Session # C-16

1. Session # C-16 CPS Process, Data Matches and Processing Changes Ginger Klock, U.S. Department of Education Teri Hunt, Macro International

2. Session Objectives • Inform how the CPS generates processing codes and selects records for rejects and verification • Provide reason for Data Matches and assist with resolving “C” Code issues • Discuss processing changes for 2009-10

3. Agenda • CPS Processing • Edits • EFC Calculation • Verification Selection • Data Matches • CPS Matches • Social Security Administration (SSA) • Department of Homeland Security (DHS) • Selective Service (SS) • Veterans Affairs (VA) • National Student Loan Data System (NSLDS) • Processing Results

4. The CPS • Receives data • Processes data • Calculates EFC • Disseminates data to students, schools and other agencies

5. Options for submitting FAFSA data • Web Applications and Corrections (English & Spanish) • Paper Applications and Corrections (English & Spanish) • Schools and Third Party Servicers Applications and Corrections using FAA Access on the Web or EDconnect and SAIG

6. Initial Receipt and Editing • Ensures data and files are valid according to the specifications • Checks for field length and valid values • Pulls forward and converts previous cycle data for Renewal Applications

7. Processing Edits • Substantive edits on application data to determine if EFC can be calculated • Edit for basic eligibility requirements (name, date of birth, citizenship, drug offense conviction, dependency status) • Edit for validity and consistency of financial data

8. Assumption Edits • Assume a logical response for missing or incorrect data based on comparison with other responses provided by the applicant • Assumed values are used in calculating the EFC • Data is identified as assumed for both the student and the FAA • Some assumptions can be overridden by the student or an FAA

9. Reject Edits • Missing or significant conflict in key information, and a logical assumption cannot be made • An EFC is not calculated • Fields are highlighted and SAR comments are provided • A correction is required

10. Types of Rejects • Alpha reject codes -- are verifiable • verify the questionable data by re-entering the same value, or • can correct it to a different value • Numeric reject codes-- are not verifiable – • the questioned data must be changed or provided • Most alpha rejects and a few numeric rejects can be overridden by an FAA

11. Warning Edits • Data is questionable or contradicting but not severe enough to be rejected • Includes cross year edits • EFC is calculated • Fields are highlighted and SAR comments are provided

12. EFC Calculation • Performed for non-rejected and signature only rejected records • Calculate primary and secondary EFC if SNT is met and asset information is provided • Calculate eleven alternate EFCs for programs of less than and greater than nine months

13. Verification Selection • Records with EFCs or rejected for missing signatures only • Goal is to select 30% of all applicants • 100 targeted criteria used - each with an associated score • Total score used to determine if record will be selected • Only Pell-eligible applicants are selected, except for random selection

14. Data Matches • Social Security Administration (SSA) • Department of Homeland Security (DHS) • Selective Service (SS) • Veterans Affairs (VA) • National Student Loan Data System (NSLDS)

15. EDE Destinations (Schools, States and Servicers) Paper FAFSA (IDC) FAFSA on the Web Products/ FAA Access SAIG Internet FSAIC Social Security Admin Social Security Admin. CPS COD Selective Service Dept of Homeland Security NSLDS Veterans Affairs

16. What are Data Matches and why do we have them? • We match CPS data with other databases to confirm an applicant’s eligibility for Title IV student aid • Mandated by Legislation • Partner with other government • agencies for information • Trading Partner Agreements • Memorandums of Understanding • Approvals at the cabinet level

17. To verify the SSN of the applicant and parent(s). • Section 484(p) of HEA and section 668.36 of the regulations require a match with the Social Security Administration (SSA) to confirm the social security number of the applicant (and the parent(s) of a dependent applicant). Social Security Administration (SSA)

18. Student SSN is invalid or belongs to a deceased individual • CPS Reject 18 or 8, No EFC calculated • If SSN is correct • Student contacts SSA • Then reaffirm SSN on SAR • If SSN is NOT correct • Correct SSN on SAR • Can re-file with the Correct SSN

19. SSA does not confirm Name or DOB for Student • CPS Reject R or D, No EFC calculated • If Name/DOB is correct • Student contact SSA • Reaffirm Name/DOB on SAR • SSA still does not confirm • CPS reject suppressed • “C” code, resolution required • Documentation required • If Name/DOB is not correct • Correct Name/DOB on SAR

20. SSN mismatch for Parents • Non-verifiable CPS reject • for invalid SSN and other parent does not have match flag 4 (Reject 6 or 7) • if unable to conduct match for at least one parent (Reject 9) • Resolution: Appropriate data elements for at least one parent must be corrected

21. Parent Name or DOB mismatch • Verifiable CPS Reject if other parent does not have match flag 4 • Mother (Reject F or T) • Father (Reject E or S) • Resolution: Correct or reaffirm • no further resolution for reaffirm • No “C” codes for parents • Parents encouraged to contact SSA to resolve discrepancies

22. Department of Homeland Security (DHS) • To verify claim of eligible non-citizen status for any applicant who responds ‘Yes’ to the eligible non-citizen question and provides an Alien Registration Number. • Sections 484(g) of HEA and 668.33 of the regulations provide that an applicant must be either a citizen or eligible non-citizen. Subpart I of the regulations prescribe the DHS matching process.

23. No Resolution Required • “Y” flag in the DHS Match Flag • ISIR field 311 or • “Y” flag in the Secondary DHS Match Flag • ISIR field 312

24. DHS Results that generate the “C” Code • Resolution Required – Do manual Secondary Confirmation (G-845) • When Secondary DHS Match Flag is: “P” - wait 10 days “C” - wait 10 days “X” - don’t wait “N” - don’t wait • Must have supporting documentation

25. Where do I get a G-845 Form and where do I send it? • IFAP, Electronic Announcement, entitled,“Summary: Update on USCIS Field Offices for Submission of Immigration Status/Document Verification Request, G-845-New Field Office for Schools".

