2017-18 Verification and Conflicting Information

By Michael Kutcher, NASFAA U Instructor

In this session, presenters from the U.S. Department of Education (ED) discussed changes that are being implemented for 2017-18 verification as well as sources of conflicting information that may result from these changes. One of the biggest changes comes with the elimination of the Household Resources verification tracking group (V6). This leaves V1, V4 and V5 as the remaining three verification groups. V2, V3, and V6 will be reserved for possible use in a future academic year.

Another big change is the shift in tax year data that should be used for the 2017-18 FAFSA. For the 2017-18 FAFSA, applicants are now required to use their 2015 tax year data. Income information used for verification on the 2016-17 FAFSA may be used to satisfy 2017-18 verification. However, schools must obtain new documentation each award year for the number of household members, number in college, and identity and statement of educational purpose. Carrying over from the 2016-17 academic year is the ability for military service members who are unable to obtain a copy of their high school diploma or transcript may use their DD214 as an alternate means to verify their high school completion status.

With regards to conflicting information, because the 2016-17 and 2017-18 FAFSA’s use the same income and tax information, there is a possibility of conflicting information to arise between the two FAFSA’s. However, the regulations under 34 CFR 668.16(f) require schools to resolve any possible conflicting information. This may mean going back to previous award years and correcting data if required and potentially adjusting awards if the previous information was incorrect. To minimize these instances, schools should encourage students to use the IRS DRT for both years and pay attention to FAFSA on the Web submission warnings. In addition, as students complete the 2017-18 FAFSA, they will be given real-time warnings if one or more of the income or tax amounts being input into a 2017-18 FAFSA differs from the amount(s) that was reported on the 2016-17 FAFSA.

After students complete the 2017-18 FAFSA, CPS will compare the last 2016-17 ISIR transaction with the 2017-18 ISIR. CPS will determine if there is income or tax information that is conflicting between the two academic years, and if the identified conflicting information would, once resolved, produce a significant change in the students expected family contribution (EFC). CPS will flag the 2017-18 ISIR to require institutional resolution if conflicting information has been identified with a comment code 399. The comment code will inform the institution that it must resolve the possible conflicting information.

The CPS review will not be performed if the student is not expected to be Pell eligible based on the 2017-18 FAFSA, if professional judgment was performed in either 2016-17 or 2017-18, if there was a change in the student’s dependency status, or if there was a change in the students’ or parents’ marital status. If a student has the 399 comment code and IRS DRT was used in either year with no changes, institutions may assume that the verified or IRS DRT transferred values are correct and submit corrections to the other year’s ISIR information. The only exception to this is if the institution is aware that the student filed an amended 2015 tax return with the IRS, in which case it must ensure that both years’ EFCs were calculated using the amounts from the amended tax return regardless if the DRT was used.


Publication Date: 7/10/2016

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