1. AASFAA Fall Conference 2016
Verification and Conflicting Information
with PPY

2. Verification Vs. Conflicting Information
The process used by the institution to check the accuracy of the information the student, and parent if a dependent student, provided when applying for Title IV aid. Information is verified by obtaining documentation or, in some cases, a signed statement attesting to the accuracy of the information
Resolving Conflicting Information
The process of ensuring the consistency of information related to the student’s application throughout the institution. All conflicting information must be reconciled before disbursing any Title IV aid.

3. 17-18 - Prior-Prior Year Begins

4. PPY and Its Affects
Income information collected on the FAFSA will be from one year earlier than what was previously collected – this is sometimes called “Prior Prior Year” or PPY information.
Because of this switch in the income information year, students are able to apply for the FAFSA earlier than previously allowed.
Below is a table providing the summary of key dates as we transition to using the early FAFSA submission timeframe and earlier income information.

6. Verification Tracking Groups
Standard (V1)
Custom (V4)
Aggregate (V5)
Household Resources (V6)
Standard (V1)
Custom (V4)
Aggregate (V5)
V6 Eliminated in the year

7. Changes in 17-18
If nontax filer and selected for verification, must get confirmation of non-filing status from IRS (can be obtained from IRS by using Form 4506-T and checking box 7)
SNAP and Child Support Paid removed from V1, V4, and V5
Elimination of V6 Tracking Group
GEN (Publication Date: April 5, 2016)

10. Verification Notes
Income information used for verification on the FAFSA may be used to satisfy verification; HOWEVER, schools must obtain new documentation each award year for the number of household members, number in college, and identity and statement of educational purpose
Military members unable to obtain a copy of their high school diploma or transcript may use their DD214 as an alternate means to verify their high school completion status

11. Verification Notes
In 16-17, CPS may move applicants from previously assigned Verification Tracking Groups V1, V4, and V6 to Verification Tracking Group V5 based on corrections made to the applicants record or other information available to FSA
Right now this is expected to be practice in the year as well with the exception of the V6 group that is eliminated in 17-18
Expected to be minimal

12. Amended Tax Return – 1040X
It is NASFAA’s understanding that you cannot automatically use line 8 from the IRS Form 1040X for the amount of income tax paid when completing the verification. You first must check whether line 15 of the 1040X shows an amount for an excess advance premium tax credit repayment. If the tax filer is claiming an excess advance premium tax credit repayment on the amended return, the box for IRS Form 8962 on line 15 will be checked and Form 8962 should be attached to the amended return.

13. Amended Tax Return Continued
If the filer is not claiming an excess advance premium tax credit repayment on the amended return, you may use the amount on line 8 of the amended return for the amount of the taxes paid. However, if the filer is claiming an excess advance premium tax credit repayment on the amended return, you must reduce the amount of taxes paid on line 8 of the amended return by the amount of the excess advance premium tax credit repayment that is reported on line 29 of Form 8962.
From NASFAA AskRegs Knowledgebase – NASFAA News 8/15/16

17. Conflicting Information: GEN16-14
When and FAFSAs conflict, ED determines whether potential change in EFC is significant and flags with C code and comment code 399 for resolution by school, UNLESS
Student is not expected to be Pell Grant eligible in
Professional Judgment was exercised in either year
Dependency status changed
Student or parent marital status changed

18. Conflicting Information: GEN16-14
Only aid applicants with the 399 code on the ISIR require resolution for cross- year conflicting information
Only the ISIR will carry code 399
Other rules for verification and resolution of other conflicting information are unchanged and must be observed for all applicants

19. Conflicting Information: GEN16-14
If ISIR is flagged with code 399, school is not required to resolve conflicts if the school:
Never received a ISIR (i.e., CPS did not provide one to the school’s SAIG mailbox); OR
Did not and will not disburse Title IV aid based on either of the ISIRs

