ISIR CORRECTIONS DUE TO TRANSFER OF INCORRECT TAX YEAR DATA FROM IRS

According to a recent announcement from Federal Student Aid (FSA), some FAFSA applicants who attempted to file a correction to their 2018-2019 FAFSA received 2017 tax year data instead of the correct 2016 tax year data. It appears that this glitch affected only a small number of applicants, particularly those who made a correction to their 2018-2019 FAFSA between September 30, 2018, and October 4, 2018, and used the IRS Data Retrieval Tool to transfer their tax information from the IRS to the FAFSA. FSA identified the issue and resolved the problem with the IRS Data Retrieval Tool on October 4th, 2018, so it shouldn’t happen again.

2018-2019 ISIR CORRECTIONS MADE DUE TO TRANSFER OF INCORRECT TAX YEAR DATA FROM IRS

On October 26, 2018, the Central Processing System reprocessed the ISIRs of affected applicants and voided the bad transactions – but they did NOT correct the tax information so ISIR corrections still need to be made. Instead, emails are being sent to affected applicants alerting them to the problem and informing them to go online and make another ISIR correction by transferring the correct 2016 IRS tax information to the FAFSA using the DRT. This issue reportedly impacted a very small number of applicants, but it is important to note that the reprocessed transactions are intended solely to alert impacted applicants and institutions that action is required; the CPS reprocessing did not modify the financial information transferred from the IRS.

Several methods exist for schools to identify records resulting from the October 26 reprocessing:
Reprocessed Institutional Student Information Records (ISIRs) will be sent under the IGSG19OP message class.
SARs and ISIRs will include SAR comment code 172, which states “This SAR was produced because we processed a change to your information based on information reported to us by another agency or because of a processing system change. Review your SAR to see what effect, if any, this change has had on your application, and call 1-800-4-FED-AID (1-800-433-3243) if you have any questions.”

ISIRs produced because of the reprocessing will include a value of “04” for the Reprocessed Reason Code (ISIR field #248).

The FAA Information page in Student Inquiry on the FAA Access to CPS Online Web site will display “04 – Reprocessed for wrong tax year transferred from IRS DRT” for the Reprocessing Code for the transaction resulting from the reprocessing. The Reprocessing Reason Code 04 description will not display in FAA Access to CPS Online until after FSA implements updates to the site in a future release.

2018-2019 ISIR CORRECTIONS DUE TO TRANSFER OF INCORRECT TAX YEAR DATA

According to a recent announcement from Federal Student Aid (FSA), some FAFSA applicants who attempted to file a correction to their 2018-2019 FAFSA received 2017 tax year data instead of the correct 2016 tax year data. It appears that this glitch affected only a small number of applicants, particularly those who made a correction to their 2018-2019 FAFSA between September 30, 2018 and October 4, 2018 and used the IRS Data Retrieval Tool to transfer their tax information from the IRS to the FAFSA.  FSA identified the issue and resolved the problem with the IRS Data Retrieval Tool on October 4th, 2018, so it shouldn’t happen again.

On October 26, 2018 the Central Processing System reprocessed the ISIRs of affected applicants and voided the bad transactions – but they did NOT correct the tax information so ISIR corrections still need to be made. Instead, emails are being sent to affected applicants alerting them to the problem and informing them to go on line and make another ISIR correction by transferring the correct 2016 IRS tax information to the FAFSA using the DRT. This issue reportedly impacted a very small number of applicants, but it is important to note that the reprocessed transactions are intended solely to alert impacted applicants and institutions that action is required; the CPS reprocessing did not modify the financial information transferred from the IRS.

Several methods exist for schools to identify records resulting from the October 26 reprocessing:

Reprocessed Institutional Student Information Records (ISIRs) will be sent under the IGSG19OP message class.

SARs and ISIRs will include SAR comment code 172, which states “This SAR was produced because we processed a change to your information based on information reported to us by another agency or because of a processing system change. Review your SAR to see what effect, if any, this change has had on your application, and call 1-800-4-FED-AID (1-800-433-3243) if you have any questions.”

