1. TASFAA 2018 Honoring the Past & Building the Future
Verification: Please Stop Changing
TASFAA 2018 Honoring the Past & Building the Future
Celia Bradley, Middle Tennessee State University
Kelly Hawthorne, Vanderbilt University

2. Honoring the Past and Building the Future
Introduction
Verification applies to recipients of the following Title IV aid:
Federal Pell Grant
Federal Supplemental Education Opportunity Grant (SEOG)
Federal Work-Study (FWS)
Direct Subsidized Loan
TASFAA 2018
Honoring the Past and Building the Future

3. Honoring the Past and Building the Future
Selection Process
Application can be selected by: OR
TASFAA 2018
Honoring the Past and Building the Future

4. Honoring the Past and Building the Future
Exclusions
Entire Application
Only Eligible For Unsub Loan
Selected after student ceasing to be enrolled at the school and all aid is paid. Also transferred and was verified at the other school.
Parental Data
Parent completing the FAFSA dies or is mentally incapacitated
Cannot be contacted or whereabouts unknown
Spousal Data
Same as Parental Data
Number in Household
Parents are married and household size is 3. Parent unmarried and household size is 2.
TASFAA 2018
Honoring the Past and Building the Future

5. Honoring the Past and Building the Future
TASFAA 2018
Honoring the Past and Building the Future

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TASFAA 2018
Honoring the Past and Building the Future

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TASFAA 2018
Honoring the Past and Building the Future

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TASFAA 2018
Honoring the Past and Building the Future

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TASFAA 2018
Honoring the Past and Building the Future

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TASFAA 2018
Honoring the Past and Building the Future

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TASFAA 2018
Honoring the Past and Building the Future

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TASFAA 2018
Honoring the Past and Building the Future

13. Honoring the Past and Building the Future
FAFSA Changes
New SAR Comment Codes 400/401 require resolution
IRS Request Flag Values added
IRS Request Flag Value of 06 - IRS DRT no longer valid
IRS Request Flag Value of 07 - IRS noted amended return filed
Note: Both the IRS DRT and the Tax Return Transcript include only the information from the original tax return filed with the IRS.
Expanded IRS Field Flags – Identifies the IRS DRT data items changed
TASFAA 2018
Honoring the Past and Building the Future

14. Honoring the Past and Building the Future
FAFSA Changes
Data that is transferred from the IRS DRT is now masked so that families cannot see the specific amounts transferred
Could cause some added calls, s, or even additional verification.
TASFAA 2018
Honoring the Past and Building the Future

15. Honoring the Past and Building the Future
Conflicting Information
Identifying and Resolving Conflicting Information
Comment Code 399
Comment Code 400/401
TASFAA 2018
Honoring the Past and Building the Future

16. Honoring the Past and Building the Future
Identifying Conflicting Information
Schools must have an adequate internal system to identify conflicting information. Examples of conflicting information:
Receipt of a subsequent FAFSA transaction (must review for potential changes)
Marital status and tax filing status are conflicting (married filing HOH)
Discrepant tax data (basic tax law knowledge required)
Failure to disclose attendance at all institutions (SAP)
TASFAA 2018
Honoring the Past and Building the Future

17. Honoring the Past and Building the Future
Comment Code 399
Although corrections can no longer be made to the FAFSA, schools must still resolve 399 as it relates to the FAFSA and make a notation in the student’s file. If the FAFSA is on file, compare the information reported on the FAFSA and request documentation, if applicable.
TASFAA 2018
Honoring the Past and Building the Future

18. Honoring the Past and Building the Future
Comment Codes 400/401
Students and parents using the IRS DRT can no longer view the information transferred from the IRS. This eliminated the inclusion of edits that may have identified potential issues. Instead, SAR Comment Codes of 400 and/or 401 were added. Resolution is required.
400 – Issues related to the reporting of parental data
401 – Issues related to the reporting of student data
TASFAA 2018
Honoring the Past and Building the Future

19. Honoring the Past and Building the Future
Potential Reasons for Comment Codes 400/401
Parent and/or student is a tax filer and the AGI is zero, but the income earned from work is greater than zero.
Parent and/or student’s Total of Additional Financial Information is greater than the AGI transferred from the IRS.
Parent and/or student reported any item from the FAFSA list of Untaxed Income that is equal to or exceeds the AGI transferred from the IRS.
TASFAA 2018
Honoring the Past and Building the Future

