ISIR Codes and Resolutions Stephanie Alford Neophyte 2018 ISIR Codes and Resolutions Stephanie Alford

Icons = question (most points gets a prize) = something to ponder or take back to ask your office

Background Once a student completes a FAFSA the application goes to the CPS. What does CPS stand for? Central Processing System

The CPS Captures FAFSA data Calculates an EFC (if possible) and notifies applicants and institutions Conducts database matches- generates comment codes Checks for possible inconsistencies, contradictions, or missing data CPS This slide shows some of the primary roles of CPS. It is their responsibility to process the data once received, conduct database matches, calculate the EFC when possible, and then disseminate the data to students school, and other agencies.

How often and who pulls in your schools’ ISIRs? Output Documents A SAR is sent to the student An ISIR is sent to the school(s) and other agencies What do SAR and ISIR stand for? How often and who pulls in your schools’ ISIRs? Student Aid Report, Institutional Student Information Record

What is the highest tran number you have seen? Transactions A transaction is an interaction between the CPS and the student applicant, your school or another school. The initial processing of the FAFSA results are transaction “01” of the ISIR. Each correction generates a new record that is identified as a subsequent transaction, or number. What is the highest tran number you have seen?

Do you know where to find these in your system? Transaction 01 295 You did not report information about your parents on your 047 Description deleted per Department specifications 001 WHAT YOU MUST DO NOW. Use the checklist below to make 049 You must report a valid Social Security Number (SSN), name, 168 You must provide answers for your parents' marital status 129 You must provide your parent(s)' income information in Items 150 You must provide asset information for you and your parent(s). 108 Your parent did not sign your FAFSA or the SAR corrections Do you know where to find these in your system? If the number of transactions exceeds 30, subsequent transactions are rejected by the CPS for “too many transactions.”

Focus Today- Comments on the ISIR Comment Codes- C Codes (sometimes referred to as C Flags)- database match results that require resolution by school- How many? Rejects- application is ‘rejected’

Where do comments come from? FAFSA data Database matches Corrections Missing FAFSA data Where do comments come from?

SAR Comment Codes and Text Guide (AKA Your BFF) Text definition Notes/Changes Reason for comment C Code Reject Code Action needed

What examples can you think of? Rejects When logical assumptions can’t be made Missing information Conflict of data EFC not calculated Comment(s) provided on SAR/ISIR Correction is required What examples can you think of? Signature missing In certain instances, the application is rejected if the student’s data is in conflict. an independent student answers that he or she is not married but provides financial information for a spouse Unusual high number of family members

Types of Reject Codes Alpha reject codes Numeric reject codes Verifiable Same value can be re-entered Different value may be entered Numeric reject codes Non-verifiable Questioned data must be changed or provided

How does your school handle rejects? Rejects Codes A- DOB equals 1900-1943 W- Usually high number in family 5- Missing in invalid DOB 12- Taxes paid greater/equal AGI 14- Student signature missing How does your school handle rejects? The school can override rejects, request info from family, or make family go back to FAA Access

What is a C code? A flag of C is an indicator that institutional resolution is required. Use the FSA Handbook, Student Eligibility chapter (Volume 1) for detailed information about the action needed to resolve discrepancies. “C” codes are typically associated with student eligibility issues. What are the seven databases eligibility is checked?

Social Security Administration (SSA) To be eligible to receive FSA funds, each student must provide a correct Social Security number (SSN). To confirm the student’s SSN for schools, the Department conducts a match with the Social Security Administration. The CPS verifies that the name and birth date associated with the SSN match the name and birth date on the application. Match Issues No match on SSN No match on name or DOB Missing Info

Documentation for Issues SS Card Driver’s License Birth Certificate Marriage Certificate

Citizenship Match- SSA A student has to be a U.S. citizen, a citizen of the Freely Associated States, or an eligible noncitizen to be potentially eligible for federal student aid. The Department of Education (The Department) matches all applications with the Social Security Administration (SSA) on U.S. citizenship status. Successful- no comment Data doesn’t match (SSN/Name/DOB) Citizenship not confirmed- student needs to provide documentation (if citizen), if noncitizen student must submit correction with A# (Alien Registration Number)

