Resolving Resolving CONFLICTING CONFLICTING INFORMATIONINFORMATION

New Aid Officers WorkshopMay 14-16, 2012

What the Reg’s say: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 When Should Conflicting Information be Resolved?Information be Resolved?

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 mustmust resolve the discrepancies before disbursing FSA fundsIf you discover discrepancies after disbursing FSA funds, you mustmust still reconcile the conflicting information and take appropriate action under the specific program requirements.

Where to Look?Where to Look?

Student Eligibility RequirementsProgram Eligibility

RequirementsSAR Comment Codes:

◦Federal Database Match Discrepancies

◦C-Flags◦Rejects

Subsequent ISIR Transactions

Student Eligibility Student Eligibility RequirementsRequirements

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 Student & Program Eligibility RequirementsEligibility 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 What are SAR Comment Codes?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 digitsThe codes are informational however

some codes include information regarding discrepancies that require resolution by the applicant or school.

SAR Comment Codes that SAR Comment Codes that Require ResolutionRequire Resolution

Federal Database Match Indicators◦C-Flags◦Rejects

IRS Data Retrieval ToolUpdates to Marital Status

What are the Federal What are the Federal Database Matches?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 18-25 born

after 1959

5. 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?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?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.

2012-2013 C-FLAGS2012-2013 C-FLAGS

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

NSLDS INFORMATIONNSLDS 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 GuideSAR Comment Text Guide

3 digit code

Federal Database Match

Example of Numeric Reject

Example of a C-Flag

C-Flags & RejectsC-Flags & RejectsMost 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 Informational SAR Comment CodesComment 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: http://ifap.ed.gov/sarcommcodestxt/attachments/1213SARCommentCodesTextATTACH.pdf

What are Subsequent What are Subsequent ISIR’s?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 TAX Returns/TranscriptsReturns/TranscriptsMay 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 DataDiscrepant Tax DataFAA 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 www.irs.gov

You are obligated to know:1. Pages 4-7: whether a person was required to

file a tax return2. Pages: 7-8: what the correct filing status for a

person should be3. Pages 20-25: that an individual cannot be

claimed as an exemption by more than one person

4. Pages 23-25 explains criteria a person must meet to file as head of household.

Required to File a Tax Required to File a Tax Return 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 StatusCorrect Filing StatusSingle

•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 RESOURCESHELPFUL RESOURCES

•IFAP Federal Student Aid Handbook, AVG, Chapter 5 SAR Comment Codes and Textwww.ifap.ed.gov Online review of Conflicting Information Policies: www.ifap.ed.gov/qadocs/FSAVeriModule/activity1verif.doc

•IRS Resource:Publication 17 Visit www.irs.gov Or Call at 1-800-829-3676 to order a copy

•NSLDS for FAAhttps://www.nsldsfap.ed.gov/nslds_FAP/