Information Regarding Institutional Responsibilities to Resolve 2017-2018 Comment Code 399 Conflicting Information Issues

Posted Date: October 21, 2016

Author: Jeff Baker, Director, Policy Liaison and Implementation, Federal Student Aid

Subject: Information Regarding Institutional Responsibilities to Resolve 2017-2018 Comment Code 399 Conflicting Information Issues

In Dear Colleague Letter GEN-16-14, published on August 3, 2016, we provided guidance on the identification and resolution of possible conflicting information between students’ 2016-2017 FAFSAs and 2017-2018 FAFSAs. That guidance included a thorough discussion of the setting of ISIR Comment Code 399. As a reminder, Comment Code 399 is assigned when the student or parent reported different 2015 income and tax information on their 2017-2018 FAFSA than what was reported on their 2016-2017 FAFSA.

Reprocessing – In an Electronic Announcement published on October 13, 2016 we informed institutions that on October 17, 2016, the CPS would reprocess a number of 2017-2018 FAFSAs to remove incorrectly assigned ISIR Comment Code 399s. That reprocessing resulted in just over 7,500 revised ISIRs being produced nationwide out of more than 1.5 million 2017-2018 FAFSAs received to date.

If the ISIR transaction resulting from the October 17 reprocessing no longer includes Comment Code 399 the institution is not required to take any action to resolve the Comment Code 399 that was included in the earlier ISIR transaction. Of course, any subsequent ISIR that includes Comment Code 399 must be resolved using the guidance provided in Dear Colleague Letter GEN-16-14.

Graduate Students – As noted in Dear Colleague Letter GEN-16-14, we have focused our selection of ISIRs for Comment Code 399 on 2017-2018 FAFSA applicants who are, or could be, Pell Grant eligible. We have been asked to clarify whether institutions must resolve Comment Code 399 if the student is a graduate student and therefore not Pell Grant eligible.

The calculation used by the CPS to set Comment Code 399 does not automatically exclude FAFSA applicants simply because they reported on their FAFSA that they would be a graduate student since we know that in some cases that self-reported grade level is in error. That said, an institution is not required to resolve the reported Comment Code 399 if –

  • The institution determines that the student was, or will be, a graduate student for all of 2016-2017 and will continue to be a graduate student for all of 2017-2018; and
  • The student did not, and will not, receive Federal Work-Study for either the 2016-2017 or 2017-2018 award years.

Note that this relief does not apply to a student who was or who will be an undergraduate student even if the student has already completed a bachelor’s degree program. This is because such a student, while not eligible for a Pell Grant or FSEOG funding, is eligible for other subsidized Title IV aid.

Professional Judgment – Dear Colleague Letter GEN-16-14 indicated that we would not be placing Comment Code 399 on 2017-2018 ISIRs if a professional judgment transaction (Professional Judgment Flag set to ‘1’) has been created for either year. Based upon information provided by some institutions, we have determined that there may be a minor processing error resulting in some 2017-2018 ISIRs being flagged with Comment Code 399 when professional judgment had been used. We are currently investigating the circumstances around this issue and will provide guidance on its resolution as quickly as possible through a subsequent Electronic Announcement. In the meantime, we thank institutions for their patience.

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