Posted Date: November 18, 2016

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

Subject: Institutional System Delay in Resolving Conflicting Information Comment Code 399

We have been asked whether institutions are required to withhold making initial or subsequent disbursements of 2016-2017 subsidized Title IV aid when the institution is not able to load ISIRs sent to the institution’s SAIG mailbox, into its institutional student aid data system. We are specifically referring to institutional systems readiness issues that delay an institution’s determination if any of the 2017-2018 ISIR records include Comment Code 399.

Generally it is expected that institutions would promptly download ISIRs from their SAIG mailbox and review them to determine if any include Comment Code 399. However, because of the new October 1st early FAFSA start-up, we are providing special consideration for instances when an institution is not yet ready to move 2017-2018 ISIRs from its designated SAIG mailbox into a “production database”.  Only in instances where the institution’s systems are not yet ready for 2017-2018 ISIRs (and not simply because the institution chooses to delay its start-up or loading of 2017-2018 ISIRs) the institution may continue to make 2016-2017 Title IV disbursements to otherwise eligible students, notwithstanding that there could be a 2017-2018 ISIR for a student with a Comment Code 399.  Once the institution is able to load its 2017-2018 ISIRs, it must promptly do so and then determine which have a Comment Code 399.  The institution should not make any additional 2016-2017 disbursements until it determines if corrections need to be made to the 2016-2017 record, and if so until it receives a new ISIR transaction with the “corrected” EFC.

Of course, institutions should consider the consequences to their students in those instances where the new EFC results in the student not being eligible for all or some of the 2016-2017 aid that had been disbursed.  The student may be required to repay funds that the institution disbursed before it determined if there was a 2017-2018 ISIR with Comment Code 399.

Finally, we remind institutions that ISIRs placed in an institution’s SAIG mailbox are only available for 180 days.

   

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