26. Helpful tips for completing the G-845 • Be sure to provide: • DHS Verification Number in #5 (ISIR Field 314) • Add student SSN in item #8 in “Other” • “Submitting Agency” is YOU, the school • Supporting documentation needed MATCH FLAGS SSN Match Flag: 4 Selective service Registration Flag: Selective Service Match: Y DHS Match Flag; N DHS Verification #: 123456789012345 SSA Citizenship Code: DHS Sec. Conf. Flag: X VA Match Flag: 1 FSSN Match Flag: 4 NSLDS Match Flag: 1 NSLDS Database Results Flag: 4 MSSN Match Flag: 4

27. DHS does not respond to the G-845 submission • After 15 days, school may disburse funds • Must have supporting documentation • See FSA Handbook • Volume 1, Chapter 2

28. Applicant corrects to “citizen” but SSA Citizenship Match does not confirm • Resolution Required - “C” code for SSA Citizenship Match – ISIR Field 234 = *, B, C, D, E, or F • Collect documentation showing proof of citizenship such as birth certificate or passport

29. To verify that males between the ages of 18 and 25 are registered with SS • Section 484(n) of the HEA and 668.37 of the regulations requires a match with the Selective Service System (SSS) to ensure that applicants who are required to be registered with Selective Service are registered. Selective Service (SS)

30. Selective Service Match Flag is N (not registered) • ISIR Field 322 = N, “C” Code, Resolution Required • Disburse ONLY if you have documentation of Registration Acknowledgement or letter of registration from Selective Service OR if the applicant qualifies for a waiver or exemption.

31. Veterans Affairs Match (VA) • To verify claim of veteran status for dependency purposes. • Sections 480(c) and 480(d) of the HEA provides that if an applicant is a veteran of the U.S. Armed Forces, he or she is considered to be independent.

32. VA does not confirm claim of Veteran • Processed as an Independent Student • If only reason applicant is an Independent • “C” code, resolution required, ISIR Field 327 = 2 or 3 • Collect documentation • If no supporting documentation, make a correction to SAR to change response to VA question 52

33. Student responds “Yes” to Active Duty, but not to Veteran • Processed as Independent Student • Match is not done with with VA • If response to Veteran is “Yes” and VA does not confirm, still processed as Independent because of claim of Active Duty in question 51 • No Resolution Required

34. NSLDS Match • To monitor defaults, overpayments, loan maximums, Pell Grant awards, etc. • Internal/FSA database

35. NSLDS information that causes the “C” code • FSEOG, Perkins or Grants in Fraud or in Overpayment • Defaulted Loans • Bankrupt Loans • Discharged Loans • Close to or Exceeding Loan Limits • Identifier Mismatch

36. Must the “C” code for NSLDS Match Results be eliminated before disbursing funds? • Timing of updates to NSLDS • Never pay on a “C” code without appropriate documentation

37. For More on NSLDS • NSLDS Sessions • #19 NSLDS Update • #18 NSLDS Enrollment Reporting • #17 NSLDS Aggregates • #20 NSLDS Website Hands-on • FSA Handbook: Volume 1, Chapter 3 • ISIR Guide: NSLDS Financial Aid History and Appendices B and C • www.nsldsfap.ed.gov

38. To identify applicants who are debarred from Title IV funds because of drug conviction. • Section 5301 of the Anti-Drug Abuse Act of 1988 prescribes that a court may decide to debar an individual convicted of a drug related offense to not be eligible to receive federal benefits until the time the period of debarment expires. Department of Justice (DOJ)

39. Applicant is on DOJ’s Drug Abuse Hold File • CPS Reject 19, No EFC calculated • DOJ refers records to FSA • Debarment Expiration Date • Student works with Parole Officer and the courts • If removed from the hold file, a new ISIR not automatic • FSA: 202-377-3385

40. FAFSA Drug Question 23 is NOT part of the DOJ Hold File • However, • Question 23 cannot be left blank • Must make correction • Must eliminate “C” code before disbursing funds

41. Processing Changesfor 2009-2010

42. Special Circumstances • Allow dependent student to submit application electronically without parental data • For applicants who cannot provide parental data • Could submit on paper in the past by leaving questions blank • Now CPS allows them to submit on the Web

43. Student submits application without Parental data • Student is presented with a series of prescreening Web pages and questions • With detailed guidance • List of limited set of conditions that meet Special Circumstances criteria

44. Student is told about the process • Student is informed they will NOT receive an EFC • Student is advised to contact their financial aid office • Student is urged to gather and provide all relevant written evidence of his or her situation

45. Other information provided to the student • Financial aid office is NOT required to approve their request • Decision of school is final • Student cannot appeal to the U.S. Department of Education

46. ISIR will have a new Special Circumstances Flag • ISIR Field 164 = “1” (without parental data) • Comment Code - 295 • CPS Rejects, no EFC calculated • Reject 2 = incomplete application • Reject 15 = no parent signature • Special Circumstances warning will alert FAA online that parental data questions are blank

47. ISIR will have a new Special Circumstances Flag • ISIR Field 164 = “2” (with parental data added) • Comment Code – 296 • CPS processes as usual

48. Student Responsibility • Student must provide documentation to school demonstrating independent status; or • Student submits correction to add parental data

49. School Responsibility • School should • Collect documentation substantiating the condition • Determine if it meets the school policy for dependency override • Submit correction with dependency override set or • Inform student to submit correction to provide parental data

50. Dependency Override without Special Circumstances Flag • Schools can still do dependency override as usual • Student does not have to request special circumstances on the FAFSA • Appropriate procedure and documentation still required