1.4 Conflicting Data
668.16 (f) Conflicting Data |
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Applicable Policies and Procedures: Policy 03:15:00 Federal Verification and Conflicting Data Policy |
As required by CFR 668.16 (f) the Financial Aid Office employs an adequate system to identify and resolved discrepancies in the infomration that the institution receives from different sources with respect to a student's application for financial aid under Title IV, HEA programs.
In accordance with Policy 03:15:00 Federal Verification and Conflicting Data Policy, if the College has reason to believe that any information on the application used to calculate the EFC is discrepant or inaccurate (or if any supporting documentation is discrepant or inaccurate), the College requires the student or parent to provide adequate documentation to resolve the conflict.
Students or parents not selected for verification –the College must resolve conflicting information regardless of whether or not the student or parent was selected for verification. The financial aid office must review all tax returns/transcripts provided to the College even if they were not requested. All C Codes on the ISIR must be reviewed and resolved by the financial aid office.
Other student or parent information received by the College –Platt College must have an adequate internal system to identify conflicting information that it may have regardless of the source. The office lead for each office is required to provide information that could impact the financial aid status of each student or parent e.g. (Admissions Office: High School Diploma, Fiscal Office: Report outside awards, Graduate Aid Office: Report outside awards, Registrar: Report changes in enrollment, Federal Work Study Office: Report FWS earning in a calendar year, National Student Loan Data System (NSLDS): Review financial aid history, (e.g. review aid received from prior colleges attended).
The following list provides examples of conflicting data. Please note: the list is not construed as an all-inclusive list.
- A student is not selected for verification, the tax return or IRS transcript is on file and information conflicts with items on the FAFSA.
- Form 1040 shows parent single head of household (HOH) and the FAFSA/ISIR shows the same person as married.
- Parent or student report on their FAFSA and signed a verification worksheet that they will not file an IRS Form 1040. The College has reason to believe that they would have been required to file a U.S. Income Tax Return, as the amount of reported income is greater than or equal to the minimum amount required to file as indicated in the instructions provided on the Form 1040.
- Statements or information that suggests that the copy of the Income Tax return/transcripts you received is not the return actually filed with the IRS.
- The College receives Profile from College Scholarship Service (CSS). Student reports a specific amount in untaxed income; FAFSA reports a different amount (If the College receives the CSS Profile, it must ensure that information contained there does not conflict with other documents received by the College).
- Veterans Affairs (VA) benefits verified by the certifying official in the Registrar’s Office don’t match the FAFSA. (To resolve conflict, can rely on certifying official).
- Admissions information received impacts student eligibility (i.e., student accepted into a non-degree program, student received scholarship from high school, etc.)
- The Student Academic Progress or Enrollment Status on file in the Financial Aid Office doesn’t agree with the information from the Registrar’s Office.
Examples of issues not considered Conflicting Data, but should be reviewed:
- Assets reported on the FAFSA are $0 or low but significant interest and dividend income or capital gains are reported on the U.S. Income Tax Return/transcripts.
- $0 income reported with no explanation as to how the student/parent/family can live on $0 income Address reported by student/parent (i.e., if parents are divorced and the address on the student’s tax return/transcripts does not match the address of the custodial parent’s tax return). Or the address doesn’t match the state of residence as listed on the FAFSA.
- If the student or parents reported business/farm net worth but didn’t file a schedule C or Form 1120 or just didn’t supply it to the College. Request additional documentation from student or parent to verify the information.
- Box 14 information from W-2. Determine if the dollars represented are untaxed income not previously reported
- Always have the ability to ask for whatever information you need any time that you think there is a problem.
Additional Documents (to Resolve Conflicting Information)
- Copy of W-2 Income Statement
- Copy of Marriage Certificate
- Copy of Birth Certificate
- Copy of Social Security Card
- Legal Guardianship/Emancipated Minor Form
- Copy of Legal Guardianship Paperwork
- Copy of Legal Emancipated Minor Paperwork
- Copy of Ward of Court or Foster Care Paperwork
- Copy of Documentation to Support Homelessness or At-Risk Homelessness
- Copy of Veteran DD214 Paperwork
- Asset Information Worksheet (AU/AX)
- Copy of a 1099/1040 Tax Return to Verify IRS/Pension Rollover
Interim Disbursements and Resolution of Conflicting Information
The College may not disburse aid until you have resolved conflicting information. Even if the conflict concerns a previous award year, the Financial Aid Department must still investigate it. The matter will be resolved when financial aid has determined which data are correct; this might simply be confirming that an earlier determination was the right one. The Financial Aid Department will document the findings and explain why, not simply assert that, the decision is justified.
Correction of Information
Once the requested information is received, Student Financial Services submits the verified corrections to the Central Processing System (CPS) electronically. This will ensure that corrections are made known to all parties and that the needs analysis will be updated accurately and according to federal standards. Once corrections are received back at the school, the student is reviewed and rewarded through Quality Control process. All interactions are communicated with the student via email communication.
As mandated by section 34 CFR 668.16 (g) of the Federal Register, any credible information indicating that a FAFSA applicant may have engaged in fraud or other criminal misconduct in connection with his or her application will be reported to the Office of the Inspector General of the Department of Education.
Effective with the 2017-2018 aid processing year, and as described in Dear Colleague Letter GEN-16-14, the Central Processing System (CPS) may flag an applicant's ISIR if it contains conflicting information which requires institutional resolution.
If an ISIP is flagged by CPS it will contain Comment Code 399. The Financial Aid Department reviews all ISIRs containing Comment Code 399. If the department is able to resolve the conflicting information using existing documentation in the student's file, s/he would verify and resolve the conflicting information. If additional documentation is need to resolve the conflicting information, the department will contact the student directly. Any adjustments to a student's financial aid eligibility as a result of updates made during the institutional resolution will be communicated to the student via College email.