	be	accepted	in	the	COD
System.
The	COD	System	will	accept	the	disbursement	and	notify	the	schools	involved	in	the	POP	in	the	following	three	ways:
COD	sends	the	school	that	submitted	the	disbursement	that	caused	the	student	to	exceed	the	100%	(or	150%	for
<Year-round=	Pell)	TEU	for	the	year	warning	edit	68	in	the	response	document.
Weekly,	COD	sends	all	schools	that	have	accepted	and	posted	disbursements	for	students	in	a	POP	status	a	Pell	POP
report	that	will	identify	the	student	and	schools	involved.
COD	sends	all	schools	that	have	accepted	and	posted	disbursements	for	the	student	in	the	award	year	an	MRR
containing	the	Pell	contact	information	for	the	schools	involved.
Warning	edit	68	informs	the	school	that	submitted	the	disbursement	that	caused	the	student	to	exceed	the	100%	(or
150%	if	qualifying	under	<Year-round=	Pell)	TEU	for	the	year	that:
Pell	disbursements	for	a	student	have	been	received	from	two	or	more	schools.
The	student9s	TEU	is	greater	than	100.000%	or	150.000%	as	applicable.
The	POP	situation	must	be	resolved	within	30	calendar	days.
During	the	30-day	period,	the	Department	expects	each	school	involved	in	the	potential	overaward	to	review	the
student9s	award	and	disbursements	and	perform	the	proper	eligibility	calculations.	The	COD	System	will	accept	and	post
disbursements	that	decrease	or	increase	the	student9s	year-to-date	disbursement	amount.	Students	will	be	removed	from
POP	status	within	30	days	of	the	date	the	student	was	initially	placed	in	the	POP	if	the	student9s	TEU	becomes	100%	(or
150%	for	<Year-round=	Pell)	or	below	based	on	downward	disbursement	adjustments	submitted	by	the	schools.	If	after	30
calendar	days	the	situation	has	not	been	resolved,	the	COD	System	generates	a	negative	disbursement	that	reduces	all
accepted	and	posted	disbursements	to	$0	for	the	student	in	the	award	year	in	question	at	all	schools	involved.	Schools
should	document	any	phone	calls,	emails,	and	letters	that	were	part	of	their	attempts	to	resolve	the	POP	with	the	student
and	the	other	schools	involved	and	be	prepared	to	provide	that	documentation	to	COD	School	Relations,	if	requested.
Schools,	along	with	the	student,	must	work	together	to	resolve	the	POP	before	contacting	COD	School
Relations	for	help.	A	school	that	has	attempted	to	resolve	an	overaward	situation	with	the	other	schools	that	have
submitted	disbursement	records	for	the	student	and	has	been	unable	to	arrive	at	a	satisfactory	solution	should	call	the
COD	School	Relations	Center	to	request	<escalated	mediation=.	The	school	should	be	prepared	to	provide	the	name	and
social	security	number	of	the	student	involved.	The	COD	School	Relations	Center	will	review	the	POP	situation	and,	if
necessary,	refer	the	case	to	the	Department	for	additional	action.
To	prevent	repeated	POP	situations	from	occurring,	schools	must:
ensure	that	students	do	not	receive	Pell	awards	for	concurrent	enrollment	at	two	or	more	schools;
take	action	when	they	receive	warning	notices	from	the	COD	System;	and
correct	overaward	situations	prior	to	submitting	subsequent	disbursement	records	to	COD.
Schools	should	remember	that	failure	to	comply	with	these	requirements	may	call	into	question	a	school9s	administrative
capability	and	fiscal	responsibility	and	might	eventually	result	in	the	Department	taking	action	to	limit,	suspend,	or
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