On April 12, 2016, the Department of Education (ED) posted 9 Q&As to the Early FAFSA Information page. This first set of Early FAFSA Frequently Asked Questions (FAQs) will be augmented as new issues arise. The financial aid community may ask additional questions through ED’s "Early FAFSA" mailbox at firstname.lastname@example.org.
The Q&As reiterate that the base year for calculating family contributions for Title IV purposes will move back from the prior year to the prior-prior year (2015 for the 2017-18 award year, rather than 2016), and that this change is not optional unless an aid administrator determines, under professional judgment, that unusual documented circumstances for a particular applicant warrants use of some other 12-month period.
A major goal of the move to prior-prior year is to allow families more time to make decisions about selecting and financing college, hence the availability of the FAFSA by October 1 rather than January 1. Schools have been encouraged to send out financial aid award letters correspondingly earlier as well. The 4/12/16 Q&As address various timing issues related to this intent.
The good news is that need analysis tables for 2017-2018 EFC calculations will be available earlier than in the past, and the IRS Data Retrieval Tool (IRS/DRT) will be available when the 2017-2018 FAFSA processing begins on October 1. The IRS has assured ED that they will be prepared to respond to IRS tax return transcript requests on and after October 1, 2016.
The bad news is that Pell Grant award and disbursement schedules and institutional campus-based allocations are dependent on Congressional action, and ED does not anticipate that action will occur earlier than usual.
Further, the Common Origination and Disbursement (COD) system functionality for 2017-2018 award originations will not be available until March 2017. However, on both of these issues NASFAA will be working with Congress and ED to find solutions to get schedules better aligned with the new FAFSA timing.
The Q&As also address a couple of issues related only to the transition year 2017-18. This year is unique in that the same base year, 2015, will be used for it that was used for the year before (2016-17). ED has decided not to use 2016-17 data to prepopulate 2017-18 applications, because of the potential for changes in applicant circumstances (dependency status, marital status, etc.). However, in an effort to reduce burden, ED will perform a review to determine whether conflicts between 2016-17 applications and 2017-18 applications could have a significant impact on the student’s 2017-2018 EFC. Only those applications with a potential for significant impact will be flagged for institutional resolution.
As a result of that centralized review, institutions will not have to compare 2016-17 and 2017-2018 ISIRs to determine if there might be conflicting information regarding 2015 data. A Dear Colleague Letter is being prepared for release later this spring that will provide additional information on this subject. In the meantime, ED continues to encourage institutions to ensure as much as possible that students complete or correct their 2016-17 FAFSAs using the IRS DRT, and also use that process to download data to their 2017-18 FAFSAs.
Publication Date: 4/14/2016