Summary: Correcting Social Security Number (SSN) errors and other student identifier information
Author: ODAS - Office of the Deputy Assistant Secretary - SFA
Posted June 24, 1998
Summary: This message provides guidance on how schools should advise applicants to correct Social Security Number (SSN) errors and other student identifier information in the federal student aid application processing system.
It has come to my attention that there is some confusion regarding how the Department of Education (ED) uses student identifiers in the federal student financial aid application process and, in particular, the proper way to correct errors in those identifiers. For example, should an applicant make a SAR/ISIR correction, file a new FAFSA, or file a Correction FAFSA to correct an SSN error?
Because of ED's reliance on accurate SSNs for all federal student aid applicants for the National Student Loan Data System (NSLDS), Pell Grant Recipient and Financial Management System (PGRFMS), statistical analysis of the SSN match process, and other data matches, it is critical that correct SSNs be reflected on all applicant records. Postsecondary schools are required to ensure that ED is notified of a student's accurate SSN if the school has some documentation that the SSN the student included on his/her FAFSA or SAR/ISIR is incorrect. (See CFR 34 668.36(b)(2).
How the Central Processing System identifies students
When a FAFSA is filed for the first time each application year, the Social Security Number (SSN) and first two letters of the last name become the student's identifier, and a transaction 01 is created. The Central Processing System (CPS) assumes that any subsequent FAFSA or correction transaction with an identical SSN and first two letters of the last name belongs to the same applicant.
If an applicant submits corrections to either the SSN or name fields (or to both) on the SAR/ISIR, the corrected data items will be updated and an incremental transaction number created. However, the original SSN and first two letters of the original last name will remain as the applicant's identifier.
If an applicant, after initially submitting a FAFSA application, submits another FAFSA, using the same SSN and last name, only changes the applicant may have included in the home address and college choice fields will be updated. An incremental transaction number is created and the original identifier remains a part of the applicant's record. No other data items are updated even though they were included on the second FAFSA application.
If two or more applicants apply using the same SSN and a last name that begins with the same two letters, the CPS cannot determine which applicant is the "true owner" without the involvement of the applicants. We are continuing to look into making changes to the CPS to better handle this situation so that no further, or only minimal, involvement from applicants would be required.
SSN Match Results
During the SSN Match with the Social Security Administration (SSA), an applicant record will be rejected only if the SSN provided does not exist in SSA's database (reject 18). If there is a match on the SSN contained in the SSA database, but either the name or date of birth does not match, the record is not rejected. Instead, match flag values are reported in the FAA Information section of the SAR/ISIR that inform the school that the match was not able to confirm the SSN of the applicant. Appropriate comments and the SAR "C" flag are included on the ISIR and SAR. For more information on this subject, please see 1998-99 Action Letter #5, dated May 1998.
Listed below are examples of how to correct certain data errors related to an applicant's SSN and other identifiers:
Data Entry Error: If the SSN or the first two letters of the last name were incorrectly keyed from the FAFSA during the data entry process, please refer these cases to the Federal Student Aid Information Center at (800) 433-3243. They will confirm data entry errors and refer them to ED to be automatically corrected without further action by the student or the school. New ISIRs and a new SAR will be produced with the correct identifiers.
Data Submission Error: If an applicant made an error in the SSN or name fields when completing the FAFSA, he or she should file a new FAFSA. Note that, in the case of an incorrect SSN, the applicant could make a correction to item 8 on his/her SAR/ISIR and resubmit it to the CPS to fulfill the regulatory requirement. However, if the SSN on the initial FAFSA is incorrect, ED recommends that the student file a new FAFSA (using the correct SSN) to fix the error and to ensure data integrity in our ED systems.
If an applicant, whose original FAFSA contained an incorrect SSN, files another FAFSA with the correct SSN after that student's Pell Grant award (if any) has been reported to the Department's Pell Grant payment system, steps must be taken to make corrections to the Pell Grant payment data. The school must submit a new Pell payment record using the original number that brings the award amount down to zero. The school must then submit the Pell payment data using the new Pell ID from the CPS transaction produced from the second FAFSA submission. This will allow the Pell information for the student to be correct. It will also allow Pell payment information for the student whose identifiers are the same as the original submission, to be included in the Pell database.
Two Applicants with same Identifiers: Once an identifier has been established for an award year, any subsequent applications using that same identifier will receive the data from the first application except for the new address and any institutions listed. In order to resolve this problem the Department has created a special Correction FAFSA process.A Correction FAFSA is necessary when an applicant's SSN and first two letters of the last name have already been used by someone else (evidenced by comment 40 printed on the SAR/ISIR).
The processed Correction FAFSA will retain all of the data provided, including address and institutions listed, and will generate a SAR/ISIR with an incremental transaction number for that identifier. Correction Applications are only available from the Department of Education at (202) 260-9988.
I hope this notice addresses the way SSN and last name data corrections should be made. If you require additional information, please contact SFAP Customer Support at (800) 433-7327.
Diane E. Rogers
Acting Deputy Assistant Secretary
Student Financial Assistance Programs