Posted Date: September 4, 2014

Author:  Jeff Baker, Director, Policy Liaison and Implementation, Federal Student Aid
Lisa DiCarlo, Director, Student Experience Group, Federal Student Aid

Subject: Issue Alert - Institutional Responsibility for Reviewing Reprocessed 2014-2015 CPS Transactions; Additional Reprocessing Scheduled for September 2014

In an Electronic Announcement posted on July 18, 2014, we provided information about the expected reprocessing of approximately 200,000 2014-2015 FAFSA® transactions where it appeared that one or more of the FAFSA “Income Earned From Work” fields was in error and that the error could have resulted in an applicant appearing to be Pell Grant eligible when they are not. Our goal was to identify those transactions and have institutions review them before Pell Grant funds were disbursed in the fall. The actual number of transactions that were reprocessed on July 21, 2014 was 182,155. We thank schools for their cooperation in working those transactions.

As we noted in the July 18, 2014 Electronic Announcement, because almost all applicants are required to report “Income Earned from Work”, and because of the nature of the error (entering cents instead of rounding), it was likely that institutional review of the July 21 reprocessed records would also result in the correction of any misreported information in other financial fields, including “Adjusted Gross Income” (AGI) and “U.S. Taxes Paid”.

Notwithstanding the above, there are additional 2014-2015 transactions that we believe need institutional review and possible resolution for applicants who may have misreported higher values to AGI and other financial fields because of the decimal/cents. Such misreporting would result in higher Expected Family Contributions (EFCs) and, in some instances, the reduction or elimination of Pell Grant eligibility when, in fact, the student might be Pell Grant eligible. We have determined that there will be another round of Central Processing System (CPS) reprocessing. We estimate that this second round will result in fewer students than in July – less than 160,000 – and expect the reprocessed transactions to be delivered to institutions on September 9 or 10, 2014.

The system-generated Student Aid Reports (SARs) will include the same Comment (Comment Code 023) that was used for the earlier reprocessing and will say the following:

This SAR was produced because an analysis we conducted on the information you reported on your application indicates you may have made an error which could affect your eligibility for federal student aid. Review all financial fields and make any necessary corrections.

The ISIRs produced as a result of next week’s reprocessing will be sent under the IGSG15OP message class and will include, in addition to Comment Code 023, a value of “03” for the Reprocessed Reason Code (ISIR field #230). The FAA Information page in Student Inquiry on the FAA Access to CPS Online Web site will initially display only the Reprocessing Code of “03”. On December 28, 2014, we will enhance the Web site to display a full description as follows: “03 - Reprocessed due to AGI query result”.

The transactions that we will reprocess will be those that were submitted online prior to the July 1, 2014 fix made to the FAFSA on the Web process that was described in the July announcement, were not included in the earlier reprocessing, and where one or more of the following was met –

  • The independent student’s reported AGI is greater than $100,000;

  • The dependent student’s reported AGI is greater than $100,000;

  • The parent’s reported AGI is greater than $500,000; or

  • The parent’s reported AGI is greater than $100,000 and the parent indicated that they filed an IRS 1040A or 1040EZ.

While meeting these criteria does not mean that an error occurred – we actually do have students who earn more than $100,000 and parents who earn more than $500,000 – we believe that it would  be prudent for institutions to review these transactions to ensure that the financial information is accurate.

Resolution

The guidance provided in the July 18 Electronic Announcement for the first reprocessing required institutions to review any reprocessed records sent to them. We are taking a slightly different approach for this upcoming reprocessing. While we strongly encourage institutions to review the reprocessed records sent to them, we are not requiring that review. This flexibility will allow institutions to consider their own student populations and behaviors and make the best decisions.

We thank you again for your cooperation in resolving this issue so that we can be certain that eligibility for Title IV aid is determined based upon correct data.

Contact Information

If you have any questions regarding the requirement for institutional review of reprocessed records, contact Kerri Moseley-Hobbs at Kerri.MoseleyHobbs@ed.gov.

If you have any questions regarding the reprocessing described in this message, contact CPS/SAIG Technical Support at 800/330-5947 (TDD/TTY 800/511-5806) or by e-mail at CPSSAIG@ed.gov.

You can also post questions to FSATECH.  FSATECH is an electronic mailbox for technical questions about Federal Student Aid systems, software, and mainframe products.  For more information about subscribing to FSATECH, go to: http://www.ed.gov/offices/OSFAP/services/fsatechsubscribe.html.

   

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