Updated: ED to Reprocess All Affected ISIRs Due to Partial Government Shutdown

Editor's Note: This article, originally published at 8:00 a.m on 1/9/2019, was updated at 4:15 p.m. on 1/9/2019 to reflect new information provided in an Electronic Announcement published mid-day on 1/9/2019.

By Megan Walter, Policy & Federal Relations Staff

As reported in Today’s News last week, the partial government shutdown is causing issues for the processing of FAFSAs for award years 2018-19 and 2019-20 that require the Selective Service database match, and has caused multiple institutions to experience a spike of comment code 390 on processed Institutional Student Information Records (ISIR). The Department of Education (ED) has notified NASFAA that it is aware of the issue, and that at the first opportunity after restoration of the database match, which won’t be until after the shutdown ends, ED plans to reprocess all affected ISIRs.

In the interim, until affected ISIRs are reprocessed, if a school has reason to believe that an applicant who was required to register for Selective Service has not done so, the school can check a student’s Selective Service status:

  • By going to the SSS website at https://www.sss.gov/Registration-Info (this will require the applicant’s last name, Social Security Number and date of birth); or

  • By requesting the student’s SSS registration card as evidence.

A printout of the web page showing registration or a copy of the SSS registration card is acceptable documentation that the student is registered.

Note that if a school does not have reason to believe that an applicant who was required to register for Selective Service has not done so, the school is not required to document registration through one of these alternative methods before continuing to process and/or disburse Title IV aid, but may choose to do so.

As another option, the school may choose to do nothing, and instead wait until the Selective Service match is conducted to continue aid processing. Schools may make different choices for individual students or groups of students.


Publication Date: 1/9/2019

Megan W | 1/10/2019 4:47:04 PM

Rita B -
We received an email from FSATech Customer Service that stated "The Selective Service Match is the only match not currently taking place; all other matches are currently taking place, despite the partial government shutdown. These external agency matches are with:

-The Social Security Administration
-The Department of Veterans Affairs
-The Department of Homeland Security
-The Department of Defense; and
-The Department of Justice

Once the partial shutdown is resolved FSA will inform the community and the bypassed records will be reprocessed. Please watch the Information for Financial Aid Professionals website for this update."

We will provide more information in Today's News as we learn more.
-Megan Walter, NASFAA Policy Analyst

Rita B | 1/10/2019 9:46:01 AM

NASFAA, could you please seek clarification on the points above regarding other database matches that are not being completed? This notification does not seem to address whether or not ISIRs missing those matches will be reprocessed or not. Thank you!

Kathryn C | 1/10/2019 9:8:32 AM

Aesha, I completely agree! DHS is also not conducting matches and I am not comfortable pushing someone through without that. If it were just Selective Service, it would be one thing. But it's multiple agencies. Where's the guidance on that?

Aesha E | 1/9/2019 11:22:12 AM

From the anecdotes I've seen it seems many schools think it's a selective service match that may be the cause of the 390 code, but short of a PMessage indicating that it's solely related to SS, and without an EA posted to the IFAP site specifying the precise nature of the code, offices still would need to figure out what agency match(es) did not take place. 390 itself does not state this, and says to see the PMessage or IFAP. So while ED should absolutely be reprocessing these ISIRs as immediately as possible, that is cold comfort for students and schools.

I don't know whether the folks at ED didn't think to inquire about continued operation of these systems during the shutdown, whether they were mislead, or chose not to share it with the aid community... but something really broke down here.

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