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

2. 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.

3. 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.

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

5. 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

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

7. 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

8. 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

9. 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

10. 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.

11. 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

12. 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)

13. 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.

14. WHO MUST FILE TAX RETURN

15. 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

16. 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

17. 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
Publication 17