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.