Resolving C-Flags. Janette Roszell Georgia Gwinnett College GASFAA Conference 1

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1 Resolving C-Flags Janette Roszell Georgia Gwinnett College 2017 GASFAA Conference 1

2 C Flags C-Code Indicated by a C next to the EFC on an ISIR Two Types Institutional Action Student Action Rejects Students with C-Flags are ineligible for all types of federal student aid and many types of state aid until the c-flag can be resolved or cleared 2017 GASFAA Conference 2

3 ISIR Reject Codes A reject code is delivered on an unofficial ISIR one that has been rejected by CPS because they are unable to process it. Rejects usually require an ISIR correction to resolve EFC on a rejected ISIR is unofficial Usually due to issues with the student or parent identity information (Name, DOB, SSN) or missing signatures 2017 GASFAA Conference 3

4 C Flags Institutional Action Many will require student action once institutional review is complete 399 Significant data conflict between 1617 and 1718 ISIR data Active Bankruptcy Exceeding loan limits NSLDS Name/SSN/DOB data conflict Pell LEU Limits Unusual Enrollment History 2017 GASFAA Conference 4

5 C Flags Student Action Student action means the student needs to submit appropriate documentation or take some other action to initiate resolution of the his/her ineligibility Citizenship not confirmed DHS Match fail Default on Stafford (Direct or FFEL) or Perkins Loan Overpayment due on FSA Grant (SEOG, IGSA, Pell or TEACH) Disability discharge of FSA Loan or TEACH Drug Conviction question left blank or answered 2 or 3 Loss of FSA Eligibility as part of sentencing for a drug related conviction Selective Service failure to register, registration not found, or not enough information to perform match SSN Match Student s name, SSN or DOB doesn t match records at SSA VA Match failed 2017 GASFAA Conference 5

6 399 Code Resolution More information on ifap.ed.gov, the program integrity website, presentations from the most recent FSA conference If a student was verified in either aid year, use those documents to resolve conflicting information, if possible. If student/parent used DRT in either aid year, use that information to resolve the conflicting information if possible. In some cases, different information is not a conflict. The information was accurately reported in each aid year. i.e. For , Medicaid is a means tested benefit for auto-zero or simplified need calculation. In , it was not. If conflicting information exists, update whichever ISIR needs correction and submit to CPS. If the ISIR is updated, the student s awards for must be reviewed and updated with the student s adjusted eligibility 2017 GASFAA Conference 6

7 Active Bankruptcy Volume 1, chapter 3 FSA Handbook Review NSLDS to determine if defaulted FSA loan or grant overpayment claimed as part of an active bankruptcy Defaulted prior to Bankruptcy Claim - NSLDS loan status code DK or OD Did not default - NSLDS loan status code BC If a defaulted loan or overpayment is claimed in the active bankruptcy filing, the student is ineligible for further aid unless/until the holder of the debt proves documentation the debt is dischargeable. (NSLDS loan status code DO) If FSA loans were not in default prior to bankruptcy claim, student is eligible for FSA funds GASFAA Conference 7

8 Exceeding Loan Limits Students need to be reviewed to see if they are, in fact, exceeding the applicable limit Undergraduate limit - $57,500 aggregate Dependent limit - $31,000 aggregate Subsidized loan limit - $23,000 aggregate Graduate limit - $138,500 aggregate Dependent students who have additional unsubsidized loans due to PLUS denial processing may appear to be exceeding limits when they are not Students who are exceeding limits may need a reaffirmation agreement to regain eligibility for FSA funding Students who have met or exceeded their applicable aggregate limit are not eligible for further loans even if a reaffirmation agreement is approved 2017 GASFAA Conference 8

9 NSLDS Data Conflict Occurs when the student has one or more identifiers on NSLDS, but not all the identifiers match the student s identity on the current ISIR. Name, date of birth and SSN are reviewed. Gather identity documents and review to ensure the student s first name, date of birth and SSN are accurate on the ISIR Review any name change documentation gathered by your school to see if the student changed his/her first name If the conflict cannot be resolved by correcting the ISIR, a ticket must be opened with NSLDS NSLDS will request relevant documentation NSLDS will communicate with the FAA about next steps NSLDS will communicate with the FAA once the ticket has been resolved 2017 GASFAA Conference 9

10 Two different C-Flags Students who have LEU between 500%- 600% Students who have met or exceeded 600% Review student s current and future awards to ensure that the student remains at or below 600% of Pell LEU Adjust aid where necessary Disbursements that exceed 600% LEU are rejected or adjusted by COD Pell Lifetime Eligibility Used 2017 GASFAA Conference 10

11 Unusual Enrollment History Two flags that need review UEH2 Review institutional records for prior four (4) award years If student has been paid any FSA aid (Pell or loans) in those years, the flag can be cleared For SACSCO purposes, may want a more in depth review to ensure all prior schools have been reported and transcripts have been received UEH3 Review student s record on NSLDS for grant and loan payments Review transcripts for all schools at which the student received aid Ensure the student earned credit in each year aid was received at each school aid was received 2017 GASFAA Conference 11

