Schools Reporting Unusually Large Batches of Reprocessed UEH-Flagged ISIRs
By Megan Walter, Senior Policy Analyst
Over the past two weeks, NASFAA members have reported receiving unusually large batches of reprocessed Institutional Student Information Records (ISIRs) carrying Unusual Enrollment History (UEH) flags, spanning both the 2025-26 and 2026-27 award years. According to member reports, these numbers are well beyond what they typically see in reprocessed transaction batches, with flagged transactions totaling anywhere from several dozen to over 1,000 across the two aid years.
A UEH flag on a reprocessed ISIR requires an institution to evaluate whether a student’s enrollment history appears legitimate before future Title IV aid disbursements can be made. Students whose applications have been flagged may be required to provide documentation to the institution, such as transcripts and enrollment and financial aid records, substantiating their enrollment history.
The school’s actions depend on whether Title IV aid has already been disbursed, regardless of the award year the UEH flag appears on the ISIR. If all aid was disbursed before the flag appeared, the school is not required to take any additional action for that year to resolve the flag. If aid has not been disbursed or has been disbursed only partially, the school must resolve the flag before making any further Title IV disbursements. According to guidance NASFAA has received from the U.S. Department of Education, if the student was eligible at the time the initial ISIR was processed and Title IV disbursements were made, neither the school nor the student needs to return any prior Title IV disbursements.
If the student had a UEH flag on a 2025-26 ISIR and is still enrolled at the institution for the 2026-27 award year without a flagged ISIR, the school may choose to review the student's academic history given the unresolved prior-year flag, but that review is discretionary, not required.
NASFAA reached out to ED after members first flagged the issue, and it has confirmed it is looking into the matter, but has not yet identified a cause or timeline for resolution as of the publication date of this article.
We will update via Today’s News when we receive a response from ED.
Publication Date: 9/23/2026
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