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(General) Subject: Operational Implementation Guidance - Implementation of Federal Student Aid System and Software Updates on October 23, 2011 for New SSA Guidelines

Posted Date:October 7, 2011

Author: William Leith, Service Director, Program Management, Federal Student Aid

Subject: Operational Implementation Guidance - Implementation of Federal Student Aid System and Software Updates on October 23, 2011 for New SSA Guidelines

As described in the June 23, 2011 electronic announcement posted to the Information for Financial Aid Professionals (IFAP) Web site, the Social Security Administration (SSA) implemented new guidelines on June 25, 2011 for assigning Social Security Numbers (SSNs) that include assigning SSNs in previously unused numeric ranges. In a follow-up July 8, 2011 electronic announcement, we provided interim guidelines for assisting students assigned SSNs after June 25, 2011, and indicated that a permanent solution would be implemented on October 23, 2011.

SSA's procedural change affected the ongoing 2011-2012 application process in several ways. The Central Processing System (CPS) currently uses the previously unassigned "888" SSN range to assign pseudo-SSNs to students from the Pacific Islands who would not otherwise be able to submit a Free Application for Federal Student Aid (FAFSA). Additionally, our application submission systems (such as FAFSA on the Web and the FAA Access to CPS Online Web site) were developed to identify and reject applications using SSN ranges that were not considered valid.

At this time, we want to provide schools with more information about the updates we will implement on October 23, 2011 to Federal Student Aid systems to permanently address the new SSA guidelines.

We present this information in the following order:

  • Impact to the CPS

  • Impact to the Electronic Data Exchange (EDE) Process

  • Impact to FAFSA on the Web

  • Impact to FAA Access to CPS Online

  • Impact to the Federal Student Aid PIN Web site

  • Impact to the 2011-2012 EDExpress Software

  • Impact to the Common Origination and Disbursement (COD) System

  • Impact to the National Student Loan Data System (NSLDS)

Impact to the CPS

The following major changes will be implemented to the CPS on October 23, 2011 to accommodate the new SSA guidelines:

  • The CPS will be updated to identify and process electronic and paper applications and corrections with “666” as the first three numbers of the SSN as Pacific Island students. These records will be excluded from the CPS match process with the SSA.

  • Application and correction records with “888” as the first three numbers of the SSN will now be identified and processed as valid SSNs (instead of pseudo-SSNs). The CPS will submit “888” records to the SSA as needed for matching according to normal processing routines applied to other valid SSNs.

  • We will remove CPS reject code P (Invalid SSN Range), which is currently generated when an application or correction record is received that has a Current SSN value outside of the valid SSN ranges used by the SSA prior to implementation of its new guidelines.

Note: With the implementation of these changes on October 23, 2011, Pacific Island students who choose to submit a paper FAFSA rather than use FAFSA on the Web for 2011-2012 (and for future award years) should enter "666" in the first three characters of the SSN field. The CPS will assign the student a new "666" pseudo-SSN when the application is processed. Instructions for EDE and Web applications for Pacific Island students are described below, in the sections titled "Impact to the EDE Process," "Impact to FAFSA on the Web," and "Impact to FAA Access to CPS Online."

In addition to these CPS changes, on October 23, 2011, the CPS will convert all Pacific Islanders' records from the 2004-2005 cycle through the 2011-2012 cycle to the new “666” pseudo-SSN range. We will also system-generate new transactions for all Pacific Islanders' records from the 2010-2011 and 2011-2012 cycles submitted through October 23, 2011, which will result in new Student Aid Report (SAR)/Institutional Student Information Record (ISIR) outputs being sent to the applicant/school. These new transactions will list the “888” pseudo-SSN as the Original SSN field value, which represents the original key associated with the FAFSA and is retained for tracking purposes, and the new “666” pseudo-SSN as the Current SSN field value.

Note: Although the FAFSA submission and correction deadlines have passed for the 2010-2011 cycle, we still must reprocess impacted 2010-2011 records to ensure we create 2011-2012 Renewal FAFSA records for eligible students with the correct identifier. We anticipate that 5,600 records will be reprocessed for 2010-2011. Schools may disregard these transactions, as no action can be taken on them.

Several methods exist for identifying 2010-2011 and 2011-2012 records resulting from this SAR/ISIR reprocessing:

  • Reprocessed ISIRs will be sent under the IGSG11OP (for 2010-2011) or IGSG12OP (for 2011-2012) message class.

  • Paper SARs and ISIRs for 2011-2012 will include the new SAR comment code 147, which states “The pseudo Social Security Number (SSN) previously assigned to you for processing your FAFSA has been changed from a number starting with 888 to the same number starting with 666. This change was necessary because the Social Security Administration has made a change in the way they assign Social Security Numbers.”

  • Paper SARs and ISIRs for 2010-2011 and 2011-2012 will include SAR comment code 172, which states “This SAR was produced because we have processed a change to your information based on information reported to us by another agency or as a result of a processing system change. Please review your SAR to see what effect, if any, this change has had on your application.”

  • ISIRs produced as a result of the reprocessing will include a value of “03” for the Reprocessed Reason Code (ISIR field #217) for 2010-2011 or a value of “04” for the Reprocessed Reason Code (ISIR Field #219) for 2011-2012.

Lastly, the CPS will generate and send a communication to all students included in the reprocessing explaining why they are being assigned a new pseudo-SSN and to contact the Federal Student Aid Information Center if they need more information. Students with a valid e-mail address on their reprocessed 2010-2011 or 2011-2012 CPS transaction will receive this communication through e-mail; otherwise, a paper letter will be sent to the student.

