G-Q1: Will FAFSA applicants have an option to use tax year 2016 income and tax information?
No. Beginning with the 2017-2018 FAFSA, students and parents will be required to use income and tax information from the 2015 tax year. However, a financial aid administrator (FAA) may use professional judgment to change any of the income or tax items by using the 2015 (or any other recent 12 month period) income and tax information, if the FAA determines that there are extenuating circumstances that justify the use of information other than the 2015 tax year information. The fact that the student might be eligible for more aid based upon the use of 2016 information is not, by itself, sufficient reason for an FAA to make a professional judgment decision to use 2016 income. [April 12, 2016]
G-Q2: Will the Pell Grant award and disbursement schedules be released earlier since the FAFSA will be available earlier?
Probably not. Development and release of the Pell Grant schedules are dependent on Congressional action which likely will not occur earlier than what has occurred over the past several years. [April 12, 2016]
G-Q3: Will institutional campus-based allocations be released earlier?
Probably not. Like the issuance of the Pell Grant schedules, release of campus-based allocations are contingent on Congressional action. [April 12, 2016]
G-Q4: Since the 2017-2018 FAFSA will use information from 2015, will the 2017-2018 expected family contribution (EFC) calculation use the same need analysis tables that are used for the 2016-2017 EFC calculations?
No. The 2017-2018 EFC calculation will use updated need analysis tables. [April 12, 2016]
G-Q5: Will the 2017-2018 EFC need analysis tables be available earlier?
Yes. The Department expects to publish in the Federal Register the 2017-2018 EFC calculation tables by the end of May. [April 12, 2016]
G-Q6: To support those institutions that award earlier, will the Department’s Common Origination and Disbursement (COD) system be available earlier for submitting 2016-2017 originations?
No. COD functionality will not be available for 2017-2018 award originations until March 2017. [April 12, 2016]
G-Q7: Will the IRS Data Retrieval Tool (IRS/DRT) be available when the FAFSA start-up begins on October 1, 2016? Similarly, will the IRS be ready to accept IRS tax return transcript requests on October 1, 2016?
Yes to both. The IRS DRT will be available when the 2017-2018 FAFSA processing begins on October 1. Additionally, we have been assured by the IRS that they will be prepared to respond to IRS tax return transcript requests on and after October 1, 2016. [April 12, 2016]
G-Q8: Will institutions have to review all of their students 2016-17 and 2017-2018 ISIRs to determine if there might be conflicting information because the two FAFSAs (2016-2017 and 2017-2018) are supposed to be completed using the same 2015 income and tax information?
No. To reduce burden on both institutions and FAFSA applicants, the Department has developed a process where the Central Processing System (CPS) will, when processing an applicant’s 2017-2018 FAFSA, perform an automatic review when there is also a 2016-2017 FAFSA on file for the applicant. This review will determine if there might be conflicting information between the two FAFSAs. The CPS will flag for institutional resolution only those 2017-2018 ISIRs where any potential conflict, once resolved, would have a significant impact on the student’s 2017-2018 EFC. A Dear Colleague Letter is being prepared for release later this spring that will provide additional information on this subject.
Also, as we stated in "Early FAFSA Electronic Announcement #2", posted to IFAP on February 18, 2016, the most effective ways to prevent conflicting information from occurring is for the FAFSA applicant to use the IRS Data Retrieval Tool (IRS DRT) when completing both their 2016-2017 and 2017-2018 FAFSAs. [April 12, 2016]
G-Q9: Will the 2017-2018 FAFSA (either initial or renewal) be pre-populated with information from the applicant’s 2016-2017 FAFSA since the information should be the same?
No. There are too many instances where such pre-populating would result in incorrect information being included on the 2017-2018 FAFSA – e.g., changes in dependency status, changes in marital status, professional judgment. However, institutions are reminded that most 2017-2018 FAFSA filers who have filed an IRS income tax return will be able to use the IRS Data Retrieval Tool (IRS DRT) to import their 2015 income and tax information directly from the IRS into their 2017-2018 FAFSA. Using the IRS DRT is the fast and most accurate way to input income and tax information into the FAFSA. Use of the IRS DRT will dramatically reduce the likelihood that the applicant will be selected for verification. [April 12, 2016]
G-Q10: Will the implementation of the 2017-2018 Early FASFA cause multiple credit checks to be conducted for Direct PLUS Loan applicants?