12 Citizenship Student needs to submit documentation to prove that s/he is a citizen of the United State of America Acceptable documentation can be found in volume 1, Chapter 2 of the FSA handbook New citizens should contact the Social Security Administration to update their status to avoid having to submit documents each year Documents must be reviewed annually 2017 GASFAA Conference 12

13 DHS match failure If primary confirmation fails, the school should wait for electronic secondary confirmation If electronic secondary confirmation fails, the school may have to submit form G-845 to USCIS for paper secondary confirmation Copies of the student s immigration documents must be sent with the G-845 Both sides of the document must be included Usually, these flags can be resolved by double checking and correcting the student s name, DOB, and/or A# on the ISIR GASFAA Conference 13

14 Default or Overpayment Student must resolve the overpayment or default with the agency that holds the debt. Rehabilitated loans are acceptable, but if the student falls back into default, the school cannot make additional disbursements to that student. Schools can use an updated ISIR, check NSLDS, or collect a copy of the clearance letter the student receives from the debt holder. If using a clearance letter, the school should check NSLDS prior to awarding and disbursing aid to ensure that all loans and/or overpayments are covered by the letter 2017 GASFAA Conference 14

15 Loan or TEACH Discharge Students who have this c-flag have received a discharge of their loan or TEACH liability due to being declared totally and permanently disabled Students with this c-flag remain eligible for FSA Grant funds If student is seeking additional loan or TEACH funds, the student must provide documentation from a physician that s/he has the ability to engage in substantial gainful activity, and sign an agreement that they cannot have the new loans discharged for any present impairment If the student is seeking new funds within three (3) years of the initial determination of disability, the student must also resume repayment for the prior funds before receiving new ones Veterans with a service-connected disability have slightly different requirements 2017 GASFAA Conference 15

16 Drug Related Offense Student may have left question 23 on the FAFSA blank Student needs to correct FAFSA Student may have answered 2 or 3 to question 23 Use worksheet in the AVG to determine eligibility May need to collect documentation related to the student s conviction and aid history to determine eligibility Convictions only count against FSA eligibility of the offense occurred during a period of enrollment for which the student was received Federal Student Aid Convictions for drug possession are treated differently that convictions for selling illegal drugs Loss of Title IV eligibility may be part of a person s sentence for a drug related offense this isn t communicated as a c-flag, it is reject code 19 Specific instructions in Vol. 1, Chapter 1 FSA handbook 2017 GASFAA Conference 16

17 Selective Service A student who was born male on his original birth certificate is required to register for selective service between the ages of Students older than 26 who have not registered must prove: They were not required to register before they turned 26 OR They did not knowingly and willfully fail to register Students who entered the US for the first time after their 26 th birthday can provide a copy of their I-94 to prove they were not required to register Students who were required to register, but failed to do so must get a status letter from the Selective Service System and submit a letter to the FAA that explains why he did not register GGC s first step to resolve these is to check the reported gender on the student s FAFSA and the reported gender on the student s admissions application. If the student is female, we update the ISIR to reflect that and the c-flag clears on its own 2017 GASFAA Conference 17

18 SSA database match fails Two related flags - Student s date of birth doesn t match SSA s records for the SSN reported on the FAFSA Student s name and SSN do not match SSA s records Other SSA flags result in rejects and not c-flags that can be cleared by FAA s FAA should collect documentation that proves the student s legal name (with the Social Security Administration) and/or date of birth Corrections to the student s last name or SSN can result the creation of a new ISIR rather than a correction to the old one GGC often makes these corrections directly in FAA Access to CPS in order to avoid data conflicts and other issues with corrections are sent from our SIS through with a corrxxin.dat file. Student may need to resolve the data conflict with SSA directly if the information in their database is incorrect 2017 GASFAA Conference 18

19 VA Match To be a qualifying veteran, the student must have been a member of the US Army, US Navy, US Airforce, US Marines, or US Coast Guard with active duty service, including training, of at least one (1) day, and be discharged in a status other than dishonorable For these students, a DD-214 showing the branch of service, active duty served, and discharge status can be used to clear the c-flag Students who served in the National Guard or Reserves for any branch of the military must have served on active duty under Presidential Orders in order to be considered a qualifying veteran and be independent FAA s should carefully review the branch of service at the top of the DD-214 to determine if a student is independent Students who are still on active duty may need to correct the FAFSA to indicate active duty military rather than military veteran 2017 GASFAA Conference 19

20 Additional Resources FSA Download fsadownload.ed.gov Technical References and Guides SAR Comment Codes and Text ISIR Guide FSA Handbook, Volume 1 Student Eligibility Acceptable documentation Definitions of eligible student Resolution of eligibility flags 2017 GASFAA Conference 20

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