Financial Aid Counselor Comment Code 399 Megan Nicholson Financial Aid Counselor

399 Code – What is it? Prior Prior Year – 2015 Tax Information One-time situation Discrepancies in AGI, Taxes Paid, Wages, etc. Additional Financial Information and Untaxed Income Warnings- cross year edits EFC change threshold

Delays Increased attrition C Code 399 Appears Identify Hold Aid Research Outreach Collect Documents Resolve Update Delays Increased attrition

How is it resolved?

How is it resolved? IRS Data Retrieval IRS Tax Transcript 1040s W2s Other Untaxed Income documentation

Resolved with lower EFC Institution must disburse any additional 2016-2017 aid, consistent with late disbursement rules 34 CFR 668.164(g) Resolved with higher EFC Institution must determine 2016-2017 eligibility based on the corrected EFC and not make additional disbursements for which the student is no longer eligible Student must repay funds they are no longer eligible for

Exceptions Changes in number in household, number in college, and assets will not cause 399 Graduate students Professional Judgements Switched parents Dependency Status or marital status Non Pell Grant eligible (maybe) 399 goes away or reprocessed

Unable to resolve? Disbursement treated as an overaward for need-based 2016-2017 aid Federal Work Study ceases Pending aid cannot be disbursed September 9, 2017 deadline

Scenarios Q- There is no Comment Code 399 on the 2017-2018 ISIR. A student called our office to ask why their financial aid package was different between 16-17 and 17-18. We noticed income differences. Do we need to do anything? Q- A parent of a dependent student was single in 2015. They were married September 20th, 2016. Do we need to include step-parent’s income on 2016-2017? 2017-2018? Q- A student claimed $200,500 in assets in 2016-2017 and $0 in 2017-2018. Do we need to resolve this discrepancy? Q- A student received a Comment Code 399 after they were enrolled at our institution. Do we need to resolve the conflicting information? Q- Are we required to resolve conflicting information on a Comment Code 399 if it will not affect the EFC for either award year?

Discussion

Questions? Comments? Megan Nicholson Financial Aid Counselor mnicho17@mail.wvu.edu 304-293-0556 EarlyFAFSAFeedback@ed.gov

Additional Information and Resources https://ifap.ed.gov/dpcletters/GEN1614.html https://www.nasfaa.org/ppy_conflicting_info https://ifap.ed.gov/eannouncements/031816EarlyFAFSAEA4DeterminingFAFSAPriorPriorItems.html https://ifap.ed.gov/eannouncements/013017CPSModifyAssigSARCommentCode399on020517RelReprocessing020617.html https://www.nasfaa.org/uploads/documents/PPY_Conflicting_Webinar_QA.pdf http://askregs.nasfaa.org/link/portal/16113/16151/Article/2949/Is-Resolution-Required-If-the-Student-Switches-Parents-Between-Award-Years-and-Has-Comment-Code-399 http://askregs.nasfaa.org/link/portal/16113/16151/Article/2910/Are-Graduate-Students-Exempt-from-Resolving-Comment-Code-399