Resolving Conflicting Information

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Resolving Conflicting Information

• SASFAA
• Greensboro, NC
• February 2006

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What is Conflicting Information under the
Regulations?

• Information obtained that is different from
  information previously available to the
  institution and that impacts a students
  eligibility for aid
• Includes, but is not limited to, verification

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Conflicting Information vs. Verification

• Conflicting information
• All Title IV recipients
• Any information that affects Title IV aid
  eligibility
  
• Verification
• Selected Title IV recipients
• Only specific ISIR data elements

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Conflicting Information 668.16(b)(3)

• Requires that the institution communicates 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 students eligibility for Title
  IV, HEA program assistance

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Conflicting Information 668.16(f)

• Develops and applies an adequate system to
  identify and resolve discrepancies in the
  information that the institution receives from
  different sources with respect to a students
  application for financial aid under Title IV, HEA
  programs

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Conflicting Information668.16(f)

• (1)   All student aid applications, need
  analysis documents, Statements of Educational
  Purpose, Statements of Registration Status, and
  eligibility notification documents presented by
  or on behalf of each applicant
• (2)   Any documents, including any copies of
  State and Federal income tax returns, that are
  normally collected by the institution to verify
  information received from the student or other
  sources and
• (3)   Any other information normally available
  to the institution regarding a students
  citizenship, previous educational experience,
  documentation of the students social security
  number or other factors relating to the students
  eligibility for funds under the Title IV, HEA
  programs.

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To File Or Not To File

• ISIR says not going to file and gross income
  meets IRS minimums
  
• Thats conflicting information!
• www.irs.gov/pub/irs-pdf/i1040.pdf
• Scroll to bottom of page 12

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Other IRS Stuff You Need To Know

• Correct filing status
• Example is married couple files separate tax
  returns and both filed as head of household
  
• Individual cannot be claimed as exemption on two
  returns
  
• Example is student and parent both claimed
  student as tax exemption
  

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Handling Conflicts In Untaxed Income

• Whats verified doesnt match Worksheets A B!
• more items reported as untaxed income and
  benefits than regulations require to be verified

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A Conflict With Assets

• Look at assets and compare to income from assets
  reported on a tax return
  
• interest and dividend income
• rental income
• business or farm income

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Sources Of Conflicting Information

• Outside scholarship sources
• State Agencies such as Voc Rehab., WIA, State
  Scholarship Agencies, etc.
  
• Tips from outside sources
• Handling anonymous calls and hearsay vs.
  documented credible evidence
  
• Being proactive
• Is the information from a routine business
  process at the school?

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What About Other Offices?

• Admissions has different information than FAO
• Business office receives outside aid payment
• Veterans Certifying Official certifies student
  for VA benefits
  
• Other campus departments award aid

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What Is Not Conflicting Information?

• Household size differs from number of exemptions
  on tax return
  
• Dependent under IRS rules vs. ED definition of
  dependent
  
• Roster of candidates for an outside scholarship,
  as opposed to a list of recipients
  
• Privacy protected information, such as
  information from professional counselors,
  chaplains, doctors, etc.
  

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What Is Not Conflicting Information?

• FAFSA filed using estimated income
• Zero or low income
• Assumptions made by the CPS
• Secondary confirmation match successful, but
  student has an expired INS document
  
• W-2 Box 14
• Tax filer claimed multiple or conflicting
  credits
  

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Sources Of Conflicting InformationInformation
From ED

• Subsequent SARs or ISIRs must be reviewed
• If no change in EFC (and no change in C Flag,
  matches, or NSLDS), no action required
  
• If EFC changes and data elements changed were
  previously verified, no action needed
  
• If EFC changes and data not previously verified,
  must resolve conflict

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Sources Of Conflicting InformationInformation
From ED

• Updated NSLDS information
• Postscreening - Info that has changed since the
  last transaction are marked on the output
  document with a sign, and a system-generated
  flag of N will appearloan limits and C flags
• Transfer Monitoring process
• MRRs and POPs from COD

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What Constitutes Resolution Of Conflicting
Information?

• Basically, resolution is the determination of
  what is the correct information
  
• sometimes that may be simply confirmation that an
  earlier determination is correct
  
• Documentation of resolution required

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Timing Of Institutions Receipt Of Conflicting
Information

• No further action is needed if
• all aid for period of enrollment has been
  disbursed, and
  
• at the time of disbursement, there was no
  conflicting information, and
  
• student no longer enrolled at the institution
  (and is not intending to re-enroll)

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What About Late Disbursements PWDs?

• If student is no longer enrolled when institution
  becomes aware of conflicting information and
  there is remaining aid to be disbursed, you must
  resolve the conflict before making any late or
  postwithdrawal disbursements

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Timing Of Institutions Receipt Of Conflicting
Information

• Cross-year conflicts must be resolved
• continuing student, but payment period or award
  year has ended and all payment periods for which
  aid has been awarded are finished
  
• between award yearsusually student eligibility
  issues such as prior default, late reporting of
  overpayment, student had BA and received Pell,
  etc.

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Timing Of Institutions Receipt Of Conflicting
Information

• Aid that school is unaware of received after
  student no longer enrolled (but is intending to
  re-enroll) may be treated as resource/EFA for the
  subsequent period of enrollment, but institution
  must resolve
• If the processing year has shut down, conflict
  must still be resolved
  

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When Should You Contact The Office Of The
Inspector General?

• Section 668.16(g) requires an institution to
  refer to the OIG any credible information
  indicating that an applicant for Title IV aid may
  have engaged in fraud or other criminal
  misconduct in connection with his or her
  application. Refer information which is relevant
  to the students eligibility or the amount of the
  assistance.
• Examples false claims of independent student
  status, false claims of citizenship, use of false
  identities, forgery of signatures of
  certifications, and false statements of income
• Remember that fraud is an intent to deceive as
  opposed to a mistake

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You Can Ask For Anything!

• If you believe that any information provided is
  incorrect, you must require that the information
  be documented
  
• Any data element may be documented
• BUT USE WHAT YOU COLLECT!!

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FSA Assessment Activity

• http//ifap.ed.gov/qadocs/FSAVeriModule/activity7.
  doc
  
• References
• Charts
• Analysis of your policies

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Resources

• 2005-2006 AVG, pages 101-102
• IRS Publication 17
• www.irs.gov/pub/irs-pdf/p17.pdf

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• Jamie A. Malone
• Training Officer
• U.S. Department of Education
• 312-886-8731
• jamie.malone_at_ed.gov