Government Shutdown May Impact Some FAFSA Database Matches

By Megan Walter, NASFAA Policy & Federal Relations staff

While the Department of Education (ED) is fully funded for the 2019 fiscal year (FY)—award year (AY) 2019-20—the partial government shutdown may still cause issues for the processing of AY 2018-19 and 2019-20 FAFSAs that require certain database matches.

Institutions have reported to NASFAA receiving Comment Code 390, denoting “one or more federal agency matches were not performed” on some processed Institutional Student Information Records (ISIR) on or after December 22 for both the 2018-19 and 2019-20 AY for applicants who would be subject to a Selective Service Match. While it was initially unclear whether this issue is isolated to applicants attempting to register for Selective Service through the FAFSA, feedback indicates that the issue is also impacting applicants who are already registered. Applicants who already had a successful match on a prior transaction do not appear to be affected by this issue.

In addition to the Selective Service System (SSS) match, the Department of Homeland Security (DHS) has a FAFSA database match to verify eligible non-citizen status, and the Department of Justice (DOJ) has a database match to identify applicants who are ineligible to receive Title IV funds due to certain drug convictions. Each agency has posted informational memos stating that their websites will not be actively managed during the shutdown, information on their websites may not be up to date, and transactions submitted through their websites may not be processed. It is not clear at this time the extent of the impact of the shutdown on FAFSA database matches through these agencies.

NASFAA has reached out to ED about the extent of the issues regarding database matches and inquired how any impacted ISIRs will be resolved.

ED, the Social Security Administration, the Department of Defense, and the Department of Veterans Affairs are fully funded for FY 2019—AY 2019-20—and remain unaffected by the government shutdown. All operations related to these offices, including FAFSA database match activities, should continue without issue.

The new 116th Congress convenes today and negotiations regarding the shutdown are expected to begin immediately.

NASFAA is continuing to monitor the issue and welcomes feedback from members regarding database match anomalies. Please send any feedback, comments, or questions to


Publication Date: 1/3/2019

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Post a your reply

Wilson M | 1/8/2019 8:0:43 PM

The US Dept. Of Education new that the shutdown was going to occur. We need guidance now rather than later! Students, and parents, at my institution, are agitated and frustrated an we are receiving the brunt of their wrath!
We need immediate guidance.

Anita K | 1/7/2019 2:3:10 PM

Happy New Year? Yes, relief on our ability to accept tax return for verification purposes will be helpful for 18/19 and 19/20. Starting our spring term with several hundred mid-year transfers in "limbo" is not fun for any of us. Thank you NASFAA for your continued advocacy efforts.

Aesha E | 1/3/2019 1:10:35 PM

MTE, David... though it may be moot if schools are trying to process ISIRs for students for this year/spring semester. Since we haven't yet received the guidance and ED was not forthcoming about the aid year to which the guidance would pertain, I am also hoping that ED will take the shutdown into consideration with regards to the ease on verification documentation. With the IRS essentially unavailable at this point, and until who knows when, if students are still required to provide transcripts for AY20 verification, that could be a mess.

David S | 1/3/2019 10:26:24 AM

Sure hope our friends at ED plan to re-run all 390 codes through the whole database match gauntlet again once we have a federal government up and running. In other words, please don't make fixing this the students' and schools' headache.

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