CFlags: A Case Study Approach

1
C-Flags A Case Study Approach

• Facilitators Barbara Wakie Dzelika Daniel

2
What is a C-flag?

• The C code is generated by the CPS as an
  indicator.
• Data matches are conducted with the CPS data and
  other federal databases.
• C-flags must be resolved. The school may collect
  adequate documentation and/or corrections are
  made to the ISIR.

3

• CPS Database matches are conducted with the
  following federal organizations
• Department of Veterans Affairs
• National Student Loan Data System
• Social Security Administration
• Selective Service
• Department of Justice
• Department of Homeland Security

4
Department of Veterans Affairs(VA)

• Any applicant who answers Yes to being a
  veteran of the armed forces has their name,
  social security , and DOB forwarded through the
  matches.
• Codes162,173,180

5
How to resolve VA C flags?

• School can collect documentation.DD214
  (Certificate of Release or Discharge from Active
  Duty, with Character of Service, anything but
  dishonorable.
• If the VA results are correct, make
  changes to ISIR to reflect correction, and
  provide parental information.
• School can collect documentation of
  discharge or upcoming
• discharge

• Record found at VA, but not
• considered an eligible veteran, and
• not considered independent for
• another reason.
• Record not found at VA, and not
• considered independent for another
• reason.
• Record found at VA but applicant is
• on active duty, and not considered
• independent for another reason.

6
VA Resolutions

• No Veteran Match Not considered an independent
  for another reason, parent information must be
  listed on FAFSA.
• National Guardsman or a reservist served on
  active duty for anything other than training but
  did not get a DD214.
• Can accept letter from a superior officer that
  documents call up to active duty and
  classifies the character service as anything but
  dishonorable.
• Student is considered a veteran.
• Student can contact VA to update database.
• Active duty letter from commanding officer
  stating he will be discharged before 6/30/07.

7
NSLDS (National Student Loan Database System)

• Overpayments of FSEOG and/or Pell
• SSN does not match Name and DOB
• Loan Default
• Loan discharge (due to disability, bankruptcy)
• Exceeded Aggregate Loan Limit (over
  subsidized/unsubsidized/total)
• Codes010,020,038,039,041,042,043,065,066,067,077,
  079,086,090,100,101,
• 102,107,115,116,124,132,133,134,135,136,138,254,25
  6,260

8
How to resolve NSLDS

• SSN Match , No Name
• match
• Loan in Default
• If SSN does not match
• DOB

• Access NSLDS online to confirm student. If record
  belongs to student, use NSLDS information
• Default must be cleared or student must have
  satisfactory repayment arrangement and account
  status has to be up to date/no longer in default
• Need documentation from the loan holder or WAIT
  for updated NSLDS info
• See clearing SSA mismatches

9
NSLDS

• Overpayment must be cleared or student must make
  satisfactory repayment arrangement and account
  status has to be up to date
• Obtain documentation from the holder of the
  overpayment or WAIT for update to NSLDS
• Both must be satisfied as stated above

• Overpayment in grant
• If both overpayment in
• Grant and default in
• loan

10
NSLDS

• Review NSLDS to get status of discharge.
• If discharged for disability, letter from doctor
  re students ability to participate in
  substantial, gainful activity.
• Bankruptcy status may be allowed to borrow if
  loans in active bankruptcy status are not
  defaulted.
• Ineligible for Title IV unless excess debt is
  repaid.
• Can not borrow Subsidized
• Can not borrow Unsubsidized
• In the case of Additional Unsubsidized based
  on PLUS denial, student must remit proof of
  denial from lender, previous institution or Dept
  of Ed.

• Loan
• Discharge/bankruptcy
• Exceeded Aggregate
• Subsidized
• Unsubsidized

11
Social Security Administration

• The social security number reported is matched
  against SSA
• database for confirmation of name and DOB.
• You must resolve any problems with the SS match
  before disbursing
• aid. If the Social Security Number is not
  found in SSA database, the students application
  will be rejected.
• Student reported wrong SSN, correct FAFSA data.
• The application will go through matches and
  if confirmed, will be eligible.
• Codes053,146,064

12
SSANumber Issues

• Student reported wrong
• SSN on the FAFSA.
• FAFSA data entry error.
• Error in the SSA
• Database.

• Student must provide the correct SSN to
  the CPS.
• Student contacts FSAIC(Federal Student Aid
  Information Center) at 1800-4-FED-AID.
• Info Center confirms data entry error, it will
  refer the error to the Dept to correct, student
  need not submit change.
• Student must contact SSA to make update. Student
  must report correct SSN and provide
  documentation.
• Database is updated, student can submit a
  correction by re-entering the SSN originally
  reported since it is a correction. CPS does
  another match.

