This Electronic Announcement provides additional flexibilities for late disbursements for students who initially filed a paper FAFSA® form for the 2024-25 award year. This includes students who may have submitted a paper FAFSA form but later filed an online FAFSA form due to paper processing delays.
Extension of the Ability to Use Application Receipt Date to Establish Late Disbursement Eligibility
The U.S. Department of Education (Department) is aware that there may be instances in which Title IV-eligible students submitted a paper FAFSA form and completed their enrollment before their paper FAFSA form was processed by the Department. A school that receives an ISIR for a student who is no longer enrolled but whose Application Receipt Date (of a paper FAFSA) was prior to the end of the student’s enrollment and who would have otherwise been eligible to receive a Title IV disbursement may still award and disburse the funds, subject to normal late disbursement requirements found in 34 C.F.R. § 668.164(j). This extends the guidance initially announced in Electronic Announcement GENERAL-24-94, which was limited to the summer 2024 term, to the entire 2024-25 academic year.
When possible, schools should use the Application Receipt Date provided on the student’s processed ISIR from the FAFSA Processing System (FPS). However, if the school is aware that the Application Receipt Date on the ISIR is not an accurate reflection of the student’s initial application date, the school may obtain documentation to support the use of an earlier paper FAFSA form application date to establish late disbursement eligibility. Such documentation could include a copy of the original paper FAFSA form, mailing receipts or delivery confirmation from the mailing service, or a signed statement from the student attesting to the date the paper FAFSA form was initially submitted. In these circumstances, institutions must maintain this documentation in the student’s file to confirm eligibility despite an Application Receipt Date in the student’s ISIR record that may be later than the date the school documented.
Additional Flexibility to Establish the 180-Day Late Disbursement Timeframe
The late disbursement requirements established under 34 C.F.R. § 668.164(j) contain several conditions including a requirement that a late disbursement must be paid within 180 days from when the institution determined the student withdrew or when the student became ineligible (dropped below halftime, completed their period, etc.). The Department is aware that, even if the student is able to meet the expanded Application Receipt Date allowance in the circumstances outlined in this Electronic Announcement, a student may still not be able to receive a late disbursement of Title IV funds due to the 180-day late disbursement timeframe restriction.
Therefore, to minimize the impact of any Department system delays on the ability of students to receive Title IV funding they would otherwise be eligible to receive, for this limited circumstance, for students who filed paper FAFSA forms for the 2024-25 award year, the 180-day late disbursement timeframe will start from the later of: (1) the date the student withdrew or otherwise became ineligible for the award year, or (2) the earliest Transaction Processed Date with an official SAI.
Additional Resources
Late disbursement requirements: 2024-25 FSA Handbook, Volume 4, Chapter 2
ISIR Record Layouts and Processing Codes: 2024-25 FAFSA Specifications Guide, Volume 4
Contact Information
Any questions about this announcement should be sent through the Contact Customer Support form link in Federal Student Aid’s Help Center. When submitting a question, please enter your name, email address, IHE, topic, and question. When selecting a topic, please select “2024-25 FAFSA.”