Resolving CONFLICTING INFORMATION New Aid Officers Workshop May 16-19, 2011

DO I REALLY NEED TO KNOW? A school must have an adequate internal system to identify conflicting information—regardless of the source or whether the student is selected for verification—that would affect a student’s eligibility. The school must resolve all such conflicting information, except when the student dies during the award year.

WHEN IS IT IMPORTANT? If your school has conflicting information concerning a student’s eligibility or you have any reason to believe a student’s application is incorrect, you must resolve the discrepancies before disbursing FSA funds If you discover discrepancies after disbursing FSA funds, you must still reconcile the conflicting information and take appropriate action under the specific program requirements.

WHERE DO I LOOK? Eligibility Elements ISIR (First and Beyond) Tax Return All documents received

ELIGIBILITY ELEMENTS Review of school records should include if the student is/has: U.S. citizen or eligible non-citizen or otherwise eligible for aid High school diploma, GED or passed ATB test Admitted into eligible program Academic level (undergrad, grad, professional, etc.) Academic progress

ISIR DATA (FIRST AND BEYOND) SAR “C” Flag Reject Codes Comment Codes NSLDS information ISIR Corrections

SAR “C” FLAG A flag of “C” is an indicator that institutional resolution is required and no EFC will be calculated. Typically a “C” flag is generated if the student’s FAFSA information could not be matched or is matched with information in a specific database. Examples include: Selective Service Citizen/Non-Citizen Status Social Security Number Veterans Status NSLDS Drug Conviction Status

REJECT CODES A reject code is produced when data is missing/questionable and an EFC is not calculated. Examples: Missing signature Taxes paid and AGI are inconsistent/missing Asset information is missing and SNT is not met Incorrect DOB/SSN Marital Status missing/questionable

COMMENT CODES A numeric comment code is shown on ISIR when conflicting data may be present and/or when a SAR “C” flag and reject codes are present. If only comment codes are shown (No SAR “C” flag or reject code) an EFC is calculated. Examples: Tax return is estimated Household size Income is different or the same Taxes paid Homelessness Emancipated Minor Dependent without parental data

NSLDS INFORMATION Changes to a student’s NSLDS information (loans and/or grants) is present on all initial and subsequent ISIR transactions. Each NSLDS record shows its own transaction number. NSLDS information may generate a SAR “C” Flag, Reject Code and/or a comment code at any time. School is required to resolve any conflicting data generated by a new NSLDS/ISIR transaction.

ISIR CORRECTIONS A corrected/subsequent ISIR can be generated by: Applicant School Another school NLSDS transaction Each ISIR must be reviewed for changes to data elements and: SAR “C” Flag Reject Codes Comment Codes NSLDS transaction

TAX RETURNS May be requested or student may have provided without request. All tax returns on file must be reviewed whether or not the student has been chosen for verification. Filing status is correct and consistent with other information AGI Taxes Paid IRA/Keogh deductions Untaxed income included on the tax return (except schedules)

Not Tax Experts!!!! No, we aren’t!!! But we do have a responsibility to have a “fundamental understanding” of tax issues that can affect a student’s eligibility for assistance. You are obligated to know: whether a person was required to file a tax return, what the correct filing status for a person should be, and that an individual cannot be claimed as an exemption by more than one person.

WHO MUST FILE TAX RETURN

CORRECT FILING STATUS? Single Married Filing Jointly or Separately not married divorced, legally separated, widowed (no dependent children) Married Filing Jointly or Separately married and living together married and living apart, but not legally separated Head of Household unmarried or considered unmarried on last day of year filed a separate return spouse did not live in the home during the last 6 months of the year home was the main home of the qualifying dependent

ALL DOCUMENTS RECEIVED Examples: Institutional Applications Transcripts (High School and College) Academic Progression Changes to Major/Eligible Program Changes to Enrollment All aid received (even by other offices) Policies must be written, equitable and consistent

HELPFUL RESOURCES www.ifap.ed.gov www.irs.gov www.nslds.ed.gov Federal Student Aid Handbook Application and Verification Guide ISIR Guide – Appendix A – Reject Codes and Reject Reasons ISIR Guide – Appendix B - Database Matches and Match Flags SAR Comment Codes and Text www.irs.gov Publication 17 www.nslds.ed.gov