Transcript Slide 1

Overview of Conflicting
Information Rules and
Required Policies &
Procedures regarding
Verification
Presented by: Sharon Abernathy, Columbia College
Jason Crowe, Barnes-Jewish College
3/8/2007
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
3/8/2007
Sharon Abernathy & Jason Crowe
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
3/8/2007
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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
3/8/2007
Sharon Abernathy & Jason Crowe
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
3/8/2007
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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 wasn’t eligible
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Sharon Abernathy & Jason Crowe
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
3/8/2007
Sharon Abernathy & Jason Crowe
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
3/8/2007
Sharon Abernathy & Jason Crowe
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
student’s application based on the
individual student’s unusual
circumstances
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What is an Adjustment?
Simply defined, an adjustment is a
change made to the student’s
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 year’s 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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Sharon Abernathy & Jason Crowe
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?
Mother’s 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:
Mother’s tax returns
Dependent verification worksheet
Proof of student’s U.S. citizenship
status
Documentation from admission’s
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?
3/8/2007
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
3/8/2007
Sharon Abernathy & Jason Crowe
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/Annual
pubs/PPManual/index.htm
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Sharon Abernathy & Jason Crowe
MASFAP Spring 2007
Discussion
Feedback
Questions
Thank you for attending our session.
3/8/2007
Sharon Abernathy & Jason Crowe