CONFLICTING INFORMATION Presented by Irma Molinares Solutions by

CONFLICTING INFORMATION Presented by: Irma Molinares Solutions by ECMC

What is Conflicting Information? Discrepancies in information used to calculate the EFC or determining eligibility for aid. § Conflicting information must be resolved regardless of type or source.

Agenda § Sources § Timeframe to Resolve § Conflicting Information vs. Verification § Professional Judgment Considerations § Fraud § Policies and Procedures

Sources of Conflicting Information High school completion status Citizenship status Enrollment status Financial aid awards or resources

Sources of Conflicting Information Documenting Conflicting Information Includes: Does Not Include: § Tax documents or schedules. § Household size different from tax exemptions. § Scholarship recipient lists. § IRS versus ED dependency status. § SARs and ISIRs. § Scholarship candidates versus recipients. § C Flags, or Comment Codes. § Privacy protected information. § Verification worksheets or signed statements. § CPS assumptions. § Estimated income on the FAFSA. § Expired documents versus successful secondary match.

Sources of Conflicting Information Unsolicited Information § ED’s definition of “received. ” § Documents or information. § Official capacity. May I ignore or shred unsolicited documents? NO

Sources of Conflicting Information Institutional Responsibility Information received by any institutional office is considered to be relevant and its effect on student eligibility is pertinent. • Regulations stipulate that institutions “communicate to the individual designated to be responsible for administering Title IV, HEA Programs, all the information received by any institutional office that bears on a student’s eligibility for Title IV HEA program assistance. ”

Agenda § Sources § Timeframe to Resolve § Conflicting Information vs. Verification § Professional Judgment Considerations § Fraud § Policies and Procedures

Timeframe to Resolve CI Received Current processing year ? Yes Is student currently enrolled (or intending to reenroll)? No All aid disbursed? Yes CI resolved at disbursement? No Review and resolve Yes Treat as EFA Reserve and resolve No No action required

Timeframe to Resolve Conflicting information does not need to be resolved if a student dies during the award year.

Timeframe to Resolve Disbursing Aid § Conflicting information must be Interim disbursements: resolved before disbursing Title IV aid. • Cannot be made if conflicting information exists. After disbursement: • No further disbursements can be made until resolved. • Student’s required to repay aid for which they are not eligible.

Agenda § Sources § Timeframe to Resolve § Conflicting Information vs. Verification § Professional Judgment Considerations § Fraud § Policies and Procedures

Conflicting Information vs. Verification Possible Types of Conflicting Information § Family size § Dependency status § Tax filing status

Conflicting Information vs. Verification What is not Conflicting Information? § Assumptions made by CPS § FAFSA filed using estimated income § IRS Request Flag other than ‘ 02’ and no reason to believe data is accurate § Dependency under IRS rules compared to ED’s definition of dependency § Household size on FAFSA § Number of exemptions on tax return are not defined in the same way and a difference in these two numbers is not automatically conflicting data.

Conflicting Information vs. Verification Conflicting Information Verification Required for: All Students selected by CPS or school. Items to review: Any information provided on Items specified annually in the FAFSA. the Federal Register. How to resolve: Collect documentation, recalculate EFC and submit corrections to CPS, as appropriate. Tolerance (optional): None. $25 per single dollar-related item, if no non-dollar-related items need to be changed. Disbursing aid: No disbursements allowed until conflicting information resolved. Interim disbursements may be made before verification is complete.

Conflicting Information vs. Verification IRS Data Fundamental understanding of certain tax issues. § Whether a person was required to file a tax return. § What the correct filing status for a person should be. § An individual cannot be claimed as an exemption by more than one person.

Conflicting Information vs. Verification IRS Data Examples that must be resolved: § Married couple files separately but both file as head of household. § IRS allows if spouses lived apart for at least 6 months of calendar year, not including separation due to business, military service, medical care or school. § Student and parent both claimed student as tax exemption. § Net assets are zero, but tax return shows income from assets.

Conflicting Information vs. Verification Subsequent ISIRs C flags and comment codes: Review all ISIRs, even if previous transaction was verified. • New flags/codes affecting eligibility? NSLDS data: • Change in default or overpayment status? • Exceed loan limits? EFC: • Increase/decrease? • Change in aid eligibility?

Conflicting Information vs. Verification Subsequent ISIRs If… And… But… Then… The EFC changed on Eligibility for aid is the ISIR the same … Document review of ISIR The EFC changed on … the ISIR Data changed already verified Document review of ISIR The EFC changed on Eligibility for aid the ISIR changed Data changed already verified Document review of ISIR The EFC changed on … the ISIR Data changed not verified Resolve conflicting information The EFC changed on Eligibility for aid the ISIR changed Data changed not verified Resolve conflicting information

Conflicting Information vs. Verification Recalculating and Reprocessing Change in Applicant Data Recalculate EFC Reprocess ISIR

Example § Tax documents received and reviewed for conflicting information. § Taxes paid: § $4, 587 on FAFSA § $0 on tax return § Recalculate results in an increase to the EFC. § ISIR must be corrected through CPS.

Example § Tax documents received and reviewed for conflicting information. § Taxes paid: § $4, 413 on FAFSA § $4, 500 on tax return § Recalculate results in no change to the EFC. § ISIR does not need to be corrected through CPS.

Agenda § Sources § Timeframe to Resolve § Conflicting Information vs. Verification § Professional Judgment Considerations § Fraud § Policies and Procedures

Professional Judgment Considerations Must resolve conflicting information before performing professional judgment. § May encounter conflicting information: § Before performing PJ. § During PJ process. § After PJ process is complete.

Agenda § Sources § Timeframe to Resolve § Conflicting Information vs. Verification § Professional Judgment Considerations § Fraud § Policies and Procedures

Fraud Intentionally providing false information Includes: • • • False claims of independent status. False claims of citizenship. Use of false identities. Forgery of signatures or certifications. False statements of income. Sources: • • • Students Parents Spouses School employees Third-party servicers Other agents of the institution

Agenda § Sources § Timeframe to Resolve § Conflicting Information vs. Verification § Professional Judgment Considerations § Fraud § Policies and Procedures

Policies and Procedures § Key areas: § § § § Identical information gathered by other offices. Additional financial aid assistance. Unsolicited documents. Selection for verification. Training Subsequent ISIRs Information from prior year files. OIG referrals.

Conflicting Information Quiz T F A household size reported on the FAFSA that differs from the number of exemptions on a tax document is considered conflicting information. T F Unsolicited tax documents received by financial aid office may be returned to the sender or destroyed. T F All subsequent ISIRs received for a student must be reviewed, even if verification was completed on the previous ISIR and all aid has been disbursed. T F Conflicting information must be resolved before a school can perform professional judgment adjustments. T F If the admissions office has entered a date of birth in its system that is different from that which was reported on the FAFSA, the conflict must be resolved. T F You may make an interim disbursement if you have not yet completed verification, even if there is conflicting information that needs resolving.

QUESTIONS ? Thank you

Sources § United Student Aid Funds Inc. (2014). Conflicting Information, Financial Aid Webcast § U. S. Department of Education. (2012). Resolving Conflicting Information and C Codes, OASFAA Spring Conference.