Carrie S | 1/9/2017 8:43:02 AM

I, too, echo the sentiments of my colleagues above. I also harbor resentment, as I think of all the other things I could be doing if I didn't have to resolve 399s. I'm irked that PJs have the code when we were told they wouldn't. I'm further irked that ED won't fix it until February (too little, too late in my opinion). I don't appreciate resolved 399s being selected for verification, nor do I appreciate the fact that some of my 399s are because there are blanks in one year where there are zeroes in the other. If that truly was an issue, don't allow students to submit FAFSAs with blanks!!! Make them put in zeroes. This has been a complete time suck, let alone the impression our students must have of us. We truly feel like the bad guys here. Falling back on "it's a federal requirement" does not make anyone feel better. This is a mess.

That being said... it's necessary. I've seen SO many mistakes that it makes my stomach churn. I just wish it was better executed. I'm the only one in my office reviewing these, and it is quite the burden. It's so complex that it's not worth the risk of having others participate - then they wouldn't be able to do their work. This is all I do, though. Day in, day out.

Tina K | 1/6/2017 3:58:14 PM

What has frustrated me, beyond what has already been stated about untaxed income triggering this code, is that there is no flexibility for student that have federal work study. To tell a student who had child support reported wrong or missed the tax deferred pension payments of their parents on their 17-18 FAFSA that they can no longer work mid-term until we can resolve the conflict is in my opinion ridiculous. It would have been nice to have had a week or two time frame to resolve the 399 code before ending work study. Yes, most students get the information in within a day or two but talk about unneeded additional stress on the students.

Karen G | 1/6/2017 9:32:09 AM

The largest variance have been on students who were verified in 1617 and the "additional income" items have been added. Then for 1718 they are not selected and are missing the "additional items" - it significantly changes their eligibility. It is a TOTAL pain, but so far, each one touched has had their eligibility change.

Anna J | 1/5/2017 6:56:56 PM

This has been a nightmare for me. I started doing the 399 conflicts in early October and have several students that lost their aid for Winter quarter, owe repayment and essentially have lost the ability to go to school. I have scrambled to save the students I can, even performed "Change of Income" requests when feasible. The most problems I have been seeing is Grants/Scholarships reported in the AGI. One student's documentation was almost right, but she misunderstood what the 1098-T was for and thought she was supposed to report her financial aid as listed on the 1098-T. Since the file was not selected for verification in 1617- she owed a huge repayment. She tried and really thought she did it right. I felt horrible. This rule is horrible and was not thought through. It's a total waste of my time and making me feel like a debt collector instead of a financial aid officer. I resent the DOE for this.

Beth J | 1/5/2017 6:44:11 PM

We have found this process to be a burden not just for the office staff, but for others on campus as well as the students. When you send a letter out that tells the student there is something wrong or not quite right with the information they have submitted on their FAFSA and that you have to stop their financial aid or may even have to alter their financial aid, the students have a hard time digesting this information. They are 4 months into a semester and are fairly confident they have their finances for school in order and then you all of the sudden pull the rug out from under them. I had one student in complete tears and so distraught because she is already strapped for cash and is scraping everything she has to cover all of her educational expenses (not just direct costs - we are talking about living while attending college).

Now, let's talk about the student who doesn't fill out their FAFSA until April 2017. Now you have the fall semester finished and most of the spring semester. They are flagged for 399. Let's say we fix the differences/discrepancies and now we have to remove aid because the discrepancies cause the EFC to go up and the Pell to be reduced. Now they owe for two semesters and can't register for the upcoming semester because they have a balance with the school, Or, if the school doesn't return the funding and reports them as an overaward, now the student can't get aid until they've reconciled the overaward. Either way the student cannot return. Again, you are talking about a student who is Pell eligible, they don't have that kind of funding at a moments notice.

I just feel early FAFSA filing should have been thought through a little more than it was before it was implemented. Luckily (or at least I hope) this will be the only year we have to do this.

Thank you for the opportunity to express comments, I do apologize for what seems like a rant.

Paul N | 1/5/2017 6:15:55 PM

The 399 conflict code is an unnecessary burden in my opinion. Of the students with the conflict code, all have been resolved. The most common corrections were to the tax deferred pension item being left off the 2017-2018 FAFSA. We require W-2s anyway from all parents/students resulting in an easy fix. Seeing the code because Parent 1 and Parent 2 income from working is switched, but otherwise identical to the previous year is especially bothersome.

Peter G | 1/5/2017 5:53:59 PM

Like David described, it was very surprising to be in the position of reviewing files of students who were enrolled in graduate study in both years.

We also had 1718 flags for students for whom we have no 1617 application, so are in the position of not being able to resolve it and just having it hanging until we can rule out that they won't apply/attend in 1617.

While sympathetic to the Department's general position, I'd rate the implementation generally negative.

Holly M | 1/5/2017 5:47:58 PM

Out of the 50 or so that we've come across, it's only made a difference for one. Many were graduate students. The few that are the most frustrating to see are the students who didn't report $50 of FWS, or said "yes" to the eligibility for A/EZ question on one FAFSA, but "don't know" which didn't impact their final EFC. ED is trying to ensure their data (background calcs and formulas) are correct, which I appreciate. I would want the same. It's just unfortunate that the end result has been very frustrating for students and parents.

