The U.S, Department of Education announced on July 18, 2014 that close to 200,000 Institutional Student Information Records (ISIRs) will be reprocessed the evening of Monday, July 21, 2014. The cause for the reprocessing is due to the fact that at least that many applicants for Federal Student Aid (FSA) incorrectly entered data on their Free Application for Federal Student Aid (FAFSA) when completing the FAFSA-on-the-Web. The errors have the potential to significantly impact those students’ eligibility for aid such as the Federal Pell Grant, as well as other types of FSA programs such as Federal Direct Subsidized Student Loans (Direct Loans) and Federal Supplemental Educational Opportunity Grants (FSEOG), etc.
The ISIR Issue
The issue arises from applicants that incorrectly entered income earned from work and adjusted gross income (AGI) figures with a decimal point. The instructions for completing those fields tell the individuals to not include decimals and the cents following a decimal; the amounts to be entered are to be rounded to the nearest dollar. The fields displayed the numbers such that the “.00” was already showing, as seen below. Therefore, the applicant was to only enter the correct, rounded, whole dollar amount.
However, close to 200,000 applicants entered the actual dollars and cents amounts that were applicable to their income data. For example, a $10,250.48 figure entered with the decimal point and cents would be read by the system to be an amount of $1,025,048 instead of the $10,250 amount that should have been displayed and used.
Naturally, such a discrepancy would have significant impact on a student’s calculated Expected Family Contribution (EFC), and as a result, the student’s overall eligibility for assistance.
ED has enhanced the system for FAFSA-on-the-Web to help eliminate this kind of error occurring in the future. The system will now require all entries to be right-justified as the numbers are entered in the fields for a particular response. Thus, as the numbers are being entered, they will automatically populate next to the pre-entered decimal point. Also, if an applicant does enter a number with a decimal, the decimal and following numbers will automatically be dropped.
New ISIRs Being Processed
The new ISIRs ED is generating on July 21, 2014 for the affected applicants will have a new ISIR comment code. The code is Comment Code 023. The comment will read:
This SAR was produced because an analysis we conducted on the information you reported on your application indicates you may have made an error which could affect your eligibility for federal student aid. Review all financial fields and make any necessary corrections.
For those individuals that import the ISIRs for their schools, they should be aware that these new ISIRs will be sent under the message class IGSG15OP and will have “02” as the Reprocessed Reason Code. The Reprocessed Reason Code shows in field #230 on the ISIR. This code will also display on the FAA Information page in the Student Inquiry on the FAA Access to CPS Online Web site. In September, in addition to the code displaying on that page, the following description will be added: “02 – Reprocessed due to Income from Work query result”.
ED anticipates that each school will have very few of these ISIRs that were affected and that are being reprocessed. The estimate is that most schools will have less than 10 ISIRs impacted by this issue, but the number will vary depending upon the number of applicants a particular school processes. The more FAFSA applicants a school has, the greater likelihood they may have students affected by this issue.
Impact on Schools
Since the effect of the incorrect data entries likely impacted the calculation of the applicants’ EFC, schools are required to review the data entered. At a minimum, schools must review the applicant’s (and parent’s or spouse’s, as applicable) AGI and Income Earned From Work fields to determine the accuracy of data reported and make corrections as necessary. When reviewing the ISIRs, entries in other financial data fields should also be reviewed (taxes paid, assets, etc.).
ED indicates that a school may conduct the necessary review by using data already on file (e.g., tax return transcripts), or the school may have to actually contact the applicant to obtain confirmation of the data reported or documentation that may be used to make a necessary correction. ED specifies that, for these purposes only, “it is acceptable for the institution to use as documentation a notation of a phone call or an e-mail from the applicant or parent, as appropriate.” [It should be noted that this confirmation of data on these ISIRs is not the same as the traditional “verification” process used when a student is routinely selected for verification by ED’s Central Processing System (CPS). However, a school is not prevented from selecting these (or any other students) for verification in accordance with its written verification policies even though they may not have been selected for verification by the CPS. And, if a student has otherwise been selected for verification by the CPS, the regular verification process should also be employed.]
The review of these new ISIRs must be completed before any subsidized Title IV aid is disbursed for the 2014-2015 award year. If there is an instance where aid has already been disbursed for 2014-2015, the institution may have to revise the award(s) and ensure any overawarded aid is appropriately returned.
The details of this issue are more fully described in ED’s Electronic Announcement dated July 18, 2014. FAME clients may submit any questions regarding this issue through the Client Solution Center.