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Resolving CONFLICTING INFORMATION. New Aid Officers Workshop May 16-19, 2011. DO I REALLY NEED TO KNOW?.
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Resolving CONFLICTING INFORMATION New Aid Officers Workshop May 16-19, 2011
DO I REALLY NEED TO KNOW? A school must have an adequate internal system to identify conflicting information—regardless of the source or whether the student is selected for verification—that would affect a student’s eligibility. The school must resolve all such conflicting information, except when the student dies during the award year.
WHEN IS IT IMPORTANT? • If your school has conflicting information concerning a student’s eligibility or you have any reason to believe a student’s application is incorrect, you must resolve the discrepancies before disbursing FSA funds • If you discover discrepancies after disbursing FSA funds, you must still reconcile the conflicting information and take appropriate action under the specific program requirements.
WHERE DO I LOOK? • Eligibility Elements • ISIR (First and Beyond) • Tax Return • All documents received
ELIGIBILITY ELEMENTS • Review of school records should include if the student is/has: • U.S. citizen or eligible non-citizen or otherwise eligible for aid • High school diploma, GED or passed ATB test • Admitted into eligible program • Academic level (undergrad, grad, professional, etc.) • Academic progress
ISIR DATA (FIRST AND BEYOND) • SAR “C” Flag • Reject Codes • Comment Codes • NSLDS information • ISIR Corrections
SAR “C” FLAG • A flag of “C” is an indicator that institutional resolution is required and no EFC will be calculated. Typically a “C” flag is generated if the student’s FAFSA information could not be matched or is matched with information in a specific database. Examples include: • Selective Service • Citizen/Non-Citizen Status • Social Security Number • Veterans Status • NSLDS • Drug Conviction Status
REJECT CODES • A reject code is produced when data is missing/questionable and an EFC is not calculated. • Examples: • Missing signature • Taxes paid and AGI are inconsistent/missing • Asset information is missing and SNT is not met • Incorrect DOB/SSN • Marital Status missing/questionable
COMMENT CODES • A numeric comment code is shown on ISIR when conflicting data may be present and/or when a SAR “C” flag and reject codes are present. If only comment codes are shown (No SAR “C” flag or reject code) an EFC is calculated. • Examples: • Tax return is estimated • Household size • Income is different or the same • Taxes paid • Homelessness • Emancipated Minor • Dependent without parental data
NSLDS INFORMATION • Changes to a student’s NSLDS information (loans and/or grants) is present on all initial and subsequent ISIR transactions. • Each NSLDS record shows its own transaction number. • NSLDS information may generate a SAR “C” Flag, Reject Code and/or a comment code at any time. • School is required to resolve any conflicting data generated by a new NSLDS/ISIR transaction.
ISIR CORRECTIONS • A corrected/subsequent ISIR can be generated by: • Applicant • School • Another school • NLSDS transaction • Each ISIR must be reviewed for changes to data elements and: • SAR “C” Flag • Reject Codes • Comment Codes • NSLDS transaction
TAX RETURNS • May be requested or student may have provided without request. All tax returns on file must be reviewed whether or not the student has been chosen for verification. • Filing status is correct and consistent with other information • AGI • Taxes Paid • IRA/Keogh deductions • Untaxed income included on the tax return (except schedules)
Not Tax Experts!!!! • No, we aren’t!!! But we do have a responsibility to have a “fundamental understanding” of tax issues that can affect a student’s eligibility for assistance. • You are obligated to know: • whether a person was required to file a tax return, • what the correct filing status for a person should be, and • that an individual cannot be claimed as an exemption by more than one person.
CORRECT FILING STATUS? • Single • not married • divorced, legally separated, widowed (no dependent children) • Married Filing Jointly or Separately • married and living together • married and living apart, but not legally separated • Head of Household • unmarried or considered unmarried on last day of year • filed a separate return • spouse did not live in the home during the last 6 months of the year • home was the main home of the qualifying dependent
ALL DOCUMENTS RECEIVED • Examples: • Institutional Applications • Transcripts (High School and College) • Academic Progression • Changes to Major/Eligible Program • Changes to Enrollment • All aid received (even by other offices) • Policies must be written, equitable and consistent
HELPFUL RESOURCES • www.ifap.ed.gov • Federal Student Aid Handbook • Application and Verification Guide • ISIR Guide – Appendix A – Reject Codes and Reject Reasons • ISIR Guide – Appendix B - Database Matches and Match Flags • SAR Comment Codes and Text • www.irs.gov • Publication 17 • www.nslds.ed.gov