Roseann A | 1/5/2017 3:27:19 PM

This has become a pretty large burden on both my staff and the students affected. Often it appears that there is no reason for the 399 code - the last one was just a change in the number in college - all income figures were the same including Untaxed and the income split, and there were no needs-test benefits received on either application. It's time to stop all of the unnecessary additional requirements that continue to be placed on the schools - as of yet we do not have Any students who were found to be ineligible for the aid they received, so I can't imagine that there is any real benefit to the taxpayer since it's costing us much more to administer than we're recapturing from any "incorrect" applications. I agree that before any new requirement is added to an already insanely burdensome process, its impact should be evaluated and scrapped if it turns out to be of minimal benefit and highly work intensive. Not to mention the confusion it causes with everyone, especially students. Speaking of confusion - is anyone else having a lot of incoming Spring students completing the wrong year FAFSA, thinking that they need the 17/18 instead of 16/17, now that it's available so early? We are and it's causing issues since they don't discover it until it's too late and tuition for This year is due and we have nothing to defer against....

Russell J | 1/5/2017 3:26:54 PM

Good question, NASFAA. I will try to be brief:

1) I applaud ED in working, as much as they could foresee, to minimize this issue. Schools are required to resolve conflicting information and ED worked to minimize this for institutions through the use of DRT for both years, Pre FOTW submission warnings, and ED identification of #399.

We are a private institution with approximately 3300 UG and 350 GR students. We have seen approximately 2-3% of students flagged and from communicating with colleagues, this seems to be, for the most part, across the board. While our numbers are thus, not high (my heart goes out to institutions with 15,000+ students and two year schools), the amount of time it takes to compare both years is indeed high and creates much work.

ED had noted that a CPS review would not be performed if the student is not expected to be Pell Grant eligible, however, many of us across the country have seen EFC's up to 6,000 being flagged ... this is not what was communicated to us on multiple occasions. We all have examples of where PJ was performed (especially in 16-17) and submitted to CPS (with the appropriate flag) but is still coming back selected (I understand this should be resolved in February). The non-taxable items (q45 and q94 range), which do not show on the DRT, is what is causing virtually all of the ISIR's being flagged. We are fortunate in that we do not have a high number of 16-17 ISIR's being flagged but the PR side of this, for the FA Office, is not welcome. It creates mistrust on the part of the family and positions offices in the defensive.

All in all, I will be thankful when this is over ... is ED perfect? No. There refusal to define "significant" change in EFC only creates mistrust. However, they have worked diligently to assist us and work with us as issues arise.

Respectfully submitted ...

Teresa J | 1/5/2017 3:21:59 PM

They're going to reprocess those that had PJ in 2016-17 and those with no Pell eligibility change in 2018, in February.

David S | 1/5/2017 12:27:25 PM

I recall hearing ED tell attendees at not one but two different conferences that they would review potential 399 discrepancies and only flag those for whom it would make a difference. I would love to have that presenter explain to me why we are seeing 399's for graduate students whose entire aid package consists of an unsubsidized loan and a Grad PLUS. If the EFC changed from 0 to 150,000, there would be no change to the package whatsoever.

There is a discrepancy between the information we were first given and what we later received. ED, please resolve this conflicting information, as you so often remind us we must.

Tracy H | 1/5/2017 11:44:21 AM

The burden for us has been trying to explain to students what the conflict means and why we're needing to resolve it mid-year. For some students it's been positive that has resulted in more Pell. For a few (not very many) it has been extremely difficult if they're no longer eligible for Pell or other need-based awards, and now they owe our institution a significant amount of money, and face the decision about whether or not to leave school.

Another frustration is not understanding why some still have 399 codes. We still have several graduate students flagged for 399. We are clearing the 399, but selecting them in 1718 if there are significant income differences...mostly for our institutional graduate aid that is based on need. We also have students that are flagged and everything seems to match except for snapshot data (household and assets), which has caused an impact to their EFC. This seems WRONG, since snapshot data CAN change from year to year. Try explaining that to a family!

I echo others comments about how the 399 selection process wasn't evaluated enough or tested thoroughly enough to detect bugs or unintended outcomes.

Karri M | 1/5/2017 11:29:51 AM

We honestly don't have many cases at this point. We run a report to identify all students with SAR C Codes, and then I go through to check which ones are 399s. At this point, we have less than 10 (between the ~1400 current students we have and the prospective students as well). A lot of the time, the information that is different between the 16-17 and 17-18 FAFSA is related to untaxed income (child support received, clergy/military benefits, etc.). It seems parents may be confused about prior-prior and don't realize that they need to be reporting untaxed income from 2015 as well. I haven't noticed that students are getting selected after submitting 2017-18 corrections (which is often what I'm doing), but I have noticed that the bulk of our 399 students were selected for V1 verification in 16-17, which doesn't require us to verify the untaxed income (beyond Child Support Paid and whether they received SNAP). And the majority of the students with 399 codes used the DRT in one or both years.