Impact to the EDE Process

Starting on October 23, 2011 schools and vendors using the EDE process to submit FAFSA data directly to the CPS (under message class EAPS12IN) should enter "666" in the SSN field for Pacific Island students. As with paper application processing, the CPS will assign the student a new "666" pseudo-SSN when the EDE application is processed.

When correction data is submitted to the CPS using EDE (under message class CORR12IN), the applicant’s original SSN serves as the key for FAFSA tracking purposes and should be provided. Therefore, schools and vendors submitting correction data using EDE for Pacific Island students whose FAFSAs were processed prior to October 23, 2011 should continue to provide the original “888” pseudo-SSN the student was assigned in the Original SSN field of the correction record. If the application was processed after October 23, 2011, the school or vendor should submit the original “666” pseudo-SSN assigned by the CPS as a result of the system updates described earlier in this message.

Impact to FAFSA on the Web

On October 23, 2011, we will remove data edits from FAFSA on the Web that prevent students from submitting applications using SSNs in a range previously identified as unissued by the SSA.

Pacific Island students submitting new 2011-2012 applications after October 23, 2011 are now directed to enter a pseudo-SSN beginning with “666” instead of “888.” Students submitting corrections should use the “666” pseudo-SSN they receive as a result of the SAR/ISIR reprocessing described in the prior section.

Impact to FAA Access to CPS Online

As with the FAFSA on the Web site, we will remove data edits from the FAA Access to CPS Online Web site on October 23, 2011 that prevent financial aid administrators from submitting applications using SSNs in a range previously identified as unissued by the SSA.

Transactions for 2010-2011 and 2011-2012 that result from reprocessing to update an “888” pseudo-SSN to a “666” pseudo-SSN will have a Reprocessed Reason Code value of "03" (for 2010-2011) or “04” (for 2011-2012) displayed on the FAA Info page in Student Inquiry on the FAA Access to CPS Online Web site.

Renewal applications submitted by financial aid administrators on behalf of Pacific Island students for 2011-2012 after October 23, 2011 should use the “666” pseudo-SSN the student received as a result of the reprocessed record for 2010-2011.

Impact to the Federal Student Aid PIN Web Site

On October 23, 2011, we will update data edits on the Federal Student Aid PIN Web site that prevent students from submitting PIN applications using SSNs in a range previously identified as unissued by the SSA.

Students from the Pacific Islands continue not to be eligible for a PIN due to the lack of a SSN. Pacific Island students who use their “666” pseudo-SSN to apply for a PIN will encounter an edit that indicates they have entered an invalid value for their SSN.

Impact to the 2011-2012 EDExpress Software

On October 23, 2011, we will post EDExpress 2011-2012, Release 4.0 to the Department’s Federal Student Aid Download (FSAdownload) Web site, located at https://www.fsadownload.ed.gov. Release 4.0 will update the Global and App Express modules to allow schools to create new EDExpress records for Pacific Island students using a “666” pseudo-SSN and submit them using the EDExpress interface with the FAA Access to CPS Online Web site. The software change will be transparent to EDExpress users.

Impact to the COD System

A system change is not required for the COD System. However, on October 23, 2011 we will convert all existing students with previously assigned pseudo-SSNs beginning with “888” to new pseudo-SSNs beginning with “666”. In addition, we will convert other pseudo-SSN ranges that currently exist within the COD System. Specifically, we will convert all pseudo-SSNs beginning with “8” (excluding any “888” numbers) and those in the ranges beginning with “734-749” and “773-799” to new pseudo-SSNs beginning with “988-8”. We will make these changes to all active award years on the COD System.

To assist a school with identifying students whose pseudo-SSNs have changed, we will include the students on the SSN-Name-Date of Birth Change Report made available via a school’s reporting newsbox on the COD Web site or sent to the school via the Student Aid Internet Gateway (SAIG). If a school has impacted students, but has opted to not receive this report, the school will be contacted directly by the COD School Relations Center.

Impact to the NSLDS

NSLDS will be updated to match the changes made in the CPS and the COD System. For students with converted SSNs, NSLDS will maintain a cross-reference to the student's prior "888" pseudo-SSN.

Data providers may continue to create and report to NSLDS pseudo-SSNs following the instructions found in the most current version of the Guaranty Agency (GA) Data Provider Instructions (Version 4.1, June 2005) or the Federal Perkins Data Provider Instructions (Version 4, June 2007).

Contact Information

For more information about the change at SSA for assigning SSNs, refer to the following information on the SSA Web site: www.SSA.gov/employer/randomization.html.

If you have questions regarding the updates to the CPS, the EDE process, the FAA Access to CPS Online Web site, or EDExpress 2011-2012, contact CPS/SAIG Technical Support at 800/330-5947 (TDD/TTY 800/511-5806) or by e-mail at CPSSAIG@ed.gov.

If your students have questions regarding FAFSA on the Web, the PIN Web site, or the CPS reprocessing described in this message, ask them to contact the Federal Student Aid Information Center at 800/4-FEDAID (800/433-3243) or by e-mail at FederalStudentAidCustomerService@ed.gov. TDD/TTY service is also available at 800/730-8913.

If you have questions regarding the updates to the COD System, contact the COD School Relations Center at 800/474-7268 for Grants or 800/848-0978 for Direct Loans. You may also e-mail CODSupport@acs-inc.com.

If you have questions regarding NSLDS, contact the NSLDS Customer Support Center at 800/999-8219. You can also contact Customer Support by e-mail at nslds@ed.gov.