The Early FAFSA implementation will not, by itself, cause multiple credit checks. However, actions taken by a school or PLUS Loan applicant may result in multiple credit checks, depending on the timing of those actions.
A Direct PLUS Loan credit check is valid for 180 days. This means that an applicant for whom a credit check was conducted will undergo another credit check if an action that triggers a credit check occurs more than 180 days after the date of the prior credit check.
A credit check is triggered if (1) a school submits a PLUS Loan award record to COD; (2) an applicant completes a Direct PLUS Loan Request on StudentLoans.gov; or (3) a school requests a credit check through COD.
An institution may want to modify its procedures to prevent multiple credit checks in connection with the Early FAFSA implementation. For example:
A school instructs its Direct PLUS Loan applicants to complete the Direct PLUS Loan Request as soon as the FAFSA is complete. A FAFSA is submitted in October 2017, and the applicant completes a Direct PLUS Loan Request at that time. This triggers a credit check. The school submits a Direct PLUS Loan award record in May 2018. This triggers a second credit check, because more than 180 days have elapsed since the prior credit check.
The school could eliminate the second credit check by changing its procedures to ensure that completion of the Direct PLUS Loan Request and submission of the PLUS award record occur no more than 180 days apart. [June 6, 2016]
G-Q11: Currently, if a student begins but does not complete a FAFSA, the partial application is saved for 45 days. Will the Department save 2017-2018 FAFSA data that has not been submitted to the Department by the student longer than the current 45-day limit?
No. The Department will not store FAFSA data that has not been submitted to the Department longer than the current 45-day limit. [June 6, 2016]
G-Q12: The chart included in Dear Colleague Letter GEN-16-14 described the circumstances under which an institution must resolve the conflicting information when a student’s 2017–2018 ISIR has Comment Code 399 (possible conflicting information). The letter is silent about institutions’ responsibilities when a student is no longer enrolled and is not expected to either re-enroll for the 2016–2017 award year or enroll for the 2017–2018 award year. Has the Department developed guidance for these situations?
Yes. If the institution receives the 2017–2018 ISIR with Comment Code 399, and the student is no longer enrolled and is not expected to re-enroll for 2016–2017 or enroll for 2017–2018, the institution is not required to resolve the possible conflicting information. However, if the student subsequently enrolls, or re-enrolls, for any period associated with either the 2016–2017 or 2017–2018 award years, the institution must resolve the conflicting information. [September 6, 2016]
G-Q13: Dear Colleague Letter GEN-16-14 says that if the new Comment Code 399 is not included on the student’s 2017–2018 ISIR, the institution is not required to determine if there are any differences in income or tax information between the two ISIRs. In what circumstances would Comment Code 399 not appear even if the reported 2015 tax/calendar year information differs between the student’s 2016–2017 and 2017–2018 ISIRs?
A student’s 2017–2018 ISIR will not include Comment Code 399 if:
The Department’s review of the information from the student’s 2016–2017 and 2017–2018 ISIRs results in a determination that any differences would not result in a significant change in the student’s expected family contribution (EFC);
The student is not expected to be Pell Grant eligible based on the 2017–2018 ISIR;
There was a change in the student’s dependency status between the 2016–2017 FAFSA and the 2017–2018 FAFSAs;
There was a change in the student’s or parents’ marital status between the 2016–2017 FAFSA and the 2017–2018 FAFSAs; or
Professional judgment was performed for the 2016–2017 award year. We remind institutions that upon making a professional judgment determination, it is very important that the CPS “Professional Judgement Flag” be set to ‘1.’ [September 6, 2016]
G-Q14: Must institutions resolve conflicting information if the student’s ISIR was flagged with Comment Code 399, but the ISIR was not selected for verification?
Yes, even if the ISIR was not selected for verification, institutions must resolve the possible conflicting information if the student’s 2017–2018 ISIR included Comment Code 399. While the process for resolving conflicting information is similar to verification the resolution of conflicting information is a separate process from verification. [September 6, 2016]
G-Q15: Can institutions use the documentation collected to verify income and tax information on the 2016–2017 FAFSA to resolve conflicting information or complete verification of the 2017–2018 FAFSA?
Yes, as noted in Dear Colleague Letter GEN-16-14, if for either year, the institution had verified the conflicting information item(s) or the student or parent had transferred information into the FAFSA using the IRS DRT and had not changed any of the transferred information (ISIR Fields #177- student and #178 parent with a value of ‘02’), the institution can assume that the verified or IRS DRT transferred values are correct and must, therefore, submit corrections to the other year’s ISIR values. [September 6, 2016]
G-Q16: Must conflicting information be resolved before an institution considers doing a professional judgment adjustment for either or both years?
