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.