Citizenship Documentation If the status cannot be confirmed, the student must provide documents proving U.S. citizenship, citizenship of the Freely Associated States, or eligible non-citizenship: Birth Certificate U.S. Passport Certificate of Naturalization or Citizenship Can a passport be expired? Original documentation can be expired except limited passport If now provide ARN must reenter and fafsa and submit so DHS can confirm

Department of Homeland Security (DHS) If the student provides an alien registration number (ARN) on the FAFSA, his record is also sent to DHS to check noncitizen immigration status. Eligible Noncitizens- Lawful permanent or conditional residents in the U.S. for other than a temporary purpose with intention of becoming a lawful permanent resident

Non Citizen Matches Matches A# with DHS records Successful- confirmed immigration status Not enough info- A# is missing or wrong Status not confirmed- secondary confirmation needed * Automated- by CPS * Third Step Verification- by school United States Citizenship and Immigration Services

Common C Codes

Third Step Verification- NEW Formerly G-845 Collect Documentation Submit to SAVE system- NEW When you receive the SAVE response, you determine the student’s eligibility (FSA Handbook- Volume 1) What does SAVE stand for?

Documentation Must be unexpired Permanent Resident Card (I-551) Resident Alien Card (I-551) Arrival/Departure Record (I-94) Machine Readable Immigrant Visa

Other eligible noncitizens Refugee Persons granted asylum Persons paroled in U.S. Cuban-Haitian Conditional entrants Jay Treaty Must photocopy front and back Are deferred action childhood arrivals eligible? DACA- no, but may get state and institutional aid

Selective Service System (SSS) Males 18-25 must register Can say ‘yes’ on the FAFSA Can register at post office or online Students who knowingly and willfully failed to register are not eligible for FSA funds Why must males register?

Exemptions Males 18-25 must register Can say ‘yes’ on the FAFSA Can register at post office or online How many exemptions to the requirement can you think of? 10

Selective Service Matches Successful match Shows the student is registered, exempt, or too young to register Registration not confirmed Student must register or show proof of exemption Unsuccessful registration CPS won’t forward the student for registration because info is missing Selective Service matches do not result in a rejected ISIR if registration is NOT confirmed or if it was an unsuccessful registration. Instead, if a c-code is generated, the FSA Handbook requires certain steps in order to resolve this issue.

Failure to Register Determining if non-registration was knowing and willful Student must get a ‘status information letter’ from SS Final decision rests with school Have you seen this letter? What have you taken for documentation?

Your student has a C code on his SAR, with the 030 comment Your student has a C code on his SAR, with the 030 comment. This student was born on October 31, 1971 and entered this country on January 2, 1999. He is an eligible non-citizen. Is he required to register for Selective Service? What documentation would you collect? Student was 28 when he entered this country—he is exempt from registering with Selective Service—Student eligibility page 62

Veterans Affairs (VA) Used when a student not independent for a reason other than veteran status Not a veteran C flag – resolution required Not in database Student on active duty Veteran matches do not usually result in a rejected ISIR, but usually generate a c-code if the VA is unable to confirm status. Your institution may only resolve a VA mismatch if it is in relation to Independent status.

If a student indicates he/she is independent based ONLY on Active Duty Military or Veteran status, and the status cannot be confirmed, then the ISIR/SAR is rejected. The only way to resolve this issue to perform a dependency override, and make the student independent.

Common C Codes Dept of VA Veteran Status Data Match 162 and 173 The Dept of VA did not confirm that you are or will be a qualifying veteran for purposes of receiving federal aid…

VA Resolutions Independent if: At least one day active duty (other than training or National Guard or Reserve enlistee activated only for state or training purposes ) Documentation DD-214 A letter from a superior officer that documents the call-up to active duty (for national guardsman or reservists) What must the ‘character of service’ show?

GI Joe completes his FAFSA and indicates that he is a veteran GI Joe completes his FAFSA and indicates that he is a veteran. His ISIR comes back as a rejected SAR because the parent information and signature is missing. You speak to Joe and discover that he has recently left the army. He shows you a copy of his DD214, which indicates that he received a dishonorable discharge. How would you handle this situation? His “Character of Service” must be other than dishonorable. He would not be considered independent because of Veteran status alone.

