CONFLICTING
INFORMATION
Presented by: Irma Molinares
Solutions by ECMC
What is Conflicting Information?
Discrepancies in information used to calculate the EFC or determining
eligibility for aid.
 Conflicting information must be resolved regardless of type or source.
Agenda
 Sources
 Timeframe to Resolve
 Conflicting Information vs. Verification
 Professional Judgment Considerations
 Fraud
 Policies and Procedures
Sources of Conflicting Information
Information
High school completion status
Citizenship status
Enrollment status
Financial aid awards or resources
Sources of Conflicting Information
Documenting Conflicting Information
Includes:
Does Not Include:
 Tax documents or schedules.
 Household size different from tax
exemptions.
 Scholarship recipient lists.
 IRS versus ED dependency status.
 SARs and ISIRs.
 Scholarship candidates versus recipients.
 C Flags, or Comment Codes.
 Privacy protected information.
 Verification worksheets or signed
statements.
 CPS assumptions.
 Estimated income on the FAFSA.
 Expired documents versus successful
secondary match.
Sources of Conflicting Information
Unsolicited Information
 ED’s definition of “received.”
 Documents or information.
 Official capacity.
May I ignore or shred unsolicited documents? NO
Sources of Conflicting Information
Institutional Responsibility
Information received by any institutional office is considered to be relevant
and its effect on student eligibility is pertinent.
• Regulations stipulate that institutions “communicate 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
student’s eligibility for Title IV HEA program assistance.”
Agenda
 Sources
 Timeframe to Resolve
 Conflicting Information vs. Verification
 Professional Judgment Considerations
 Fraud
 Policies and Procedures
Timeframe to Resolve
Current
processing year ?
CI Received
No
All aid
disbursed?
Yes
Yes
Treat as EFA
Reserve and resolve
Is student
currently
enrolled (or
intending to reenroll)?
CI resolved at
disbursement?
No
Review and
resolve
Yes
No
No action required
Timeframe to Resolve
Conflicting information does not need to be resolved if a
student dies during the award year.
Timeframe to Resolve
Disbursing Aid
 Conflicting information must be resolved Interim disbursements:
before disbursing Title IV aid.
• Cannot be made if conflicting information
exists.
After disbursement:
• No further disbursements can be made until
resolved.
• Student’s required to repay aid for which
they are not eligible.
Agenda
 Sources
 Timeframe to Resolve
 Conflicting Information vs. Verification
 Professional Judgment Considerations
 Fraud
 Policies and Procedures
Conflicting Information vs. Verification
Possible Types of Conflicting Information
 Family size
 Dependency status
 Tax filing status
Conflicting Information vs. Verification
What is not Conflicting Information?
 Assumptions made by CPS
 FAFSA filed using estimated income
 IRS Request Flag other than ‘02’ and no reason to believe data is accurate
 Dependency under IRS rules compared to ED’s definition of dependency
 Household size on FAFSA
 Number of exemptions on tax return are not defined in the same way and a difference in these two
numbers is not automatically conflicting data.
Conflicting Information vs. Verification
Conflicting Information
Verification
Required for:
All Students.
Students selected by CPS or
school.
Items to review:
Any information provided on
the FAFSA.
Items specified annually in the
Federal Register.
How to resolve:
Collect documentation, recalculate EFC and submit
corrections to CPS, as appropriate.
Tolerance (optional):
None.
$25 per single dollar-related
item, if no non-dollar-related
items need to be changed.
Disbursing aid:
No disbursements allowed
until conflicting information
resolved.
Interim disbursements may be
made before verification is
complete.
Conflicting Information vs. Verification
IRS Data
Fundamental understanding of certain tax issues.
 Whether a person was required to file a tax return.
 What the correct filing status for a person should be.
 An individual cannot be claimed as an exemption by more than one person.
Conflicting Information vs. Verification
IRS Data
Examples that must be resolved:
 Married couple files separately but both file as head of household.