Yes, as is the case for a student who has been selected for verification, the institution must resolve any possible conflicting information and submit any required ISIR changes to the CPS before it makes a professional judgement determination. [September 6, 2016]
G-Q17: The “Resolving Possible Conflicting Information and Submitting Corrections” section of Dear Colleague Letter GEN-16-14 instructs institutions to compare information from “both years” ISIRs to determine which income or tax item or items are in conflict.” Which 2016–2017 ISIR should be used for this comparison in cases where the institution received more than one 2016–2017 ISIR?
In cases where an institution has received more than one 2016–2017 ISIR for a student, the required comparison must be between the 2017–2018 ISIR with Comment Code 399 and the 2016–2017 ISIR that was, or will be, used as the basis for awarding and disbursing Title IV aid. [September 6, 2016]
G-Q18: Will a new 2017-2018 ISIR transaction with comment code 399 be generated if the only reason for the transaction is to indicate comment code 399? For example, if a 2017-2018 FAFSA is filed before the student’s 2016-2017 FAFSA, will a new 2017-2018 ISIR be generated to flag the student’s 2017-2018 ISIR with comment code 399 if the comparison between the two years results in conflicting information?
Comment code 399 will only appear on a 2017-2018 ISIR if there was conflicting information between the student’s 2016-2017 and 2017-2018 records when any 2017-2018 ISIR was processed. For example, if a 2017-2018 ISIR is processed before the student’s 2016-2017 FAFSA was submitted there cannot be a 399 code on the 2017-2018 ISIR since there would be no conflicting information. If the student then submits a 2016-2017 FAFSA no comparison with the previously processed 2017-2018 ISIR transaction will be made, thus no new 2017-2018 ISIR will be generated. However, if a subsequent 2017-2018 ISIR is generated for any reason (e.g. corrections, NSLDS post-screening) after the 2016-2017 FAFSA was processed, a comparison will be done and if conflicting information is identified, the new 2017-2018 ISIR will include the 399 code.[October 3, 2016; Updated November 21, 2016]
G-Q19: In Dear Colleague Letter GEN-16-14 published on August 3, 2016, the last item in the chart described how, when institutions intend on disbursing Title IV aid for 2017-2018, the institutions must resolve conflicting information even if the student never attended in 2016-2017. In these cases, since the student did not attend in 2016-2017, does the institution have to submit any identified corrections to the 2016-2017 ISIR?
No. If comment code 399 appears on the 2017-2018 ISIR, and the resolution of the conflicting information is that it is the 2016-2017 ISIR that is incorrect, the institution does not need to submit corrections to the 2016-2017 ISIR if the institution will not disburse Title IV aid for the 2016-2017 award year. [October 3, 2016]
G-Q20: When the resolution of conflicting information related to Comment Code 399 determines that a student is no longer eligible for all or some of the subsidized aid that had been awarded, what action must the institution take regarding the subsidized aid that was disbursed?
As discussed in Dear Colleague Letter GEN-16-14, if the resolution of Comment Code 399 results in an overaward, the institution may adjust any subsequent disbursements in the same award year to eliminate the overaward. For example, a student is eligible for $4,000 in Pell Grant funds for the 2016-2017 award year. The institution disburses $2,000 for the Fall 2016 semester with the remaining $2,000 scheduled to be disbursed for the Spring 2017. However, after resolving Comment Code 399, the institution determines that the student is only eligible for $3,500 in Pell Grant funds for the entire 2016-2017 award year. The institution must reduce the Spring 2017 disbursement from $2,000 to $1,500. Of course, if the student does not return for the Spring 2017 term, the overaward becomes an overpayment that must be returned.
If an institution determines that a student’s overaward cannot be totally eliminated by adjusting subsequent disbursements, any remaining portion of the overaward attributed to a Title IV grant or Perkins Loan must be returned. For more information on returning overawards, institutions can refer to Volume 4, Chapter 3 of the Federal Student Aid Handbook. [November 21, 2016]
G-Q21: What is a reasonable amount of time that institutions should allow students to submit documentation to resolve Comment Code 399?
When determining a deadline for submitting documentation to resolve a Comment Code 399, institutions should use the same guidance provided in the verification provisions of the April 4, 2016 Federal Register Notice. [November 21, 2016]