As a follow up to Dear Colleague Letter GEN-16-14, FSA updated their Early FAFSA FAQ to clarify circumstances under which an institution must resolve the conflicting information from PPY info when a student’s 2017–2018 ISIR has Comment Code 399 (possible conflicting information). For example, if the institution receives the 2017–2018 ISIR with Comment Code 399, and the student is no longer enrolled and is not expected to re-enroll for 2016–2017 or enroll for 2017–2018, the institution is not required to resolve the possible conflicting information. However, if the student subsequently enrolls, or re-enrolls, for any period associated with either the 2016–2017 or 2017–2018 award years, the institution must resolve the conflicting information.

If the new Comment Code 399 is not included on the student’s 2017–2018 ISIR, the institution is not required to determine if there are any differences in income or tax information between the two ISIRs. Institutions must still resolve conflicting information if the student’s ISIR was flagged with Comment Code 399, but the ISIR was not selected for verification because the resolution of conflicting information is a separate process from verification.

Institutions Can use the documentation collected to verify income and tax information on the 2016–2017 FAFSA to resolve conflicting information or complete verification of the 2017–2018 FAFSA if for either year, the institution had verified the conflicting information item(s) or the student or parent had transferred information into the FAFSA using the IRS DRT and had not changed any of the transferred information. Since the institution can assume that the verified or IRS DRT transferred values are correct it must, therefore, submit corrections to the other year’s ISIR values.

As is the case for a student who has been selected for verification, the institution must resolve any possible conflicting information and submit any required ISIR changes to the CPS before it makes a professional judgment determination.

The “Resolving Possible Conflicting Information and Submitting Corrections” section of Dear Colleague Letter GEN-16-14 instructs institutions to compare information from “both years” ISIRs to determine which income or tax item or items are in conflict.” Which 2016–2017 ISIR should be used for this comparison in cases where the institution received more than one 2016–2017 ISIR?

In cases where an institution has received more than one 2016–2017 ISIR for a student, the required comparison must be between the 2017–2018 ISIR with Comment Code 399 and the 2016–2017 ISIR that was, or will be, used as the basis for awarding and disbursing Title IV aid. Check out the updated FAQ here: