Conflicting Information and Resolution

In addition to reviewing the application and data match information provided by the Central Processing System (CPS), a school must have an adequate system to identify conflicting information regardless of the source and regardless of whether the student is selected for verification. The school is responsible for reconciling any conflicting information that it has.

All such discrepancies must be resolved before any Federal Student Aid (FSA) funds are disbursed to the student. If a discrepancy is discovered after disbursing FSA funds, the information must still be reconciled and appropriate action must be taken.

Discrepant Data with Enrollment Services

Individuals who have completed high school, college or university course work in a country other than the United States must obtain a complete evaluation of foreign transcripts, degrees, and other relevant documents, even if the foreign coursework has been accepted by a college or university in the US.

High School Diploma/GED:

If a student did not state on their FAFSA application completion of HS/GED, student must submit a copy of their High School diploma

Bachelor’s Degree:

If a student does not indicate that he/she has a Bachelor’s degree or higher on the FAFSA but does on the enrollment application, a graduation clarification form is requested

Program of Study:

Students must be in an eligible program of study for financial aid purposes. If not, a Program Declaration is requested.

Residency Status:

If a student did not state on their FAFSA application California residency but did so their admission application, clarification is requested from Enrollment Services and the student to determine the correct residency status to determine eligibility for the California College Program Grant.

Discrepant Tax Data

Financial aid administrators are required to know whether a person is required to file a tax return, the correct filing status, and that an individual cannot be claimed as an exemption by more than one person. If an individual is required to file taxes and did not file, he or she will be required to complete the appropriate tax form and submit a tax transcript or utilize the IRS Data Retrieval Tool on the FAFSA before the processing of the financial aid application can be completed.

If it is discovered that a student and/or spouse, or a dependent student’s married parents have each filed as “head of household” or claimed a spouse as a dependent, the individuals will be required to amend the tax return and file under the correct filing status. It is not acceptable to simply add the two tax returns together. A copy of the IRS tax return transcript will be required before the financial aid application can be completed.

Publication 17 of the IRS Your Federal Income Tax is an excellent resource.

IRS Flag 07

Potential conflict in data transferred by the student and/or the parent from the IRS. To ensure that correct information is used to determine the applicant’s Title IV eligibility, when IRS Flag 07 appears on an ISIR, the file will be selected for verification. An Income Verification form will be requested along with a copy of the amended tax return and IRS tax transcript.

400 and 401 Comment Code

Potential conflict in data transferred by the student and/or the parent from the IRS. To ensure that correct information is used to determine the applicant’s Title IV eligibility, when Comment Code 400 or 401 appears on an ISIR, the file will be selected for verification.

Cal Grant Eligibility

It is necessary to verify financial eligibility for all Cal Grant recipients who have been selected for verification or who have an ISIR/Cal ISIR loaded into our system with a transaction number of 2 or greater. The purpose of this review is to ensure that changes to a student’s application do not result in the student’s information exceeding the Cal Grant income and asset ceiling.