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(Application Processing) Subject: Issue Alert: CPS Modifications to Assignment of SAR Comment Code 399 Scheduled for February 5, 2017, with Related CPS Reprocessing on February 6, 2017

Posted Date:January 30, 2017

Author: Lisa DiCarlo, Director, Student Experience Group, Federal Student Aid

Subject: Issue Alert: CPS Modifications to Assignment of SAR Comment Code 399 Scheduled for February 5, 2017, with Related CPS Reprocessing on February 6, 2017

Updates to the Central Processing System (CPS) are being implemented on February 5, 2017, to adjust and potentially reduce the assignment of 2017-2018 Student Aid Report (SAR) comment code 399 to some 2017-2018 student transactions. These updates will modify how the CPS assigns SAR comment code 399 to 2017-2018 transactions with an “automatic zero” Estimated Family Contribution (EFC) and transactions with the professional judgment flag applied in 2016-2017.

The CPS will reprocess 2017-2018 transactions impacted by the updated logic for SAR comment code 399 assignment on February 6, 2017.

See the sections below for additional information.


We created SAR comment code 399 exclusively for the 2017-2018 processing cycle to address situations where CPS cross-year data edits identify discrepancies between financial information reported by the applicant for 2016-2017 and 2017-2018. With the implementation of prior-prior year financial information reporting for the 2017-2018 Free Application for Federal Student Aid (FAFSA®), the financial information submitted for the two cycles should be the same.

If the CPS identifies a discrepancy over a certain threshold in the calculated EFC between the two cycles during the processing of a 2017-2018 transaction, SAR comment code 399 is assigned, along with a SAR C code, requiring further verification by the financial aid administrator (FAA). The text of comment code 399 states, “Your Financial Aid Administrator may contact you to resolve any issues related to differences in the 2015 income information you reported on your 2016-2017 FAFSA and 2017-2018 FAFSA.”

CPS Modifications

We are implementing two key changes to the CPS on February 5, 2017 to modify the assignment of SAR comment code 399 to 2017-2018 records:

  • For students with an automatic-zero EFC for 2017-2018, the CPS will now compare financial information provided for 2017-2018 to the student’s 2016-2017 financial information; SAR comment code 399 will only be assigned to the transaction if the EFC difference calculated by the CPS is over a certain threshold.

  • We added a condition for student records with a professional judgement on the 2016-2017 transaction to be excluded from the cross-year edits that set SAR comment code 399.

We are aware that resolving comment code 399 situations with students has placed an additional burden on FAAs. The CPS modifications we are implementing on February 5, 2017 will both increase the accuracy of the assignment of comment code 399 and reduce the number of students receiving comment code 399.


The CPS will conduct a reprocessing on February 6, 2017 for 2017-2018 student records with an auto-zero EFC on their 2017-2018 record or a professional judgment on their 2016-2017 record. SAR comment code 399 will be added or removed as needed based on the updated logic that will be implemented on February 5, 2017.

This reprocessing will also include a sub-set of 2017-2018 dependent student records that need to be re-evaluated for SAR comment code 399 based on the resolution of a separate CPS issue that caused the cross-year EFC calculation to use the current cycle's calculated total income instead of the prior cycle's calculated total income. The reprocessing will potentially add or remove comment 399 from the records identified as being affected by this issue. This issue impacted students who were dependent, had student financial information on record, and qualified for the cross-year EFC calculation and edit.

We anticipate this reprocessing effort will affect less than 15,000 records.

Several methods will exist for schools to identify records resulting from the February 6, 2017 reprocessing:

  • Reprocessed Institutional Student Information Records (ISIRs) will be sent under the IGSG18OP message class.

  • SARs and ISIRs will include SAR comment code 172, which states “This SAR was produced because we processed a change to your information based on information reported to us by another agency or as a result of a processing system change. Review your SAR to see what effect, if any, this change has had on your application, and call 1-800-4-FED-AID (1-800-433-3243) if you have any questions.”

  • ISIRs produced as a result of the reprocessing will include a value of “02” for the Reprocessed Reason Code (ISIR field #230).

  • The FAA Information page in Student Inquiry on the FAA Access to CPS Online Web site will display “02 - Reprocessed because Comment Code 399 not assigned correctly” for the Reprocessing Code for the transaction resulting from the reprocessing.

Contact Information

If you have any questions regarding this message, contact CPS/SAIG Technical Support at 800/330-5947 (TDD/TTY 800/511-5806) or by e-mail at

You can also post questions to FSATech. FSATech is an electronic mailing list for technical questions about Federal Student Aid systems, software, and mainframe products. For more information on subscribing to FSATech, go to:

If your students have any questions regarding the upcoming changes described in this message, refer them to the Federal Student Aid Information Center at 800-4-FEDAID (800-433-3243) or by e-mail at TDD/TTY service is also available at 800-730-8913.

Last Modified: 01/29/2017