PPY Implementation Task Force Offers Hints and Tips for Resolving Comment 399-Flagged ISIRs

The PPY Implementation Task Force understands that resolving the 399 code indicating conflicting information between award years 2016-17 and 2017-18 is confusing and wants to draw your attention to the flowchart in the PPY Toolkit that indicates you only need to resolve conflicting cross-year information for ISIRs flagged with the 399 comment code if:

  • Your school received an ISIR for the student in both 2016-17 and 2017-18;
  • You have disbursed or will disburse federal aid in either of those award years; and
  • The student is or will be an undergraduate in EITHER of the years.  

This and other guidance was provided in an Electronic Announcement dated October 21, 2016.

The fields that must be resolved are the tax and income-related fields detailed below and are also included in Dear Colleague Letter GEN-16-14:

FAFSA Question Number(s) for
Student/Spouse/ Parents

FAFSA Question

Question 32 Tax return status (already completed, will file, not going to file)
Question 80
Question 33 Type of tax return (1040, 1040A, 1040EZ, foreign return, Puerto Rico or other U.S. territory return)
Question 81
Question 34 Tax filing status (single, head of household, married filing jointly, married filing separately, qualifying widow, don’t know)
Question 82
Question 35 Eligible to file a 1040A or 1040EZ?
Question 83
Question 36 Adjusted gross income
Question 85
Question 37 U.S. taxes paid
Question 86
Question 38 Number of exemptions claimed
Question 87
Question 39 Income earned from work – Student
Question 40 Income earned from work – Spouse
Question 88 Income earned from work – Parent 1
Question 89 Income earned from work – Parent 2
Question 44 Exclusions from income
Question 93
Question 45 Untaxed income
Question 94

PPY Implementation Task Force hints and tips for resolving 399 codes:

  • The Department of Education (ED) reprocessed over 7,500 ISIRs for incorrect 399 codes in October. Check that you do not have a subsequent 2017-18 ISIR without a 399 code before working to resolve 399 codes.
  • Some ISIRs contain codes 395-398. These may provide a hint of where the conflict in information resides, but in themselves do not require resolution and may not represent the only conflicting information present on the ISIR. These codes are for informational purposes only.
  • Sometimes the conflict is in Untaxed Income (questions 45/94) which is not part of the IRS Data Retrieval Tool (IRS-DRT). This can be easy to overlook but still requires resolution.
  • ED has indicated they may have flagged some ISIRs with 399 codes even when a PJ was performed.  In this case, we recommend you confirm that the source of the conflict results from the PJ and document that you reviewed. ED has indicated they have not excluded graduate students from the selection criteria that assign comment code 399. If a student is at the graduate level for both 2016-17 and 2017-18 and did not and will not receive Federal Work-Study in 2016-17 or 2017-18, no resolution is required.
  • In some cases, you will need to correct information on the 2017-18 ISIR.  If this is corrected, the 399 code and C flag should not appear on the subsequent, corrected ISIR record.
  • In some cases, you will need to correct information on the 2016-17 ISIR. If this is corrected, the 399 and C code will continue to appear on the 2017-18 ISIR. Normal awarding and disbursing for 2017-18 can proceed with the C code in place once your school has resolved the conflict.
  • Remember, if you have verified the conflicting information item(s), or the student or parent used the IRS DRT (and made no subsequent changes), you may assume that the verified or IRS DRT transferred values are correct and use those figures to correct the other year’s information.
  • Once you receive and load a 2017-18 ISIR with a 399 code you should not disburse any subsequent Title IV aid until you have resolved the conflict or documented the code is in error.  Also any students who are currently receiving Federal Work-Study should stop earning until the conflict is resolved. If you are unable to load 2017-18 ISIRs there is no need to hold 2016-17 aid, but schools are expected to load these ISIRs as soon as they are able.

Remember, this is just a one-year process that will not be repeated. The original webinar on the 399 code and resolving conflicting information along with the flowchart and Q&A from the webinar are available on the PPY toolkit. Also, ED’s Early FAFSA FAQ contains useful information for resolving comment code 399.


Publication Date: 12/1/2016

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