Overview of Conflicting Information Rules and Required Policies

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Overview of Conflicting Information Rules and
Required Policies Procedures regarding
VerificationPresented by Sharon Abernathy,
Columbia College Jason
Crowe, Barnes-Jewish College
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What is Conflicting Information?

• Refers to contradictory or discrepant information
  
• All conflicting information must be resolved
• Resolving conflicting information ensures all
  application data is accurate, in the financial
  aid office, and throughout the institution,
  before any Title IV monies are disbursed

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Examples of Conflicting Information

• Discrepancies between the financial aid office
  and other campus offices
• Resolve conflicting information, not just in the
  financial aid office, but campus wide

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Examples of Conflicting Information

• Examples of Title IV-related data items that may
  conflict with information found in other campus
  offices include
• Receipt of other financial aid resources from
  other sources
• Changes in academic status, such as grade level
  or degree objective
• Changes to enrollment status

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Examples of Conflicting Information

• Examples of Title IV-related data items that may
  conflict with information found in other campus
  offices include
• Accuracy of citizenship status
• Accuracy of the social security number
• Changes to cost of attendance components
• Elements which affect calculation of EFC

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Examples of Conflicting Information

• Discrepancies between the ISIR and non-Title IV
  loan or scholarship application
• Data on the private application differs from
  information listed on ISIR/SAR

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Examples of Conflicting Information

• Discrepancies between initial and subsequent
  output documents which include
• C-flags and comment codes
• Subsequent ISIR selection for verification when
  initial ISIR was not selected
• Updated NSLDS information
• Receipt of reject ISIR/SAR and subsequent receipt
  of valid ISIR/SAR

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Resolving Conflicting Information

• An institution must always resolve conflicting
  information as soon as discrepancy is found
• Exception is only if the student is no longer
  enrolled at the time the institution learns of
  conflict

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Student Enrollment and Resolving Conflicting
Information

• If a student is enrolled, the institution must
• Resolve conflicting information even if
  processing year has ended
• For a prior year, the institution must
  investigate and resolve the conflict
• Discrepancy discovered after disbursing Title IV
  funds, the conflicting information must be
  reconciled student must repay any aid for which
  he or she wasnt eligible

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Student Enrollment and Resolving Conflicting
Information

• If a student is enrolled, the institution must
• Treat the aid as a resource for the subsequent
  period of enrollment if the student is intending
  to reenroll once the period of enrollment has
  ended and the institution was unaware of aid
  received

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Student Enrollment and Resolving Conflicting
Information

• The institution must take the following action if
  the student is no longer enrolled
• If the institution becomes aware of conflicting
  information after student is no longer enrolled
  but student is eligible for late or
  post-withdrawal disbursement, the institution
  must resolve conflict before making disbursement

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Student Enrollment and Resolving Conflicting
Information

• If the institution knows the student is no longer
  enrolled and does not intend to re-enroll,
  resolution of conflicting information is not
  required if
• All aid for period of enrollment has been
  disbursed, and
• At time of disbursement, there was no conflicting
  information

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Referrals to the Office of Inspector General

• Examples of referrals are
• False claims of independent student status
• False claims of citizenship
• Use of false identities
• Forgery of signatures or certifications
• False statements of income

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Conflicting Information and Professional Judgment

• Professional judgment is the authority by which a
  financial aid administrator has the discretion to
  make a special determination on a students
  application based on the individual students
  unusual circumstances

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What is an Adjustment?

• Simply defined, an adjustment is a change made to
  the students application data by a financial aid
  administrator using professional judgment

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Crossover Years Projected Year Income Versus
Actual Income

• What about projected calendar year income
  information from the prior award year and actual
  income information reported on the new award
  years FAFSA?
• Is this conflicting information if the projected
  income and the actual income do not match?
• In this instance, this is not considered
  conflicting information

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Shiloh Jolee-Pit Case Study

• Just as you would search for Waldo, see if you
  can identify all the conflicting information in
  this case study

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Did you find all the issues?

• Mothers earned income and filing of a 1040 tax
  return
• Siblings nonattendance in post secondary school.
  ( in college)
• EFC recalculation based on revised income, in
  college, and tax filing status. No longer auto 0
  EFC. No longer grant eligible
• Citizenship status?

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Shiloh Jolee-Pit Case Study

• What sources of documentation would you collect
  to resolve the conflicting information?

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Ideally you would need to collect

• Mothers tax returns
• Dependent verification worksheet
• Proof of students U.S. citizenship status
• Documentation from admissions office of
  siblings nonenrollment

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Shiloh Jolee-Pit Case Study

• Does Shiloh have a genuine reason for receiving a
  professional judgment adjustment on her
  dependency status?
• Discussion and opinions

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How well is Verification covered in your Policy
and Procedures Manual?
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Verification Policies and Procedures

• School must establish written
• Verification policies
• Procedures by which it will carry out its
  policies
• Verification regulations
• Contain very specific directives
• Leave some options to school
• Must be clear and consistently applied

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NASFAA Policies and Procedures Tools

• Introduction and Instructions
• Templates for Your Policies and Procedures Manual
• Regulatory Resources Guide

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NASFAA Policies and Procedures Tools

• Formulating, Implementing, and Evaluating
  Policies and Procedures
• Formatting Your Policies and Procedures Manual
• Sample Polices and Procedures Manual
• Reading and Interpreting Regulation and Statute

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NASFAA Policies and Procedures Tools

• Where might you find these resources?
• The new and improved tools, templates, and
  samples can be found at
• http//www.nasfaa.org/Annualpubs/PPManual/index.ht
  m

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MASFAP Spring 2007

• Discussion
• Feedback
• Questions
• Thank you for attending our session.