13
SSA No match on name or DOB

• No Name Match.
• Application has conflicting information if
  student or parents ssn is in SSA but name is
  different than reported on FAFSA.
• Name on SS card must be the same as reported on
  FAFSA.
• Student submits documentation to FAA and makes
  corrections with SSA to update database.
• Name is accurate on FAFSA, but does not match the
  SS card, student can override by changing the
  name on FAFSA to match the name which is on the
  SS card. Student must follow up with SSA to make
  corrections.
• No DOB Match
• DOB is accurate on FAFSA, but does not match SSA
  database, student first makes corrections to go
  through match process again.
• If mismatched a second time, then student
  presents school with documentation to prove true
  DOB. Student must follow up with SSA to make
  corrections.

14
Selective Service

• Not confirmed as Registered because
• Did not answer, Are you male?
• Applicant is too old or missing date elements
• Student did not register
• Codes030,033,057,064

15
How to resolve Selective Service?

• The Selective Service reported that you did not
  register with them.
• If female or born before 1960, registration not
  required.
• If not already registered, male and between the
  ages of 18 and 25 student must answer Yes to
  registering or
• Complete registration at Post Office or online at
  www.sss.gov.
• If the student believes they are registered
  already or exempt, they must contact SSS at
  1-847-688-6888.
• If the student is male and above the age of 26,
  they cannot use the SAR to register. They must
  contact Selective Service System to resolve their
  status before receiving federal aid.
• Student will provide school with Selective
  Service Registration Acknowledgment, Status
  Information Letter (Waiver or Exemption).
• Codes053,146,064

16
Department of Justice (DOJ)

• In response to Drug Eligibility question.
• Applicant is found on DOJ Debarment File at CPS
• The student self-certifies in applying for aid
  that they are eligible.
• Codes053,056,058,054

17
DOJ

• Possession of Illegal Drugs
• 1st offense 1yr from date of conviction
• 2nd offense 2yrs from date of conviction
• 3 offenses Indefinite period
• Sale of Illegal Drugs
• 1st offense 2 yrs from date of conviction
• 2 offenses Indefinite period

18
DOJ

• If student was convicted of both possessing and
  selling illegal drugs, and the period of
  ineligibility are different, student will be
  ineligible for the longer period.
• A student regains eligibility the day after the
  period of ineligibility ends
• Or when they successfully complete a drug
  rehabilitation program. Further drug convictions
  will make them ineligible again.
• Refer to the Federal Student Guide for criteria
  of a qualified drug rehabilitation program.

19
Department of Homeland Security

• No match to citizenship and Alien Reg
• Answered Yes to eligible non-citizen but blank
  or invalid Alien Reg
• Codes046,105,109,141,142,144

20
DHS Confirmation

• Ineligible
• Family Unity Status (relief from deportation,
  were once eligible)
• Temp Residents (Allowed to work and live in the
  US under Legalization or Special Agriculture
  Worker program were once eligible)
• Non-immigrant Visas (work, students, visitors,
  foreign govt officials)

• Eligible
• Permanent resident (non-citizen who is permitted
  to live and work in the USA)
• Refugee (temp status, can apply for perm
  resident)
• Asylees (employment authorized for 1 yr, an end,
  can apply for perm resident status will continue
  unless revoked by DHS or until perm residence is
  given)
• Conditional entrants (Terminated in 1980)
• Parolees (must show intent to become Perm.
  Resident)
• Cuban-Haitian entrants

21
DHS

• Alien Reg match DHS Confirmation
• (used in 2ndary Confirmation)

22
DHS

• If SSA confirms citizenship, no reject. If SSA
  did not confirm, Collect documentation then
  correct citizenship and ARN.
• Correct the ARN
• Automatic 2ndary Confirmation
• Will go thru match again. Determine why the
  student made change. Student may have to submit
  proof of citizenship, depends on reason for
  change.
• Wait at least 5 days for results. After 15 days,
  begin paper G-845S process.

• Match not conducted-
• No response to Citizenship and Alien Reg
• Match not conducted-
• Responded as eligible non-cit but blank or
  invalid ARN
• DHS did not confirm as eligible non-citizen
• Student changed ARN after DHS confirmed as
  Non-Citizen
• If Auto 2ndary Confirm.

23
DHSSecondary Confirmation

• Automated 2ndary Confirm did not confirm
• x status or additional info required by DHS

• Begin Paper Process
• Docs must provide proper evidence of eligible
  non-cit status. If not, school can determine stu
  ineligible before starting process.

