As Title IV administrators, we’re all too familiar with the term “conflicting information.” It’s a staple in our daily operations in higher education, and its regulatory definition can be found in 34 CFR 668.16(f), 34 CFR 668.16(b)(3), and 34 CFR 668.54(a)(2). These regulations require Financial Aid Administrators (FAAs) to establish a robust system for identifying and resolving any discrepancies that might affect Title IV eligibility, ensuring accurate communication with the designated individual responsible for Title IV administration.
On June 17, 2024, the Department of Education issued GENERAL-24-71 Resolving Conflicting Information which introduced updates on July 24, 2024, and August 1, 2024, specifically for the 2024-25 academic year. This guidance marks a departure from our usual approach to resolving conflicting information, particularly in light of challenges associated with the 2024-25 FAFSA rollout. The implementation of the new FAFSA Partner Portal (FPP) saw delays and reductions in services, as detailed in GENERAL-24-96, which outlines the timeline for availability and functionality.
The June 17 announcement (GENERAL-24-71) identified certain data issues, such as those arising from the Department of Education’s IRS and Future Act Direct Data Exchange (FA-DDX), that impact a subset of FAFSA applicants. For the first time, specific items are listed that should not be considered conflicting information. This approach differs from the traditional review of all potential conflicts.
Key updates include:
- Inaccurate Education Data: Data transferred inaccurately before March 30, 2024, is not deemed conflicting.
- Amended Tax Returns: Discrepancies between amended and original tax returns should generally not be considered conflicting, except when an institution becomes aware of an amended return, as outlined in the 2024-25 AVG.
- Manual Entry vs. FA-DDX: Both manually entered data and FA-DDX data, derived from different tax line references, are considered accurate. Corrections will be implemented in 2025-26 for discrepancies in online and paper FAFSA forms. This is unusual, as typically, there is one correct set of tax lines on a FAFSA.
- FAFSA Processing System Errors: Calculation errors that led to FAFSA reprocessing are not considered conflicting. Institutions are reminded of the option for Professional Judgments (PJs) on a case-by-case basis, potentially increasing eligibility if warranted (see GENERAL-24-39).
The Department also clarified manual data entry scenarios for cases where marital status changes affect FA-DDX data retrieval, necessitating manual input due to a joint filing with a non-FAFSA contributor.
For non-filers with Federal Tax Information (FTI), a July 24, 2024, amendment indicated a technical fix in progress to allow corrections via FPP. The August 1, 2024, note expanded on this, urging institutions to review corrections made prior to July 24.
The complexity stems from changes in the calculation of SAI and Pell Grants. Non-filers automatically receive a -1500 score, excluding FTI from calculations. Institutions must treat this as conflicting and gather contributor tax documentation to make corrections. Though not a professional judgment, institutions must override the “did not file” status to enable accurate SAI calculation.
Institutions are urged to review both blue notes, as the July 24, 2024, note revised original instructions, while the August 1, 2024, note emphasized documentation requirements and the need to review previous adjustments.
As we navigate this new era of financial aid, the challenges of changing platforms and processes can be overwhelming. Yet, our industry’s strength lies in our ability to collaborate and resolve the many complexities we face together.
If your institution needs additional hands on deck during this time, the team at College Aid Services is ready to assist. Contact us at (833) 438-2271 or email info@collegeaidservices.net