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Early 2017-2018 FAFSA processing and managing the SAR Comment Code of 399 (Doc ID 2177511.1)

Last updated on FEBRUARY 01, 2017

Applies to:

PeopleSoft Enterprise CS Financial Aid - Version 9 to 9.2 [Release 9]
Information in this document applies to any platform.


Although the 2016-2017 and 2017-2018 FAFSAs should be completed using the same 2015 income and tax information, there is the possibility that there might be conflicting information between the two FAFSAs.

If the CPS process described above results in the possibility of a significant change in a student’s EFC, and resultant Pell Grant eligibility, the student’s 2017-2018 SAR and ISIR will be flagged with a ‘C’ code and a special new Comment Code 399 informing the institution that it must resolve the possible conflicting information.

When resolving possible conflicting information between a 2016-2017 and 2017-2018 ISIR, based on the special new Comment Code of 399 included on a student’s ISIR, the institution must comply with the following:

• The institution must compare all of the 2015 income and tax related FAFSA/ISIR items from both years’ ISIRs to determine which income or tax item or items are in conflict. (See Early FAFSA Electronic Announcement #4 for a listing of those FAFSA/ISIR items).

• If, for either year, the institution had verified the conflicting information item(s), or the student or parent had transferred information into the FAFSA using the IRS DRT and had not changed any of the transferred information (ISIR Fields #177- student and #178 parent with a value of ‘02’), the institution can assume that the verified or IRS DRT transferred values are correct and must, therefore, submit corrections to the other ISIRs year’s values.


Condition  Resolution Required? Note Reason
Institution received a 2016-2017 ISIR and disbursed, or may disburse, aid based on that 2016-2017 ISIR. Yes Institution must resolve the conflicting information, even if the institution will not be awarding Title IV aid based on the 2017-2018 ISIR because, for example, the student will not attend in 2017-2018. Resolution might result in a change to the student’s 2016-2017 Title IV eligibility.
Institution received a 2016-2017 ISIR but did not review or process that ISIR. Yes Institution must resolve the conflicting information even if, for example, the student never attended during 2016-2017. Resolution might result in a change to the student’s 2017-2018 Title IV eligibility.


Update January 31, 2017:

CPS will be conducting a reprocessing of 399 records

The CPS will conduct a reprocessing on February 6, 2017 for 2017-2018 student records with an auto-zero EFC on their 2017-2018 record or a professional judgment on their 2016-2017 record. SAR comment code 399 will be added or removed as needed based on the updated logic that will be implemented on February 5, 2017.

This reprocessing will also include a sub-set of 2017-2018 dependent student records that need to be re-evaluated for SAR comment code 399 based on the resolution of a separate CPS issue that caused the cross-year EFC calculation to use the current cycle's calculated total income instead of the prior cycle's calculated total income. The reprocessing will potentially add or remove comment 399 from the records identified as being affected by this issue. This issue impacted students who were dependent, had student financial information on record, and qualified for the cross-year EFC calculation and edit.

ISIRs produced as a result of the reprocessing will include a value of “02” for the Reprocessed Reason Code.

Consider adding the following records.fields to the queries you're using to identify your SAR Comment 399 cohort:

Federal Application records:


ISIR Staging records:


Records having a Reprocess Reason Code of ‘02’ will either be newly assigned 399 records or will have lost the 399 assignment due to being erroneously assigned under the original logic. Institutions will need to compare this list to their existing list to know which records they don’t need to continue pursuing conflict resolution for and for which they do. After this reprocessing effort, they can return to the way they have been identifying/handling/resolving 399 records.



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