20. Conflicting Information: GEN16-14
If ISIR is flagged with code 399, school must resolve conflict if school:
Received a ISIR and disbursed, or may disburse, aid based on that ISIR (regardless of whether school will disburse aid for ); OR
Received a ISIR but did not review or process that ISIR (resolution might still affect eligibility)

21. Resolution: GEN 16-14
If either FAFSA used IRS-DRT, that is presumed the correct data unless subsequently changed
If data was already verified in either award year, verified data is considered correct and can use this information to submit any needed corrections
Exception: amended tax return was filed subsequent to IRS download or verification
In all other instances, school will likely need to collect documentation to resolve conflicts

24. Example 1 Institution receives 2016-2017 ISIR for student
Student never attends and no record created in institution’s financial aid management system
ISIR goes to “holding” or “staging” table in financial aid system
Institution receives ISIR for student flagged with comment 399 & C code
Institution processes aid; intends to disburse

25. Example 1 Must the institution resolve the conflicting data?
Yes, and must adjust aid accordingly

26. Example 1: CAUTION!
Be sure to put a process into place to ensure that ISIRs in staging or holding tables are not overlooked, OR
Establish a policy to resolve conflicts for every ISIR with comment 399, regardless of ISIR receipt status

27. Example 2 Student files 2017-2018 FAFSA in December 2016
Institution awards aid in February 2017
Student files FAFSA in May 2017
Intends to enroll Summer 2017 (16-17 trailer)
A subsequent ISIR transaction with comment 399 and C code is generated due to new conflict arising out of the new FAFSA filing

28. Example 2 Must the institution resolve the conflicting data?
Yes, and must adjust aid for both award years

29. Example 2: CAUTION!
Some institutional processes might not catch the subsequent ISIR with the new C code until it holds up disbursement for the fall
But, the institution has awarded and disbursed aid in the summer without resolving the conflict as required
Be sure to have a process in place that identifies new ISIRs with comment 399 as they come in and checks whether aid was disbursed or may be disbursed

30. Example 3
Institution receives ISIR for ; awards and disburses aid
Student files FAFSA in October 2017; ISIR generated with comment 399 and C code

31. Example 3 Must the institution resolve the conflicting data?
Yes, prior to disbursing and aid
No resolution is required for because it is past the last date to submit ISIR corrections for that award year (Sept 9, 2017)

33. Example 3: CAUTION!
Be sure that all ISIRs with comment 399 and C code that are received prior to September 9, 2017, have all conflicting data resolved and corrections are submitted (main concern in submitting corrections is with because of deadline)
NASFAA is seeking clarification for ISIRs received very close to this deadline

34. Example 4 Student receives aid from institution in 2016- 2017
Student files FAFSA in May 2017, which is flagged with comment 399 and C code
Institution reaches out to student to provide documentation to resolve conflict
Student does not respond to request/does not adequately explain the reason for the conflict

35. Example 4 What must the institution do?
Institution must treat aid as an overaward
Institution may not disburse future aid
Institution may not disburse aid
Institution must cease paying student out of FWS funds immediately

36. Resolving Conflicting Data: GEN16-14
If the required correction is to the record, the institution must correct the ISIR and use the corrected EFC for awarding and disbursing all Title IV aid for
If the required correction is to the record, the institution must correct the ISIR and ensure that the student’s awards and disbursements for are based on the correct EFC
Exception: records cannot be corrected after September 9, 2017

37. Resolving Conflicting Data: GEN 16-14
If in either year aid was disbursed on an incorrect EFC that was lower than the correct EFC, the student is considered overawarded
If the school is unable to resolve the conflicting information (student did not respond to the institution’s request for information or student did not adequately clarify the reasons for the conflicting information):
Student is considered to be overawarded for any need- based Title IV aid that was disbursed, and
Student must cease earning FWS immediately

38. Resolving Overawards: GEN 16-14
Student is liable for overpayments
Even if aid was used to pay institutional charges, school is not financially liable for any repayment based upon the resolution of conflicting information
Overawarded Direct Subsidized Loans are repaid under promissory note (like R2T4)

