1. Conflicting Information and Data Accuracy
Allene Begley Curto, Associate Director of Financial Aid Services, Springfield College

2. Conflicting Information
CFR (f)

3. Conflicting Information
Requirement to verify questionable data
34 CFR (a)(2)
“If an institution has reason to believe that an applicant’s FAFSA information is inaccurate, it must verify the accuracy of that information.”

4. FSA AVG 18/19 (AVG 115) CONFLICTING INFORMATION
In addition to reviewing application and data match information from the CPS, a school must have an adequate internal system to identify conflicting information—regardless of the source and regardless of whether the student is selected for verification—that would affect a student’s eligibility, such as information from the admissions office as to whether the student has a high school diploma or information from other offices regarding academic progress and enrollment status. The school must resolve all such conflicting information, except when the student dies during the award year or when she is no longer enrolled and will not re-enroll; if the student later enrolls, you are again obligated to resolve the conflicting information.
If your school has conflicting information concerning a student’s eligibility or you have any reason to believe his application information is incorrect, you must resolve the discrepancies before disbursing FSA funds and, as with verification, before making any PJ adjustment. If you discover discrepancies after disbursing FSA funds, you must still reconcile the conflicting information and take appropriate action under the specific program requirements.

5. Possible sources of conflicting information
Information from other offices at the school
Subsequent ISIRs
Discrepant tax data
Comment codes 400 and 401 (possible conflicting information from IRS DRT)
IRS DRT code 07 (possible conflicting information from IRS DRT)
Any other questionable data

6. Information From Other Offices
HS diploma or GED
Academic Progress
Enrollment status
Any other information normally available to the institution regarding citizenship, previous educational experience, social security number, or other factors relating to Title IV eligibility

7. Subsequent ISIRs Required to Review: Change to EFC Change to C flag
New comments that might impact eligibility
NSLDS information that might impact eligibility (add or remove default, add or remove overpayment, LEU, SULA, aggregate loan limits, annual loan limits)

8. Review of Subsequent ISIRs
How do you know when received?
We “ lock” from automatic loading if there is a counselor coded (meaning review has begun)
We load and review these “bypassed” ISIRs for all required elements
If applicant or another school has changed a data element – we must document why we did or did not accept that change.

9. Discrepant tax data FAAs are required to know:
If an applicant is required to file
Correct filing status
That a person can’t be claimed as an exemption by more than one person
Note that comments encourage review by institution but don’t require resolution

10. C Codes 400 and 401
Possible conflicting information on data transferred by IRS for parent (400) or student (401)
If there is a correction to FAFSA after the use of IRS DRT that might invalidate the IRS DRT (change in marital status or date for example) the school must review to see if action needs to be taken to request new documentation.

11. 2018/19 400/401 Resolution May Be Required

12. Questionable Data Requirement to verify questionable data
34 CFR (a)(2)
“If an institution has reason to believe that an applicant’s FAFSA information is inaccurate, it must verify the accuracy of that information.”

13. Amended Returns
Beginning in 2018/19, the question will no longer be asked on the FAFSA “did you file an amended return?”
There is a new IRS Request Flag with a value of 07 that indicates that the applicant or parent filed an amended tax return. This flag is set when the applicant or parent links to the IRS, successfully authenticates, chooses to transfer his/her information into the FAFSA form, and the IRS determines that the tax filer has an amended return on file for the relevant tax year (2016 for the 2018–19 FAFSA). However, the income and tax information that is transferred from the IRS will be from the originally filed tax return and will not include changes that were made on the amended tax return (IRS Form 1040X).
If an institution receives an ISIR with an IRS Request Flag value of 07, it must contact the applicant or parent, as applicable, and make any necessary changes to any of the data items, regardless of whether those items are required to be verified.

14. FAFSA filers can no longer see IRS DRT values

15. Data Accuracy What data is brought in from other sources?
Registrar – grades, major, CIP codes, credits enrolled, repeat courses, ineligible courses, leaves of absence and withdrawals
Admissions – term of entry, admission status, HS completion, citizenship
Faculty – Never attended, stopped attending

16. Data Accuracy How do we ensure the accuracy of the data?
FAO needs to be part of the discussion on data recorded and how it is used
FAO needs to review data received from ther sources for conflicting information and for accuracy
How do we keep the data current?
Determine the frequency and schedule to bring in data that will provide FAO with data needed

17. Questions? Allene Begley Curto Associate Director of Financial Aid
Springfield College