ED Provides Safe Harbors and Additional Details on How to Document and Package, for Certain ISIR Errors

By Hugh T. Ferguson, NASFAA Senior Staff Reporter

In its latest electronic announcement the Department of Education (ED) reiterated that it will reprocess all Institutional Student Information Records (ISIRs) impacted by recent errors, and also includes further instructions on how to meet professional judgment and compliance requirements if a school elects to award on an original ISIR with a lower SAI rather than a reprocessed ISIR. 

The announcement  provided three conditions, that must all be met, for institutions to use their judgment to rely on the original ISIR sent—not the reprocessed record—to send out aid offers. The original ISIR must:

  •   Be “based on a 2024-25 FAFSA form and is the basis for aid offered and disbursed during the 2024-25 award year.”

  •   Result in “greater financial aid eligibility for students ,” meaning it has a lower SAI. However, if a reprocessed ISIR results in greater financial aid then schools can only make estimated offers and will need to use the reprocessed record when determining final offers and disbursing funds.

  •    Be subject to reprocessing due to one of nine specific errors, documented in guidance from April 10 and outlined in this most recent announcement. 

If an institution chooses to award on the original ISIR that has a lower SAI then according to ED the case-by-case requirement outlined by professional judgment has been met.

The guidance also provided details on how schools should approach this use of professional judgment, and how to ensure compliance. Institutions must document and maintain a record, in the student file, detailing how it determined aid eligibility, including the original 2024-25 ISIR and the reprocessed record demonstrating the lower amount of aid eligibility.

“When considering an institution’s compliance with Title IV, HEA requirements related to the packaging or processing of Federal student aid, the department will make its assessments in light of these instructions and the unique circumstances in which institutions are being asked to make judgments about correct award amounts of Title IV, HEA funds,” the notice reads. 

ED specifically states that following the instructions in this announcement will not, in and of itself, create compliance concerns, nor will an institution’s decisions on packaging as described in this announcement on their own, lead the department to initiate a program review.


Publication Date: 4/12/2024

Katherine A | 4/12/2024 3:24:35 PM

We are going to wait for the corrected ISIRs. There is no way we would risk using bad info, because we do not know how much of a swing we'll see from the old SAI to the new SAI.

James C | 4/12/2024 11:15:25 AM

This contradicts the letter the Secretary sent out that said we can award aid "based on the information we have now." Congress should allocate emergency funds for the 2024-25 aid year to give to families with high and moderate need to compensate for the FAFSA fiasco.

Stephani B | 4/12/2024 11:10:13 AM

No, we are waiting for corrections to be made by FSA/ED and wait for new transaction to come in.

Joshua M | 4/12/2024 10:55:42 AM

is anyone going to award on these incorrect ISIRS?

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