Resolving C Code 399 Training

When an applicant submits a 2017-2018 FAFSA application the Central processing System will perform a comparison between prior 2016-2017 ISIR transactions and the 2017-2018 ISIR. If there is conflicting income or tax information between the two ISIRS, that would, once resolved, produce a significant change in the student’s expected family contribution and resultant Pell Grant eligibility, the student’s 2017-2018 SAR and ISIR will be flagged with a ‘C’ code and a special new Comment Code 399 informing the institution that it must resolve the possible conflicting information.

The Department recently updated the Early FAFSA FAQ with additional information for institutions about resolving conflicting information related to comment code 399 on 2017-2018 ISIRs.

Q – Will a new 2017-2018 ISIR transaction with comment code 399 be generated if the only reason for the transaction is to indicate comment code 399? For example, if a 2017-2018 FAFSA is filed before the student’s 2016-2017 FAFSA, will a new 2017-2018 ISIR be generated to flag the student’s 2017-2018 ISIR with comment code 399 if the comparison between the two years results in conflicting information?

A – Comment code 399 will only appear on a 2017-2018 ISIR if there was conflicting information between the student’s 2016-2017 and 2017-2018 records when any 2017-2018 ISIR was processed. For example, if a 2017-2018 ISIR is processed before the student’s 2016-2017 FAFSA was submitted there cannot be a 399 code on the 2017-2018 ISIR since there would be no conflicting information. If the student then submits a 2016-2017 FAFSA no comparison with the previously processed 2017-2018 ISIR transaction will be made, thus no new 2017-2018 ISIR will be generated. However, if a subsequent 2017-2018 ISIR is generated for any reason (e.g. corrections, NSLDS post-screening) after the 2016-2017 FAFSA was processed, a comparison will be done and if conflicting information is identified, the new 2017-2018 ISIR will include the 399 code.

Q – When the resolution of conflicting information related to Comment Code 399 determines that a student is no longer eligible for all or some of the subsidized aid that had been awarded, what action must the institution take regarding the subsidized aid that was disbursed?

A – As discussed in Dear Colleague Letter GEN-16-14, if the resolution of Comment Code 399 results in an overaward, the institution may adjust any subsequent disbursements in the same award year to eliminate the overaward. For example, a student is eligible for $4,000 in Pell Grant funds for the 2016-2017 award year. The institution disburses $2,000 for the Fall 2016 semester with the remaining $2,000 scheduled to be disbursed for the Spring 2017. However, after resolving Comment Code 399, the institution determines that the student is only eligible for $3,500 in Pell Grant funds for the entire 2016-2017 award year. The institution must reduce the Spring 2017 disbursement from $2,000 to $1,500. Of course, if the student does not return for the Spring 2017 term, the overaward becomes an overpayment that must be returned.

If an institution determines that a student’s overaward cannot be totally eliminated by adjusting subsequent disbursements, any remaining portion of the overaward attributed to a Title IV grant or Perkins Loan must be returned.

Q – What is a reasonable amount of time that institutions should allow students to submit documentation to resolve Comment Code 399?

A – When determining a deadline for submitting documentation to resolve a Comment Code 399, institutions should use the same guidance provided in the verification provisions of the April 4, 2016 Federal Register Notice.

You can read the Early FAFSA FAQ here:

Does your staff need training on resolving C-Code 399? Contact us today to discuss your training needs. | 203-836-4806