ISIRs produced because of the reprocessing will include a value of “04” for the Reprocessed Reason Code (ISIR field #248).

The FAA Information page in Student Inquiry on the FAA Access to CPS Online Web site will display “04 – Reprocessed for wrong tax year transferred from IRS DRT” for the Reprocessing Code for the transaction resulting from the reprocessing. The Reprocessing Reason Code 04 description will not display in FAA Access to CPS Online until after FSA implements updates to the site in a future release.

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RESOLVING CONFLICTING INFORMATION FOR CODE 399

Although the 2016-2017 and 2017-2018 FAFSAs should be completed using the same 2015 income and tax information, there is the possibility that there might be conflicting information between the two FAFSAs. To help administrators identify applications with potential conflicting information, beginning with the 2017-2018 award year, ISIRS will contain a comment code of 399 indicating conflicting information of prior-prior year data.

Federal Student Aid recently announced that they will continue to monitor the 2016-2017 and 2017-2018 FAFSA applications for conflicting information between the two years. Schools are required to resolve 399 codes in accordance with the guidance in GEN 16-14

Through September 9, the last day to make ISIR corrections for the 2016-2017 FAFSA cycle. After September 9, and for the remainder the of the 17-18 cycle, CPS will continue to push 399 C-codes when information conflicts between the two award years, but schools aren’t required to make any changes to 2016-2017 FAFSA or award data after September 9, 2017. Instead to resolve conflicting information, schools must review both years and if the conflict is caused by incorrect 16-17 year data, the school should document that the correction deadline has passed in student files and make sure that 17-18 data is correct before awarding or disbursing. For more information, check out FSA’s recent guidance in this electronic announcement.

COMMENT CODE 399 CHANGES

Resolving comment code 399 situations with students has placed an additional burden on FAAs. Two key changes to CPS were implemented last month to increase the accuracy of the assignment of comment code 399 and reduce the number of students receiving comment code 399.

For students with an automatic-zero EFC for 2017-2018, the CPS will now compare financial information provided for 2017-2018 to the student’s 2016-2017 financial information; SAR comment code 399 will only be assigned to the transaction if the EFC difference calculated by the CPS is over a certain threshold.

For student records with a professional judgment on the 2016-2017 transaction a condition was added to exclude those records from the cross-year edits that set SAR comment code 399.

On February 6, 2017 the CPS reprocessed 2017-2018 student records with an auto zero EFC as well as 2016-2017 records with professional judgment indicators checked. As a result, comment code 399 will be added or removed as needed based on the new CPS logic. http://bit.ly/2lKGWsd

UNUSUAL ENROLLMENT HISTORY FLAGS FOR 2017-2018 ISIRS

Federal Student Aid recently provided information about the Unusual Enrollment History Selection for the 2017-2018 award year. Any financial aid advisor will tell you that some students who have an unusual enrollment history have legitimate reasons for their enrollment at multiple institutions. However, such an enrollment history requires a review to determine whether there are valid reasons for the unusual enrollment history.

There is a flag in NSLDS for students whose pattern of enrollment and / or award history for either Pell or Direct Loans (other than a Direct Consolidation Loan or Parent PLUS Loan) is identified as unusual. The CPS will flag the Unusual Enrollment History field (UEH) on the student’s SAR/ISIR indicating whether the FAFSA applicant has an unusual enrollment history with regard to the receipt of Title IV student aid. The specific unusual enrollment pattern is one where the student may have attended an institution long enough to receive a Title IV credit balance, leaves without completing the enrollment period, enrolls at another institution, and repeats the pattern of remaining enrolled just long enough to collect another Title IV credit balance. The award years that are monitored for unusual enrollment are the four award years preceding the current FAFSA award year. For the 2017-2018 award year, the UEH Flag will consider enrollment history for award years 2013-2014, 2014-2015, 2015-2016, and 2016-2017. http://bit.ly/2jvnta4