SAR comment code 399 and the SAR C flag are assigned to a record by CPS when the student or parent reports a different 2015 income amount on the 2017-2018 Free Application for Federal Student Aid than the 2016-2017 FAFSA. With the implementation of prior-prior year financial reporting for the 2017-2018 processing cycle, applicants and parents of dependent applicants should be reporting the same 2015 income for 2017-2018 as they did for 2016-2017. In early October, schools reported they were receiving SAR comment code 399 on 2017-2018 records with no discernable difference in the 2015 income reported for 2016-2017 versus 2017-2018. CPS identified a system issue causing the incorrect assignment of SAR comment code 399, and has updated CPS to resolve the issue on October 16, 2016. ISIRS and SARS were reprocessed on October 17, 2016 to fix 2017-2018 student records that were assigned comment 399 incorrectly.
Several methods exist for schools to identify records resulting from the October 17 reprocessing:
- Reprocessed Institutional Student Information Records (ISIRs) were sent under the IGSG18OP 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 as a result 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 as a result of the reprocessing include a value of “02” for the Reprocessed Reason Code (ISIR field #230).
- After updates are implemented in February 2017, the FAA Information page in Student Inquiry on the FAA Access to CPS Online Web site will display “02 – Reprocessed because Comment Code 399 not assigned correctly” for the Reprocessing Code on the transaction resulting from the reprocessing.
If the ISIR transaction resulting from the October 17 reprocessing no longer includes Comment Code 399 the institution is not required to take any action to resolve the Comment Code 399 that was included in the earlier ISIR transaction. Of course, any subsequent ISIR that includes Comment Code 399 must be resolved using the guidance provided in Dear Colleague Letter GEN-16-14.
Special Note for Graduate Students: The calculation used by the CPS to set Comment Code 399 does not automatically exclude FAFSA applicants simply because they reported on their FAFSA that they would be a graduate student since we know that in some cases that self-reported grade level is in error. That said, an institution is not required to resolve the reported Comment Code 399 if:
- The institution determines that the student was, or will be, a graduate student for all of 2016-2017 and will continue to be a graduate student for all of 2017-2018; and
- The student did not, and will not, receive Federal Work-Study for either the 2016-2017 or 2017-2018 award years.
Note that this relief does not apply to a student who was or who will be an undergraduate student even if the student has already completed a bachelor’s degree program. This is because such a student, while not eligible for a Pell Grant or FSEOG funding, is eligible for other subsidized Title IV aid.