39. From GEN 16-14
Strike in 3rd row, 3rd column based on AskRegs posted in NASFAA News on 10/3/16 which supersedes GEN 16-14

40. Information from the FAQ
September 29, 2016 the White House announced that Pell Charts will be released in mid- October; date for campus-based aid is based on Congressional action and may not be released until February.
EFC calculation will use updated need analysis tables. Those tables have now been published.
COD functionality will not be available for award originations until March 2017
IRS DRT will be available on October 1, 2016

41. Information from the FAQ
FAFSA will not pre-populate income information on a renewal application.
The Department of Education will not release the “threshold” amount at which they will flag a student with comment code 399.
Any student with a comment code 399 must have conflicting information resolved even if they are not selected for verification.
All conflicting information must be resolved before institutions complete a PJ.

42. Information from NASFAA Q&As
Comment Code 399 will only appear on ISIRs.
NASFAA has confirmed with ED that if corrections are made to the ISIR to resolve the cross-year conflict, a new ISIR will be generated with both the C flag and comment code 399 removed. If corrections are made only to the ISIR to resolve conflict, however, a new ISIR will not be generated.

43. Information from NASFAA Q&As
“Income data” refers to the untaxed income reported by students/parents as well. If these do not match that could be one cause of the comment code Asset changes would not cause the comment code 399 as those change as of the date the FAFSA is filed.
Foreign institutions are required to resolve cross-year conflicting data for ISIRs with comment 399.

44. Information from NASFA Q&As
No ISIR will be pushed if a student files a ISIR AFTER filing a FAFSA; comparison of data occurs only at the point a application is filed or corrected. Since the ISIR will not be flagged with comment 399, no resolution is required. However, if a school does receive a subsequent ISIR with comment 399 as a result of other activity, it must resolve cross-year conflicting data at that point. Also, all other normal conflicting data rules apply.

45. Information from NASFA Q&As
ISIR comment codes 035 and 036 have been revised for to indicate parental income or income tax paid conflict with the FAFSA, and ISIR comments have been added to indicate that student income or income tax paid conflict with the FAFSA. Early FAFSA Electronic Announcement #4 lists the FAFSA questions that must be completed using tax data and consequently, are the data items that could potentially conflict across years. To determine exactly which data item(s) conflict, institutions would need to compare the and ISIRs.

46. Information from NASFA Q&As
The institution would not be required to reverse a prior PJ decision to resolve conflicting data, nor should the FAA carry forward a previous year’s PJ adjustment without ascertaining that mitigating circumstances applicable to the new year exist.
If verification was used in the year using extension information, but in the year the tax return information is available, institutions should use that data to resolve cross-year conflicting data.

47. Information from NASFA Q&As
NASFAA is awaiting confirmation from ED that the institution does not correct ISIR data if resolution shows it to be incorrect, but the student did not attend that particular school in

49. Resources From IFAP – Early FAFSA Information Page
February 11, 2016 (GEN-16-03): ED reminds FAAs of PJ basics in context of PPY
February 18, 2016 (EF EA #2): ED urges early awards, acknowledges possible conflicting information, urges use of IRS-DRT for both years to either complete or correct
March 18, 2016 (EF EA #4): Chart showing year used for data elements
April 12, 2016 (EF EA #5): ED begins publishing FAQs in IFAP

50. Resources
August 3, 2016 (GEN-16-14): Identification & resolution of conflicting information
August 10, 2016: Letter from ED Undersecretary Ted Mitchell urging schools to award early but not move up deadlines
August 31, 2016: NASFAA’s Prior-Prior Year: Understanding the Treatment of Conflicting Information Webinar (Q&As now released)
NASFAA tools at

51. For Any Questions You can email EarlyFAFSAFeedback@ed.gov
You will usually not get a direct response from this , but your question will be added to the FAQs on IFAP

52. Contact Information
Jennifer Williams Southern Arkansas University Tech Thank you for attending!