James C | 1/5/2017 10:27:26 AM

I would like to echo many of the criticisms listed in the comments here. My two big issues are the lack of guidance from the feds on how to resolve PPYCON due to the many different can of worms it opens up AND also the many people who are either selected for PPYCON who shouldn't be and the people selected for a verification after a PPYCON has been resolved. Not cool. I criticize the feds for not thinking through all the ramifications of PPYCON before they decided to create it. It creates an undue burden on both students and FA administrators. But this is typical of the feds. They keep creating new regulations that create an undue burden. The two questions the feds should be asking when they create new regulations is "Is this creating an undue burden?" AND "Is this making the financial aid process more complicated?" If the answer is "yes" to either question, it needs to be shelved and reconsidered. It seems each year, the feds come up with new regulations that create an undue burden. Simplifying the process is something the feds have yet to learn.

Kathleen B | 1/5/2017 10:1:52 AM

Because we award a large amount of institutional aid we self select a large number of first year students for verification. Consequently the majority of 399 codes we are seeing are for students that we verified in 1617 who did not report all of their untaxed income on the 1718 FAFSA. We have a report that identifies these students and we are correcting their 1718 FAFSAs. This process is very time-consuming, but when we begin packaging it will be nice to know their 1718 FAFSAs are accurate.

We have had a very small number of students with the 399 code because the students used data retrieval in 1718 but not in 1617. When we have corrected the 1617 FAFSAs for these students the new 1617 ISIRs have NOT come back selected for verification.

Overall we're noticing a lot less students selected for verification by CPS in 1718, so that's a positive!

Stephen S | 1/5/2017 9:57:04 AM

It is difficult to understand why these processes are not thought through better to minimize the burden on students. Additionally, the extra burden on under-staffed FA offices is already high and this just exacerbates it. It is frustrating that processes like the 399 codes make FA offices look like we are unorganized. Service to and trust from students is critical. We need the Department to make that a priority in addition to all of the other safekeeping duties they have. They have a tough job but we are their front line.

Tyler B | 1/5/2017 9:53:33 AM

I have seen much of what has already been mentioned. We also continue to see 399 codes on 1718 records where the 1617 record was a PJ case- therefore they should not have the 399 code. As a traditional age student type of college we are not seeing many changes in awards in 1617 due to students who said non-filer but actually did file and said 'filed' in 1718.

We are seeing a lot of files where there are no differences in data submitted, only EFC differences, or where maybe a federal program question changed (i.e., food stamps, etc.)
I agree the behind the scenes algorithm they are using to select the cases to have the 399 code still needs a lot of work. It will only get worse when more renewal students start doing FAFSAs in February which is their traditional time for starting the next year's financial aid process.

Annamarie G | 1/5/2017 9:41:46 AM

I am handling the 399 conflicts for our office and a lot of what I am seeing is students who did the DRT for both years but the EFC is slightly higher in 17-18 like maybe $60 and they are hit with the 399 code. so I am wasting time comparing ISIRs when nothing needs to be changed.

I am also seeing students selected with the 399 with non DRT items....it is very time consuming and honestly this was not completely thought through before implements. It is very frustrating on both sides.

I am glad this is only for one year but it is going to be a VERY LONG year!

Eric A | 1/5/2017 9:21:13 AM

Most corrections are due to non-DRT items, such as untaxed income. Had the department followed through with using 399 codes on non-verified, non-PJ situations, it would have been much more manageable. It hasn't been as cumbersome as I imagined, but still very time consuming and glad it is only one year. This fall has been SIGNIFICANTLY busier due to PPY...that was the bigger mistake starting in October. Using PPY with a Jan. 1 start would have made a lot more sense.

Melissa G | 1/5/2017 9:18:36 AM

We're just automatically selecting them for verification for both years (if not already chosen/completed). We already have a good process in place for verification and keeping track of them so it seemed like the easiest route for us.

Shannon G | 1/5/2017 8:52:45 AM

I just wanted to chime in regarding what others are saying about verification. After we clear the 399, 1617 ISIRs are coming back for verification. Besides having to contact the student again, it makes it look like our office neglected to collect all the necessary information the first time, which isn't true. This causes students and their families to become frustrated with the process.

Thomas P | 1/5/2017 8:51:46 AM

This seems to bee a poorly thought out process that puts an extra burden on already overworked financial aid offices. I've seen so many child support paid cases where the amount was left out...it is ridiculous. Maybe this should have waited a year to be implemented.

Christen N | 1/5/2017 8:37:59 AM

Same here. Corrections being made to resolve the conflicting information are resulting in the student being selected for verification. Not cool. Dept can see that the school made the correction, one would think they would somehow exclude them from verification.

We are using reports to resolve our 399s. We find them by report, then run a second report that compares the required data elements between the 2 aid years and displays a "change flag" next to the discrepant information.

Michael C | 1/5/2017 8:27:18 AM

We find that in the cases where the family used IRS DRT for 1718, when we make the changes to 1617, the 1617 ISIR is selected for verification. This requires another contact with the student.