What is Conflicting Information?

1. Overview of Conflicting Information Rules and Required Policies & Procedures regarding VerificationPresented by: Sharon Abernathy, Columbia College Jason Crowe, Barnes-Jewish College

2. What is Conflicting Information? • Refers to contradictory or discrepant information • All conflicting information must be resolved • Resolving conflicting information ensures all application data is accurate, in the financial aid office, and throughout the institution, before any Title IV monies are disbursed Sharon Abernathy & Jason Crowe

3. Examples of Conflicting Information Discrepancies between the financial aid office and other campus offices • Resolve conflicting information, not just in the financial aid office, but campus wide Sharon Abernathy & Jason Crowe

4. Examples of Conflicting Information Examples of Title IV-related data items that may conflict with information found in other campus offices include: • Receipt of other financial aid resources from other sources • Changes in academic status, such as grade level or degree objective • Changes to enrollment status Sharon Abernathy & Jason Crowe

5. Examples of Conflicting Information Examples of Title IV-related data items that may conflict with information found in other campus offices include: • Accuracy of citizenship status • Accuracy of the social security number • Changes to cost of attendance components • Elements which affect calculation of EFC Sharon Abernathy & Jason Crowe

6. Examples of Conflicting Information Discrepancies between the ISIR and non-Title IV loan or scholarship application • Data on the private application differs from information listed on ISIR/SAR Sharon Abernathy & Jason Crowe

7. Examples of Conflicting Information Discrepancies between initial and subsequent output documents which include: • C-flags and comment codes • Subsequent ISIR selection for verification when initial ISIR was not selected • Updated NSLDS information • Receipt of reject ISIR/SAR and subsequent receipt of valid ISIR/SAR Sharon Abernathy & Jason Crowe

8. Resolving Conflicting Information • An institution must always resolve conflicting information as soon as discrepancy is found • Exception is only if the student is no longer enrolled at the time the institution learns of conflict Sharon Abernathy & Jason Crowe

9. Student Enrollment and Resolving Conflicting Information If a student is enrolled, the institution must: • Resolve conflicting information even if processing year has ended • For a prior year, the institution must investigate and resolve the conflict • Discrepancy discovered after disbursing Title IV funds, the conflicting information must be reconciled; student must repay any aid for which he or she wasn’t eligible Sharon Abernathy & Jason Crowe

10. Student Enrollment and Resolving Conflicting Information If a student is enrolled, the institution must: • Treat the aid as a resource for the subsequent period of enrollment if the student is intending to reenroll once the period of enrollment has ended and the institution was unaware of aid received Sharon Abernathy & Jason Crowe

11. Student Enrollment and Resolving Conflicting Information The institution must take the following action if the student is no longer enrolled: • If the institution becomes aware of conflicting information after student is no longer enrolled but student is eligible for late or post-withdrawal disbursement, the institution must resolve conflict before making disbursement Sharon Abernathy & Jason Crowe

12. Student Enrollment and Resolving Conflicting Information If the institution knows the student is no longer enrolled and does not intend to re-enroll, resolution of conflicting information is not required if: • All aid for period of enrollment has been disbursed, and • At time of disbursement, there was no conflicting information Sharon Abernathy & Jason Crowe

13. Referrals to the Office of Inspector General Examples of referrals are: • False claims of independent student status • False claims of citizenship • Use of false identities • Forgery of signatures or certifications • False statements of income Sharon Abernathy & Jason Crowe

14. Conflicting Information and Professional Judgment Professional judgment is the authority by which a financial aid administrator has the discretion to make a special determination on a student’s application based on the individual student’s unusual circumstances Sharon Abernathy & Jason Crowe

15. What is an Adjustment? Simply defined, an adjustment is a change made to the student’s application data by a financial aid administrator using professional judgment Sharon Abernathy & Jason Crowe

16. Crossover Years: Projected Year Income Versus Actual Income • What about projected calendar year income information from the prior award year and actual income information reported on the new award year’s FAFSA? • Is this conflicting information if the projected income and the actual income do not match? • In this instance, this is not considered conflicting information Sharon Abernathy & Jason Crowe

17. Shiloh Jolee-Pit Case Study Just as you would search for Waldo, see if you can identify all the conflicting information in this case study… Sharon Abernathy & Jason Crowe

18. Did you find all the issues? • Mother’s earned income and filing of a 1040 tax return • Siblings’ nonattendance in post secondary school. (# in college) • EFC recalculation; based on revised income, # in college, and tax filing status. No longer auto 0 EFC. No longer grant eligible • Citizenship status? Sharon Abernathy & Jason Crowe

19. Shiloh Jolee-Pit Case Study What sources of documentation would you collect to resolve the conflicting information? Sharon Abernathy & Jason Crowe

20. Ideally you would need to collect: • Mother’s tax returns • Dependent verification worksheet • Proof of student’s U.S. citizenship status • Documentation from admission’s office of siblings’ nonenrollment Sharon Abernathy & Jason Crowe

21. Shiloh Jolee-Pit Case Study • Does Shiloh have a genuine reason for receiving a professional judgment adjustment on her dependency status? • Discussion and opinions Sharon Abernathy & Jason Crowe

22. How well is Verification covered in your Policy and Procedures Manual?

23. Verification Policies and Procedures • School must establish written: • Verification policies • Procedures by which it will carry out its policies • Verification regulations: • Contain very specific directives • Leave some options to school • Must be clear and consistently applied Sharon Abernathy & Jason Crowe

24. NASFAA Policies and Procedures Tools • Introduction and Instructions • Templates for Your Policies and Procedures Manual • Regulatory Resources Guide Sharon Abernathy & Jason Crowe

25. NASFAA Policies and Procedures Tools • Formulating, Implementing, and Evaluating Policies and Procedures • Formatting Your Policies and Procedures Manual • Sample Polices and Procedures Manual • Reading and Interpreting Regulation and Statute Sharon Abernathy & Jason Crowe

26. NASFAA Policies and Procedures Tools Where might you find these resources? The new and improved tools, templates, and samples can be found at: http://www.nasfaa.org/Annualpubs/PPManual/index.htm Sharon Abernathy & Jason Crowe

27. MASFAP Spring 2007 • Discussion • Feedback • Questions • Thank you for attending our session. Sharon Abernathy & Jason Crowe