The Department has released additional guidance for 2024-25 Aid Awards using the ISIRs affected by errors.
They reaffirmed the plan to retransmit all impacted ISIRs in the coming weeks. For the purposes of packaging and disbursing aid expeditiously, schools and states may, based on data provided by the Department, use their judgment to rely on the original ISIR sent—not the reprocessed record—if certain conditions are met.
The announcement(General – 24-39) provides more guidance on adhering to professional judgment and compliance mandates for schools that choose to grant awards based on an original ISIR.
The full announcement is below.
POSTED DATE: April 11, 2024
AUTHOR: Federal Student Aid
ELECTRONIC ANNOUNCEMENT ID: GENERAL-24-39
SUBJECT: Guidance on Aid Awards Using ISIRs Affected by Errors
In this Electronic Announcement, the Department of Education (Department) provides additional information about how to treat Institutional Student Information Records (ISIRs) affected by errors when making financial aid offers and disbursing funds during the 2024-25 award year.
The Department has transmitted the ISIRs from more than 7 million FAFSAs to schools and states. As previously noted, some of these ISIRs were affected by calculation errors and inconsistent tax data. For more information on these issues, see the Technical Frequently Asked Questions and Known Issues document, Electronic Announcement (GENERAL-24-29), and Electronic Announcement (GENERAL-24-34).
The Department intends to reprocess all of the affected records in the coming weeks, as described in Electronic Announcement (GENERAL-24-37). However, schools and states do not need to wait for those reprocessed records. For the purposes of packaging and disbursing aid expeditiously, schools and states may, based on data provided by the Department, use their judgment to rely on the original ISIR sent—not the reprocessed record—if the following three conditions are met:
- The ISIR is based on a 2024-25 FAFSA form and is the basis for aid offered and disbursed during the 2024-25 award year.
- The original ISIR results in greater financial aid eligibility for students. (If the reprocessed ISIR results in greater financial aid, schools may make estimated offers now but must use the more accurate, reprocessed record for final offers and disbursement of funds.)
- The ISIR is subject to reprocessing by the Department due to one of the errors described in Electronic Announcement (GENERAL 24-38) and listed below. For more information on these issues, see the Technical Frequently Asked Questions and Known Issues document.
- Pell Grant Eligibility Flag is incorrectly blank: The Pell Grant Eligibility Flag (ISIR field 571) was incorrectly blank for some students.
- Pell Grant Eligibility Flag incorrectly set to Y on ISIRs without an SAI: The Pell Grant Eligibility Flag (ISIR field 571) should not be set to Y on rejected records.
- Comment code 217 sometimes appears incorrectly: A small number of ISIRs incorrectly include comment code 217 instead of 327.
- Dependent students with assets and blank SCA: FPS was not including all data fields needed to correctly calculate the SAI for dependent students who reported assets.
- SAI is blank on some ISIRs that do not contain reject codes: The SAI should not be blank if a processed ISIR contains no reject codes.
- Federal tax information (FTI) is missing from some non-rejected ISIRs where FTI consent has been provided: Cases where a production ISIR is not a reject, contributors have provided consent to retrieve and disclose FTI from the IRS, there is not manual tax data, and yet the FTI data and SAI is missing without expected flags and errors on the ISIR.
- Inconsistent tax data, Education Tax Credits: Data for education tax credits transferred prior to March 30, 2024 are inconsistent.
- Inconsistent tax data, Amended and Updated Tax Returns AGI or filing status mismatch: In cases in which taxpayer information is updated through an amended tax return, the most recent adjusted gross income (AGI) and filing status is mixed with original values for other tax return elements, leading to inconsistent tax data.
- Inconsistent tax data, Schedule H indicator or other mismatch: The Department found a number of ISIRs with other mismatched data, mostly with the Schedule H indicator. Most institutions will not see any ISIRs with this issue, and any ISIRs that are impacted will be reprocessed.
Additional Details
Assessing an institution’s use of professional judgment: When assessing an institution’s judgment in these situations, the Department considers each instance in which an institution awards aid from the original ISIR in the circumstances described above to be a circumstance that differentiates the student and their contributors and, therefore, is being handled on a case-by-case basis. Additionally, institutions retain the authority to consider other circumstances and use professional judgment to amend FAFSA values or cost of attendance components to more accurately reflect a student’s financial circumstances.
Documentation of decision: Institutions that choose to award and disburse Title IV, HEA funds based on the original ISIR data in these circumstances must document and maintain a record of the decision in the student file, including the original 2024-25 ISIR on which the school bases its award and the reprocessed record that demonstrates a lower amount of aid eligibility.
Compliance: When considering an institution’s compliance with Title IV, HEA requirements related to the packaging or processing of Federal student aid, the Department will make its assessments in light of these instructions and the unique circumstances in which institutions are being asked to make judgments about correct award amounts of Title IV, HEA funds. In addition, as always, institutions may share with the Department their challenges in meeting compliance obligations for reasons outside the control of the institution. The Department considers these challenges in assessing compliance concerns or enforcement actions.
The Department maintains final authority to determine the extent of an institution’s compliance with Title IV, HEA requirements, including when resolving non-federal audits. However, following the instructions in this document will not, in and of itself, create compliance concerns. In addition, using judgment to proceed with original ISIRs or to use reprocessed ISIRs as described in this announcement will not, on its own, lead the Department to initiate a program review.
We thank you for your continued partnership in ensuring all students have the resources they need to access and succeed in higher education.
SOURCE: (GENERAL-24-39) Guidance on Aid Awards Using ISIRs Affected by Errors