1. TASFAA 2017 Education Is Key

2. TASFAA 2017 Education Is Key Session Title:
Resolution of the “399” ISIR Comment Code
Presented By:
Stephen White
Director of Financial Aid
Middle Tennessee State University
TASFAA 2017
Education Is Key

3. TASFAA 2017 Education Is Key Session Objectives:
Overview of ISIR Comment Code 399 resolution.
Resources
Audience participation – Q&A; Best practices
If time allows, discussion regarding increased PJ resulting from PPY
TASFAA 2017
Education Is Key

4. Overview of ISIR Comment Code 399 Resolution:
1. The and FAFSA applications both use 2015 year income / tax information. Once you receive a ISIR Comment Code (CC) 399 resulting from conflicting income / tax information between the two award years, you cannot disburse additional federal / state aid until resolved. The institution is not liable for Title IV / TSAC funds disbursed prior to CC 399.
TASFAA 2017
Education Is Key

5. Overview of ISIR Comment Code 399 Resolution:
2. If the student is enrolled at the point you receive CC 399, you must contact the
student to resolve conflicting information. Else, if not enrolled, you must still track in the event the student returns or
Specify the FAFSA questions that are in conflict.
Specify a deadline date for resolution.
Specify that failure to resolve conflicting information will result in notification to federal / state agencies that a Pell, SEOG, Perkins Loan overpayment has occurred.
Specify that failure to resolve conflicting information will result in the student owing the full amount of Pell, SEOG, and Perkins Loans already disbursed for the award year.
Specify that the student will be ineligible for additional federal / state funds until the overpayment is resolved.
TASFAA 2017
Education Is Key

6. Overview of ISIR Comment Code 399 Resolution:
3. If the student resolves conflicting information, you must determine whether the
student was eligible for Pell, SEOG, Perkins Loan, and Subsidized Stafford Loan funds previously disbursed for the award year.
Regarding Pell…
In some cases, the EFC does not change. You can proceed with disbursing Pell based on the initial award.
Based on a lower EFC, you might be able to increase the Pell award.
Based on a higher EFC, you might be able to reduce the Spring / Summer Pell awards to preclude an overpayment.
Based on a higher EFC, the student might owe a repayment to the Federal Pell Grant for funds disbursed prior to receiving CC 399.
TASFAA 2017
Education Is Key

7. Overview of ISIR Comment Code 399 Resolution:
Regarding SEOG…
If the student is still eligible for Pell but no longer has an EFC of zero, the student might be in an overpayment status depending upon your institutional policy.
The student must repay SEOG if he/she was not eligible to receive Pell.
Regarding Perkins…
You may need to adjust the award if a change of EFC precludes sufficient “need” for the Perkins Loan or the student might need to repay a portion or all of the loan.
Regarding Subsidized Stafford…
You might need to adjust subsequent disbursements or reallocate to Unsubsidized Stafford if there is a change of EFC that impacts “need”. Regardless, the student is not reported as an overpayment status to NSLDS but must honor conditions of MPN.
TASFAA 2017
Education Is Key

8. Overview of ISIR Comment Code 399 Resolution:
4. If the student resolves conflicting information that results in a Pell, SEOG, Perkins
Loan overpayment, notify the student of the overpayment and allow 30 days for the student to make payment of the overpayment amount to the institution.
Update NSLDS and e*GRandS as applicable regarding the overpayment. On NSLDS, specify the type fund (example: Pell), date of disbursement (must match COD and your system), indicator as “Overpayment”, today’s date, amount of overpayment, and source as “School”.
If the student makes full payment, reduce the Pell, SEOG, Perkins Loan awards that were previously disbursed by the overpayment amount and update COD and G-5 regarding the updated disbursement record. Also update NSLDS (“Repaid” with “Zero” balance) and e*GRandS to reflect the overpayment has been resolved.
If the student fails to make payment, notify the student that the collection process has been transferred to the Federal Default Resolution Group. Update NSLDS as Transfer. Send documentation to the Federal Default Resolution Group.
TASFAA 2017
Education Is Key