 IRS allows if spouses lived apart for at least 6 months of calendar year, not including separation due
to business, military service, medical care or school.
 Student and parent both claimed student as tax exemption.
 Net assets are zero, but tax return shows income from assets.
Conflicting Information vs. Verification
Subsequent ISIRs
C flags and comment codes:
Review all ISIRs, even if previous
transaction was verified.
• New flags/codes affecting eligibility?
NSLDS data:
• Change in default or overpayment status?
• Exceed loan limits?
EFC:
• Increase/decrease?
• Change in aid eligibility?
Conflicting Information vs. Verification
Subsequent ISIRs
If…
And…
But…
Then…
The EFC changed on
the ISIR
Eligibility for aid is the …
same
The EFC changed on
the ISIR
…
Data changed already Document review of
verified
ISIR
The EFC changed on
the ISIR
Eligibility for aid
changed
Data changed already Document review of
verified
ISIR
The EFC changed on
the ISIR
…
Data changed not
verified
Resolve conflicting
information
The EFC changed on
the ISIR
Eligibility for aid
changed
Data changed not
verified
Resolve conflicting
information
Document review of
ISIR
Conflicting Information vs. Verification
Recalculating and Reprocessing
Change in
Applicant Data
Recalculate EFC
Reprocess ISIR
Example
 Tax documents received and reviewed for conflicting information.
 Taxes paid:
 $4,587 on FAFSA
 $0 on tax return
 Recalculate results in an increase to the EFC.
 ISIR must be corrected through CPS.
Example
 Tax documents received and reviewed for conflicting information.
 Taxes paid:
 $4,413 on FAFSA
 $4,500 on tax return
 Recalculate results in no change to the EFC.
 ISIR does not need to be corrected through CPS.
Agenda
 Sources
 Timeframe to Resolve
 Conflicting Information vs. Verification
 Professional Judgment Considerations
 Fraud
 Policies and Procedures
Professional Judgment Considerations
Must resolve conflicting information before
performing professional judgment.
 May encounter conflicting information:
 Before performing PJ.
 During PJ process.
 After PJ process is complete.
Agenda
 Sources
 Timeframe to Resolve
 Conflicting Information vs. Verification
 Professional Judgment Considerations
 Fraud
 Policies and Procedures
Fraud
Intentionally providing false information
Includes:
•
•
•
•
•
False claims of independent status.
False claims of citizenship.
Use of false identities.
Forgery of signatures or certifications.
False statements of income.
Sources:
•
•
•
•
•
•
Students
Parents
Spouses
School employees
Third-party servicers
Other agents of the institution
Agenda
 Sources
 Timeframe to Resolve
 Conflicting Information vs. Verification
 Professional Judgment Considerations
 Fraud
 Policies and Procedures
Policies and Procedures
 Key areas:








Identical information gathered by other offices.
Additional financial aid assistance.
Unsolicited documents.
Selection for verification.
Training
Subsequent ISIRs
Information from prior year files.
OIG referrals.
Conflicting Information Quiz
T F
A household size reported on the FAFSA that differs from the number of
exemptions on a tax document is considered conflicting information.
T F
Unsolicited tax documents received by financial aid office may be returned to
the sender or destroyed.
T F
All subsequent ISIRs received for a student must be reviewed, even if
verification was completed on the previous ISIR and all aid has been
disbursed.
T F
Conflicting information must be resolved before a school can perform
professional judgment adjustments.
T F
If the admissions office has entered a date of birth in its system that is
different from that which was reported on the FAFSA, the conflict must be
resolved.
T F
You may make an interim disbursement if you have not yet completed
verification, even if there is conflicting information that needs resolving.
QUESTIONS ?
Thank you
Sources
 United Student Aid Funds Inc. (2014). Conflicting Information, Financial Aid Webcast
 U.S. Department of Education. (2012). Resolving Conflicting Information and C Codes, OASFAA Spring Conference.