UPDATE: ED Explains Large Batches of Reprocessed UEH-Flagged ISIRs
By Megan Walter, Senior Policy Analyst
As highlighted last week, NASFAA members reported receiving unusually large batches of reprocessed Institutional Student Information Records (ISIRs) with Unusual Enrollment History (UEH) flags, spanning both the 2025-26 and 2026-27 award years.
In an email posted to the FSATech Listserv Friday afternoon, Federal Student Aid (FSA) explained that the UEH code had been disabled from late June until September 13, and that reenabling it generated a ‘catch-up’ batch of flagged ISIRs covering that timeframe. FSA said that the UEH code is now working correctly.
FSA’s message reminds schools that under 34 CFR 668.19, they must review a student’s National Student Loan Data System (NSLDS) information prior to disbursement. Schools are not required to check for changes to that data after receiving it, but a school that learns a student was not or is no longer eligible must stop disbursing Title IV funds and help the student arrange repayment of any aid for which they were ineligible. If the student has any pending disbursements for the award year, the school must resolve the UEH flag before making further disbursements. If a UEH flag is added to a student's record after all aid for the award year has been disbursed, the school is not obligated to complete a UEH review.
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Publication Date: 9/28/2026
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