Part: 2 - - The Application Process
SectionTitle: Using the Official EFC to Document Eligibility
Using the Official EFC to Document Eligibility
The CPS calculates the "official" EFC using the CPS edits and eligibility matches. The EFC is printed at the top of the first page of the SAR. The EFC, the secondary EFC, and the alternate EFCs printed in the FAA Information section of the SAR are all considered official figures that can be used for payment. The CPS may provide the school with an official EFC on an ISIR. An EFC from a source other than the CPS is considered an estimated figure and cannot be used for payment of any federal student aid.
When a student qualifies for the simplified needs test but he or she provides asset information on the FAFSA anyway, a primary and secondary EFC are calculated. The simplified EFC is the primary and is printed on the front of Parts 1 and 2 of the SAR. Both the primary EFC and the secondary EFC (calculated by including the supplemental data) are printed on the back of Part 2 in the heading of the School Use Only box.
The secondary EFC is rarely used. If you need to use the secondary EFC in determining the student's Pell Grant, you must indicate such when you report the Pell Grant payment.
You must base a student's Pell Grant on his or her official EFC, and you must resubmit through the CPS any data changes that result in a changed award. Ultimately, to document a student's eligibility for a Pell Grant, you must have in your records the student's final EFC and the correct application data used to calculate that EFC. The student's valid ISIR serves as this eligibility document or record (a valid ISIR is one on which all the information used to calculate the EFC is correct). Also note that a copy of an ISIR a school receives from a student or another school does not constitute a valid eligibility document; the CPS must send the ISIR directly to your school.
For the other federal student aid programs (except PLUS), you must have in your files at least one ISIR containing an official EFC and data processed by the CPS for each recipient. This ISIR need not contain the final, corrected, or adjusted data for that student. It merely documents that the student's data has been processed through the CPS and has gone through system edits and the eligibility matches.
You may not make payments based on an estimated EFC (an EFC from a source other than the CPS). Packaging can be based on an estimated EFC, and a FFEL application can be certified with an estimated figure. However, funds cannot be delivered until the school has received an official EFC from the CPS. If you have received the official EFC but need to correct or adjust the student's information, you may pay the student campus-based, Direct Loan, or FFEL funds based on your EFC recalculation. Or, you may obtain a new official EFC from the CPS by making changes through EDE or by having the student submit a corrected SAR.
The school is liable for any recalculation errors that result from using an EFC that the school or a third-party need analysis servicer calculates. The Department does not certify the accuracy of the calculations need analysis servicers perform. The Need Analysis System (NAS) program calculates the same EFC as the CPS; however, the student's information must be processed by the CPS at least once, because NAS cannot perform the eligibility matches.
To receive the 1998-99 NAS specifications, all interested need analysis servicers must enter into an agreement with the Department and comply with the procedures set forth in that agreement. New servicers must complete and sign the agreement in order to receive the NAS specifications, which are sent automatically to current NAS servicers.
Under the Federal Pell Grant Program regulations, schools are not allowed to make a first disbursement of a Pell Grant without a valid ISIR. However, you may still make an interim disbursement to a student who is selected for verification (including a student selected for verification by the school rather than the CPS). See the 1998-99 version of The Verification Guide for more information.
Signature Requirements (Federal Pell Grant)
Previously, for an ISIR to be valid, the student was required to sign a statement certifying the data's accuracy. This is no longer a requirement. In other words, once the student has signed the FAFSA, he or she doesn't have to sign other documentation in order to receive a Pell Grant-unless a correction or verification is required.
If a line item on a paper SAR is corrected, the student and at least one parent (for a dependent student) must sign Part 2 of the SAR before it is returned to the CPS. If an FAA has adjusted a SAR line item (or several), the adjustment(s) can be processed without the signatures of the student and parent. For corrections received through EDE, the school must have signed documentation from the student and parent: the correction on Part 2 of the SAR, a signed copy of the correction sent to the CPS, or signed verification documentation. The school must collect this documentation before sending data to the CPS.
Remember, if a student files through EDE at your school, you must keep on file the student's signature (on a completed paper application or on the "echo document" printed from EDE) even if the student does not receive federal student aid or does not attend your institution.
The Statement of Educational Purpose and the Certification Statement on Overpayments and Defaults are on the FAFSA, not the SAR or ISIR. The school is not required to collect or keep a separate copy of these statements.