National Student Loan Data System (NSLDS) Defaulted loans Bankruptcy/Discharged loans Unusual enrollment history Overpayments of grants or loans/Fraud Loan limits

Bankruptcy A student who has filed for bankruptcy may need to give additional documentation before receiving aid. Depends on loan code- check NSLDS for code Ex- Code DO= no further FSA funds unless the student provides school with documentation from the holder of the debt stating it is dischargeable

Disability Discharge A student who had a loan discharged for disability may need to give additional documentation before receiving aid. Ok for FSA funds but… if they want DL or Teach Must have physician’s certification that student has the ability to engage in substantial gainful activity Borrower must sign statement acknowledging that the new loan or TEACH grant can’t later be discharged for any present impairment unless it deteriorates so that he is again totally and permanently disabled. If the borrower requests a new loan or TEACH Grant during the post-discharge monitoring period, he must also resume payment on the old loan before receipt of the new loan or TEACH grant.

Unusual Enrollment History To reduce fraud and abuse of Title IV Looking for patterns of a student receiving Title IV then withdrawing or receiving aid at multiple schools during the same term. If student is flagged school must review academic records (their institution and/or others) during the past 4 years to determine if/why academic credit wasn’t earned.

Defaults- DL, FFELP, Perkins If NSLDS still shows a default you can use the following documentation from the loan servicer: Repayment in full (including consolidation)- voluntary or involuntary Satisfactory repayment arrangements- 6 voluntary payments on time (still in default though) Loan rehabilitation- 9 voluntary payments within a 10 mo. period

Aggregate/Annual Loan Limits Pull NSLDS to check most recent totals Can still receive FSA funds unless they have gone over If over limit, can’t receive any FSA funds until excess is repaid - Need letter from holder showing excess has been repaid or there are satisfactory repayment arrangements made

Overpayments and Fraud Refer to loan holder

Subsidized Usage Limit Identifies applicant records that are being tracked based on regulations limiting the maximum period of time (measured in academic years) that a student can receive DL to 150% of the published program length of the program in which the applicant is currently enrolled.

How does your school handle these? NSLDS History NSLDS scans or postscreens its database weekly to find cases in which a student’s status has changed. If it finds a change that affects eligibility, it notifies CPS. The CPS sends an updated ISIR to the school. How does your school handle these?

Department of Defense (DOD) Determines if the student had a parent who died as a result of military service in Iraq or Afghanistan after 9/11/01. The student may be Pell eligible.

Drug Conviction Student is disqualified from receiving FSA if convicted for a federal/state offense (possession or sale of illegal drugs) while receiving Title IV aid. If a student regains eligibility during the award year the school must certify student completed rehab program Is this drug question checked against a database match?

Drug Conviction Worksheet

Department of Justice Anti-Drug Abuse Act of 1988 says judges can deny aid to persons convicted of drug trafficking and possession. CPS has ‘hold file’ of those convicted. This is separate from the drug conviction question. Will generate a reject.

Pell LEU Comments 345-357 tell the school about a student’s Pell LEU (600% max): % is high % is close to 600 limit % is at or exceed 600 % is no longer exceeding 600

Comment Codes 400/401 To ensure that correct information is used to determine the applicant’s Title IV eligibility The institution must review the relevant data items for all possible conditions noted. The school may need to obtain documentation to support the accuracy of the information. If the information is determined to be incorrect, institutions must submit corrections.

How does your school handle these? What’s Next? Once you have ‘cleared’ a C-flag or have a valid EFC you are good to go HOWEVER… You may have follow-up- ex. Default You may receive a subsequent ISIR tran with new C-flags (you must look at these)! How does your school handle these?

ISIR Comment Codes Reference Materials SAR Comment Codes and Text The ISIR Guide FSA Handbook, Volume 1- Student Eligibility www.ifap.ed.gov

Director, Financial Aid Thank You! Stephanie Alford Director, Financial Aid Goucher College stephanie.alford@goucher.edu