Resolving CONFLICTING INFORMATION

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

2. 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.

3. When Should Conflicting 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 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 to Look? • Student Eligibility Requirements • Program Eligibility Requirements • SAR Comment Codes: • Federal Database Match Discrepancies • C-Flags • Rejects • Subsequent ISIR Transactions

5. 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

6. 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

7. 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.

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

9. What are the Federal Database Matches? • IRS • IRS Data Retrieval Tool • VA • Independent Veteran Status • SSA • Name, SSN, DOB & U.S. Citizen Match • SS • Selective Service Registration Match for Males 18-25 born after 1959 • DOJ • Drug Hold for applicants who were convicted of a drug felony while receiving Title IV Aid • DHS • Eligible Non-Citizen Match • NSLDS • Title IV Grant/Loan Overpayments, Loan Aggregates, Annual Loan Limits, Enrollment Reporting (TML), Loan Default, Bankruptcy, Loan Discharge • DOD • Afghanistan & Iraqi Service Grants

10. 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: • Alpha- can be updated or reinstate that “data is correct” • Numeric- requires correction

11. 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.

12. 2012-2013 C-FLAGS • Requires resolution from the school typically consist of collecting documentation from the student and/or the FAA utilizing NSLDS.

13. 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.

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

15. 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 C-Flags & Rejects

16. 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: http://ifap.ed.gov/sarcommcodestxt/attachments/1213SARCommentCodesTextATTACH.pdf

17. 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

18. 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

19. 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 www.irs.gov You are obligated to know: Pages 4-7: whether a person was required to file a tax return Pages: 7-8: what the correct filing status for a person should be Pages 20-25: that an individual cannot be claimed as an exemption by more than one person Pages 23-25 explains criteria a person must meet to file as head of household.

20. 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

21. 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

22. HELPFUL RESOURCES • IFAP • Federal Student Aid Handbook, AVG, Chapter 5 • SAR Comment Codes and Text • www.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 FAA • https://www.nsldsfap.ed.gov/nslds_FAP/