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Ask a Fed: Verification, PPY, GE, and More

October 31, 2016

Federal Training Officer David Bartnicki recently shared these updates:


David Bartnicki, Federal Training Officer

Early FAFSA/Prior, Prior Year

ED provided an electronic announcement dated October 21, 2016 outlining several updates to the comment code 399 process.

On October 17, 2016, CPS reprocessed a number of 2017-2018 FAFSAs to remove incorrectly assigned ISIR Comment Code 399s. If the ISIR transaction resulting from the October 17 reprocessing no longer includes Comment Code 399 the institution is not required to take any action to resolve the Comment Code 399 that was included in the earlier ISIR transaction (of course later 399 codes would have to be resolved accordingly).

We also provided updated guidance for graduate students receiving the 399 code. An institution is not required to resolve the reported Comment Code 399 if:

  • The institution determines that the student was, or will be, a graduate student for all of 2016-2017 and will continue to be a graduate student for all of 2017-2018; and
  • The student did not, and will not, receive Federal Work-Study for either the 2016-2017 or 2017-2018 award years

Note that this relief does not apply to a student who was or who will be an undergraduate student even if the student has already completed a bachelor’s degree program. This is because such a student, while not eligible for a Pell Grant or FSEOG funding, is eligible for other subsidized Title IV aid.

And finally, based upon information provided by some institutions, we have determined that there may be a minor processing error resulting in some 2017-2018 ISIRs being flagged with Comment Code 399 when professional judgment had been used. We are currently investigating the circumstances around this issue and will provide guidance on its resolution as quickly as possible.


The October 18, 2016 Electronic Announcement provided the long-awaited guidance allowing schools to accept alternative documentation for tax filers who (after the requisite processing time) have been unable to obtain a tax transcript. Please note that this verification documentation exception is for 2016-2017. Guidance for 2017-2018 will come out shortly before the beginning of the 2017-2018 award year.

The alternative documentation includes the following:

  • A signed copy of the relevant (i.e., applicant, spouse, or parent) 2015 IRS tax return that was filed with the IRS
  • A statement from the tax filer, on or attached to the tax return, which certifies that the tax return submitted to the institution includes the same information that was submitted to the IRS
  • Documentation from the IRS that the transcript request was unsuccessful
    • For tax filers who requested a transcript using the IRS online transcript request process, a signed and dated copy of the screen shot from the official IRS Web page that displays a message indicating that the transcript request was unsuccessful
      • Failure of a tax filer to successfully register for Get Transcript Online is not a sufficient reason for an institution to accept the alternative documentation discussed in this Electronic Announcement. In such a case, a tax filer must request a tax transcript using Get Transcript by Mail or by using paper Form 4506T-EZ or Form 4506-T and provide documentation from the IRS that the tax transcript request was unsuccessful, if applicable
    • For tax filers who requested a transcript using IRS Form 4506T-EZ or Form 4506-T, a copy of the IRS response that was mailed to the tax filer stating that the IRS could not provide the transcript. The copy of the IRS response must be signed and dated by the tax filer
  • A completed and signed IRS Form 4506T-EZ or Form 4506-T that includes on line 5 the name, address, and telephone number of the institution as the third party to whom the IRS is to mail the 2015 IRS transcript. (to be used by the school ONLY if the school questions the accuracy of the information on the signed copy of the paper tax return)

For more information, please see the 10/18/16 EA.

In addition, we updated our program integrity Q&A webpage with the following exception to the verification of nonfiling letter from the IRS:

DOC-Q29. Since a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number is required to obtain a verification of nonfiling from the IRS, how can a nontax filer without one of these identifiers meet the verification requirement to obtain confirmation of nonfiling from the IRS?

DOC-A29. We are aware of circumstances where one or both of the parents of a dependent student or the spouse of an independent student does not have a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number and therefore is unable to obtain a verification of nonfiling from the IRS. Individuals in these cases and whose income is below the IRS filing threshold must submit to the institution:

  1. A signed and dated statement:
    • Certifying that the individual(s) does not have a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number; and
    • Listing the sources and amounts of earnings, other income, and resources that supported the individual(s) for the appropriate tax year; and
  2. If applicable, a copy of IRS Form W–2 for each source of employment income received for the appropriate tax year or an equivalent document

Note: Individuals who submit W-2s that total a gross income that equals or exceeds the IRS tax filing threshold must request a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number and file an income tax return before the student is eligible to receive Title IV aid.