9. Overview of ISIR Comment Code 399 Resolution:
5. If the student fails to resolve conflicting information, notify the student of the
overpayment and allow 30 days for the student to repay all Pell, SEOG, and Perkins Loan awards disbursed during to the institution.
Update NSLDS and e*GRandS as applicable regarding the overpayment. On NSLDS, specify the type fund (example: Pell), date of disbursement (must match COD and your system), indicator as “Overpayment”, today’s date, amount of overpayment, and source as “School”.
If the student makes full payment, then reduce the Pell, SEOG, Perkins Loan awards that were previously disbursed by the overpayment amount and update COD and G-5 regarding the updated disbursement record. Also update NSLDS (“Repaid” with “Zero” balance) and e*GRandS to reflect the overpayment has been resolved.
If the student fails to make payment, notify the student that the collection process has been transferred to the Federal Default Resolution Group. Update NSLDS to Transfer. Send documentation to the Federal Default Resolution Group.
TASFAA 2017
Education Is Key

10. Overview of ISIR Comment Code 399 Resolution:
6. If you determine that the student only received a Federal Subsidized Stafford Loan
overaward, do not update NSLDS as an overpayment. Additionally, do not update e*GRandS as an overpayment. The student will be required to make repayment per requirements of the MPN. If the student fails to resolve conflicting information, cancel undisbursed Federal Subsidized awards as applicable.
TASFAA 2017
Education Is Key

11. Overview of ISIR Comment Code 399 Resolution:
7. TSAC Programs
If you paid TSAA, Aspire, Access, Hope Non-Trad prior to the “399” ISIR Comment Code, the student does not have to repay these funds even if the EFC goes beyond 2100 or the AGI goes above $36,000.  However, in such cases, the student becomes ineligible for future disbursement of these funds for the award year.  The student is ineligible for future state funds if the federal overpayment is not resolved and you have updated NSLDS to reflect overpayment.
TASFAA 2017
Education Is Key

12. TASFAA 2017 Education Is Key Resources
34 CFR (f): Administrative capability – Identify and resolve discrepancies.
Early FAFSA website:
Electronic Announcement 09/14/15 President’s Announcement of FAFSA Filing Changes
Electronic Announcement 02/18/16 Preparing for Early FAFSA and PPY
Electronic Announcement 03/11/16 Availability of the Early FAFSA Info Page
Electronic Announcement 03/18/16 Determining FAFSA Prior-Prior Items
Electronic Announcement 04/12/16 Frequently Asked Questions
Electronic Announcement 05/06/ System and Software Availability Dates
Electronic Announcement 06/14/16 Availability of FSA Resources for
Electronic Announcement 08/10/16 Ltr. from Undersecretary Mitchell to Presidents
Electronic Announcement 10/13/16 Outreach Campaign Counters Myths of Fin. Aid
Electronic Announcement 10/13/16 CPS to Update Records Incorrectly Assigned CC 399
Electronic Announcement 10/21/16 Institutional Responsibilities to Resolve CC 399
Electronic Announcement 10/27/ FAFSA Campaign
TASFAA 2017
Education Is Key

13. TASFAA 2017 Education Is Key Resources Early FAFSA website (cont.):
Electronic Announcement 11/18/16 Institutional System Delay in Resolving Conflicting Info
Electronic Announcement 11/30/17 CPS Modifications to Assignment of SAR CC 399
GEN /11/16 Use of PJ when PPY Income is Used for FAFSA Info
GEN /03/ FAFSA – Identification / Resolution of CC 399
Frequently Asked Questions
SFAH – Volume 4, Chapter Overawards and Overpayments
TSAC Guidance /27/16
Not required to repay state aid if disbursed prior to CC 399
If updating NSLDS regarding overpayment, update e*GRandS
NASFAA Webinar /22/17 Verification and PJ in a PPY World
TASFAA 2017
Education Is Key

14. Questions from the Audience:
TASFAA 2017
Education Is Key