Resolving CONFLICTING INFORMATION New Aid Officers Workshop May 14-16, 2012

What the Reg’s say: 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 for Title IV Funds.

When Should Conflicting Information be Resolved? must 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 must 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 to Look? Student Eligibility Requirements Program Eligibility Requirements SAR Comment Codes: ◦ Federal Database Match Discrepancies ◦ C-Flags ◦ Rejects Subsequent ISIR Transactions

Student Eligibility Requirements Review of school records should include if the student is/has:  U.S. citizen or eligible non-citizen  Final High school diploma, GED  Ability To Benefit Test (ATB)  Admitted into eligible program/degree seeking  Academic level (undergrad, grad, professional, etc.)  Satisfactory Academic progress

Student & Program Eligibility Requirements 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

What are SAR Comment Codes? CPS adds comment codes and text to the students transaction to provide information to the student and to the institution about the students FAFSA ◦ Printed on the SAR and ISIR The comment code is three digits The codes are informational however some codes include information regarding discrepancies that require resolution by the applicant or school.

SAR Comment Codes that Require Resolution Federal Database Match Indicators ◦ C-Flags ◦ Rejects IRS Data Retrieval Tool Updates to Marital Status

What are the Federal Database Matches? 1.IRS  IRS Data Retrieval Tool 2.VA  Independent Veteran Status 3.SSA  Name, SSN, DOB & U.S. Citizen Match 4.SS  Selective Service Registration Match for Males born after DOJ  Drug Hold for applicants who were convicted of a drug felony while receiving Title IV Aid 6.DHS  Eligible Non-Citizen Match 7.NSLDS  Title IV Grant/Loan Overpayments, Loan Aggregates, Annual Loan Limits, Enrollment Reporting (TML), Loan Default, Bankruptcy, Loan Discharge 8.DOD  Afghanistan & Iraqi Service Grants

What is a Reject? A SAR comment code could involve information about Rejects which involves information the applicant/parent left out and requires resolution by the applicant/parent before CPS can calculate the EFC. ◦ The applicant or parent must take action to resolve a Rejected ISIR  Rejects are listed as: 1. Alpha- can be updated or reinstate that “data is correct” 2.Numeric- requires correction

What is a C-Flag? CPS generates a SAR comment code also known as C-Codes/C-Flags. This happens when either of the federal database matches results require resolution by the school due to discrepant information the applicant reported on the FAFSA.

C-FLAGS Requires resolution from the school typically consist of collecting documentation from the student and/or the FAA utilizing NSLDS.

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.

SAR Comment Text Guide 3 digit code Federal Database Match Example of Numeric Reject Example of a C-Flag

C-Flags & Rejects Most Common C-FLAGS Citizenship Selective Service Veteran Affairs Social Security Grant Overpayment Loan overpayment Loan default/discharge/Bankruptcy Most Common Rejects No signatures from either student or parent if student is a dependent Missing student/parent signatures when a correction or update is made to FAFSA Missing asset information and do not qualify for a simplified or auto- zero EFC Taxes paid are = or > than AGI SSN # wrong or mismatched Citizenship question blank or incorrect Parent information left out on dependents FAFSA

Informational SAR Comment Codes  SAR Code: 156& 157 Reminders sent to all applicants/parents who indicated Will File once Tax Filing Date has passed.  SAR Code: 002 Professional Judgment was performed by FAA  SAR Code: 284 Dependency Override was completed by FAA  SAR Code: 163 Homeless status approved by FAA  SAR Code: 073 & 074 Review of number in HHS reported the previous year increased significantly All codes can be found in the SAR Comment Codes and Text Guide: odesTextATTACH.pdf odesTextATTACH.pdf

What are Subsequent ISIR’s? A Subsequent ISIR is a new transaction received after submission of the initial FAFSA due to a Correction, Update or Adjustment. Applicant School CPS Each subsequent ISIR must be reviewed for the following: EFC Changes –check data elements that affect the amount and type of aid received must investigate if not previously verified SAR “C” Flag Updates Reject Codes Updates Comment Codes Updates NSLDS Updates

TAX Returns/Transcripts 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. Data elements are correct and consistent with FAFSA information AGI Taxes Paid IRA/Keogh deductions Untaxed income included on the tax return

Discrepant Tax Data FAA must have a fundamental understanding of relevant issues that can considerably affect the need analysis Publication 17 of the IRS is a useful resource for FAA: Available online at You are obligated to know: 1.Pages 4-7: whether a person was required to file a tax return 2. Pages: 7-8: what the correct filing status for a person should be 3. Pages 20-25: that an individual cannot be claimed as an exemption by more than one person 4. Pages explains criteria a person must meet to file as head of household.

Required to File a Tax Return Examples include: Filing Single under 65 years of age: $9,500 Married Filing Jointly under 65 years of age $19,000 both spouses Married Filing Separately any age: $3,700 Single Dependents (if parents or someone else) can claim you as a dependent on their taxes: $5,800

Correct Filing Status Single 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

HELPFUL RESOURCES IFAP Federal Student Aid Handbook, AVG, Chapter 5 SAR Comment Codes and Text Online review of Conflicting Information Policies: IRS Resource: Publication 17 Visit Or Call at to order a copywww.irs.gov NSLDS for FAA