2017-2018 Pell Grant

Of course we need to keep the award years straight but I am happy to announce that ED recently released the final 2017-18 Pell Grant Payment and Disbursement schedules in GEN-16-19. I have been told that the figures provided are final. The 2017-2018 maximum Pell Grant award amount is $5,920, while the actual 2017-2018 Award Year minimum Scheduled Award amount is $596. The maximum Pell Grant eligible expected family contribution (EFC) for 2017-2018 is 5328.

For more information and the actual 2017-18 Pell schedules, please see GEN-16-19.

Cohort Default Rates

I hope all of my schools saw a decrease in their FY2013 3-year official CDRs. The national rate fell to 11.3%. Please note that the time period for appealing the FY 2013 3-Year Official Cohort Default Rates under 34 C.F.R Part 668, Subpart N begins on Tuesday, October 4, 2016 for all schools (45 day window).

For further assistance, please refer to the Cohort Default Rate Guide.

You may also contact our Default Management group at or by calling the Operations Performance Division’s hotline at 202.377.4259.

COD and Updates

Electronic announcements dated October 18, 2016 summarized some key enhancements to COD and occurring this weekend or in early November. Below are some highlights:

  • Effective 10/30/16 in COD
  • New experimental site reporting tool
  • System edit changes and modifications to subsidized usage period impacting the 150% DL Sub limits
  • Valid date ranges for Enrollment Date and Payment Period Start Date fields will be updated for Pell, Iraq and Afghanistan, and TEACH Grants
  • Effective 11/14/16 in COD
  • Direct PLUS Loan Request completed, NSLDS will be checked to confirm borrower’s default status on federal student loans
  • Direct PLUS application system-generated response will include Y = The borrower is in default; N = The borrower is not in default; E = Unable to determine default status
  • Effective 10/30/16 in
  • New loan servicing form library and Navigator tool to assist visitors in finding the desired form(s)
  • Direct Consolidation Loan application process will be updated to identify Perkins Loans separately from all other loan types
  • If applicant selects a Perkins Loan for consolidation, will receive a warning message about consequences
  • The TEACH Grant website and all current
    TEACH Grant website functionality will be integrated into the website.

Gainful Employment

Several new GE electronic announcements came out recently discussing key aspects of the GE process.

Electronic announcement – #93 (10/20/16)

  • Draft GE D/E rates and GE debt measures backup data for each GE program sent to schools October 19th
  • Sent to SAIG mailbox – message class GEBFLEOP
  • Letter sent to CEO with draft rates – message class GELFLEOP
  • GE Debt-to-Earnings Backup Data Viewer Tool can be used to display an institution’s GE Debt Measures Backup Data detail file in a viewable, user-friendly format

Electronic announcement – #94 (10/21/16)

  • The 45-day Draft GE Debt-to-Earnings (D/E) Rates Challenge Period: October 24 to December 7, 2016
  • May challenge through NSLDS certain TIV loan data:
    • Loan does not belong to the student or to the institution;
    • Incorrect loan period dates;
    • Loan debt amount is incorrect
  • Detailed instructions in Chapter 9 of NSLDS Gainful Employment User Guide
  • Must provide comments when challenging for each student and include the GE Record ID – Loan Record ID for each loan
  • Must email supporting documents to

GE electronic announcement #95 – October 26, 2016

  • May appeal a final GE D/E rate if using the alternate earnings would change a program’s D/E rate from zone to pass or from fail to either zone or pass
  • Notice of Intent to appeal must be filed with ED no later than 14 days after the issuance of the final D/E rates
    • Institutions may submit their notice upon receipt of draft D/E rates
    • Specific filing instructions – subject line, content, etc.
    • Alternate earnings data can be from an institutional survey of the GE program’s former students or from a state-sponsored data system
  • Materials to substantiate the appeal are due no later than 60 days following the issuance of the final D/E rates

Pell Recalculations and Modules

Based on earlier guidance provided, I want to remind schools that if they use multiple Pell recalculation dates with modules, the module recalculation date (Census date) applies only to those students who enroll and begin attendance in the module. If the module recalculation date applies, it applies to all of the student’s courses going back to the beginning of the payment period in order to determine the student’s Pell enrollment status.

Repeat Coursework

Since I have gotten several questions around this topic I want to remind schools that once a student has passed a course, TIV aid will only pay for one repeat. If the student does not receive TIV aid for the first repeat, they can get paid TIV aid for the second repeat. The key is that the student only receives TIV aid for one repeat. In addition, remember that Ws do not count as the one repeat since the repeat must be a fully attempted course (earned letter grade).

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