24
DHS

• Acceptable Documents
• Alien Registration Receipt I-151 (Green Cards)
• Permanent Resident Card (1997-) I-551
• Resident Alien Card (before 1997) I-551
• Student with approved application for permanent
  resident waiting for Alien Registration Receipt
  Card must have proper I-94 stamp.

25

• Permanent residents
• Passport or Arrival/Departure Record (I-94)
• Passport or I-94 stamped Processed for I-551.
  Temporary evidence of Lawful Admission for
  Permanent Residence. Valid until_____.
  Employment authorized.
• I-94 stamped Temporary Form I-551. Admission
  for permanent residence at ____(port)on____(date)
  verified._____(signature of issuing
  officer)________ (title).

26

• Refugees
• I-94 with appropriate stamp indicating admission
  as a refugee or status changed to that of refugee
• Refugee Travel Document (form I-571)if not
  expired
• Asylees
• I-94 with stamp reading Asylum granted pursuant
  to Section 208, USCIS. Valid to ___. Employment
  authorized.
• Conditional Entrants
• I-94 with stamp indication student has been
  admitted to the US as a conditional entrant.
  (prior to March 31, 1980).
• Parolees
• I-94 stamp indicating student has been paroled
  into the US for at least one year, with a date
  that has not expired.
• Cuban-Haitian Entrants
• I-94 with stamp indicating Cuban-Haitian entrant.
  Valid even if expired.

27
DHSDocuments Showing Non-Eligible Status

• Form I-797 Family Unity Program
• From I-668A, I-668B, I-766 and I-668 all related
  to eligibility to work in the US
• Non-immigrant Visa(ie. F1, J1)
• I-94 stamped Temporary Protected Status
• An application for permanent resident status is
  not sufficient for receipt of Title IV aid.

28
DHS

• Disbursement can be made pending DHS response if
• 15 business days have passed since documents were
  submitted
• And
• FAA believes the student meets the requirements
• Must
• Notate that USCIS had exceeded the time allotment
  and eligibility was determined without their
  verification.

29
Case 1 Eric Eligible Non Citizen

• C-Flag 109
• The Department of Homeland Security did not have
  enough information to confirm your response that
  you are an eligible noncitizen (Item 14). You
  must contact the Financial Aid Administrator at
  your school to find out what information is
  needed. If you do not submit the required
  information within 30 days, or longer if your
  school allows, you may not be eligible for
  federal student aid.

30
Case1Resolution

• Student submitted a I-512L (Authorization for
  Parole of an Alien into the United States travel
  document) form which is not allowed documentation
  for financial aid eligibility.
• Student then submitted I-94 form stamped paroled
  new August 2006 with expiration date of August
  2007.
• 2nd Confirmation still pending with USCIS.
• Is student eligible for Financial Aid?
• NO. 2nd confirmation outstanding and Student has
  to have been in the country for at least one
  year.

31
Case 2Wilma Will-Have (green card by next
semester)

• C-Flag 109
• The Department of Homeland Security did not have
  enough information to confirm your response that
  you are an eligible noncitizen (Item 14). You
  must contact the Financial Aid Administrator at
  your school to find out what information is
  needed. If you do not submit the required
  information within 30 days, or longer if your
  school allows, you may not be eligible for
  federal student aid.

32
Case 2 Resolution

• Student submitted parents documentation to proof
  she would be receiving her green card.
• Parents Form I-797C Application for Status as
  Temporary Resident dated 2/2001
• Parents Form I-485 Application to Register
  Permanent Resident dated 6/2002
• Parents Form G-56 Adjustment of Status
  Interview dated 10/2003
• Students I-94 with no stamps posted
• Student was not eligible for financial aid
  through out her fours years of college.

33
Case Study 3 Daisy Disability

• C-Flag 115
• Student has one or more Title IV loans that were
  discharged due to disability.

34
Case 3 Resolution

• Student signed a statement acknowledging that any
  loan that has been conditionally discharged may
  not be discharged due to the same or any
  disability existing at the time the borrower
  applied for a total and permanent disability
  discharge or when the new loan is made, unless
  the disabling condition substantially
  deteriorates to the extent that the definition of
  total and permanent disability is met and
  acknowledging that collection activity will
  resume on any loans in a conditional discharge
  period.
• Student obtained a physicians statement
  certifying that she was currently able to engage
  in substantial gainful activity (defined as the
  ability to work and earn money).

35
References

• 2006-2007 Sar Comment Codes and Text, Department
  of Education
• 2006-2007 FSA Handbook Volume1-
• Student Eligibility

36
Case Studies

• Share Your Experience