20. Honoring the Past and Building the Future
Other Reasons for 400/401
Other reasons for Comment Codes 400 or 401 are considered technical
reasons that do not require resolution, but be careful using this option. It may penalize the student.
Use FAA Access to determine the reason 400/401 appear by simulating a FAFSA correction by changing a middle initial and selecting calculate. The edit will appear.
TASFAA 2018
Honoring the Past and Building the Future

21. TASFAA 2018 Resolution of Comment Code 400/401
Review the information reported on the FAFSA to determine if it meets any of the three criteria previously described. These must be resolved.
Review FAFSA information for potential errors.
Request applicable documentation.
Simulate a change in FAA Access to see the reason for being selected flagged.
Make a note in the student’s file regarding the resolution of 400/401.
TASFAA 2018
Honoring the Past and Building the Future

22. Honoring the Past and Building the Future
Common 400/401 Issues
Parent information has been duplicated in the student section of the FAFSA
Parent 1/Parent 2 or Student/Spouse income earned from work is identical.
Income reported for 2016 is significantly different than amount reported for 2015.
TASFAA 2018
Honoring the Past and Building the Future

23. Honoring the Past and Building the Future
IRS Request Flag 06
An IRS Request Flag of 06 will be set to indicate data was transferred from the IRS, but a subsequent change made the parent ineligible to use the IRS DRT. The IRS Display Flag is set to K.
NASFAA AskRegs: “How Do We Resolve IRS Request Flag 06?”
TASFAA 2018
Honoring the Past and Building the Future

24. Honoring the Past and Building the Future
Resolving IRS Request Flag 06
Compare the FAFSA transactions to determine if corrections were
made to the marital status or marital status date that warrant the
request of additional information.
Confirm the correct parental information was reported on the
FAFSA by contacting the parent.
If changes were not submitted that would have caused the issue,
note in the student’s file that there were no apparent changes.
Request additional information/clarification as necessary to resolve the 06 issue.
TASFAA 2018
Honoring the Past and Building the Future

25. Honoring the Past and Building the Future
IRS Request Flag 07 for Amended Tax Returns
The IRS DRT will only transfer the tax information from the original tax return. If the IRS determines the tax return was amended or if the return was corrected by the IRS, the IRS Request Flag will be set to “07”.
Resolution is required, regardless of whether or not the FAFSA was selected for Verification.
NASFAA AskRegs: “How Do We Resolve IRS Request Flag 07 for Amended Returns?”
TASFAA 2018
Honoring the Past and Building the Future

26. TASFAA 2018 Resolving IRS Request Flag 07
Selected for Verification: Must document the original and amended tax information by requesting the following:
A signed copy of IRS Form 1040X that was filed with the IRS; and either of the following:
An IRS Tax Return Transcript or any other IRS tax transcript that contains all income and tax information from the original return; or
Unchanged IRS DRT data on the ISIR record
TASFAA 2018
Honoring the Past and Building the Future

27. TASFAA 2018 Resolving IRS Request Flag 07
Not Selected for Verification: Must document the original and amended tax information by requesting the following:
Same documents acceptable for those selected for verification;
A signed copy of the original tax return along with the 1040X, or
A signed statement explaining the changes, if the school deems that to be appropriate
TASFAA 2018
Honoring the Past and Building the Future

28. Honoring the Past and Building the Future
ISIR and Verification Resources
Federal Register – May 5, ( Information to be Verified)
Dear Colleague Letter GEN-17-05
Application and Verification Guide
ISIR Guide
Summary of Changes for the Application Processing System
Electronic Announcement August 16, 2017 (Verification Suggested Text)
Electronic Announcement August 7, 2017 (Changes to IRS DRT Process)
Electronic Announcement May 3, 2017
Electronic Announcement February 23, 2017
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Honoring the Past and Building the Future

29. Honoring the Past and Building the Future
ISIR and Verification Resources - continued
NASFAA Ask Regs
IRS Publication 17
IRS website
EDE Technical Reference
The EFC Formula,
TASFAA 2018
Honoring the Past and Building the Future

30. Honoring the Past and Building the Future
Questions?
TASFAA 2018
Honoring the Past and Building the Future