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Ask a Fed: Verification, Early FAFSA, Program Eligibility, and More

November 22, 2016

Federal Training Officer David Bartnicki recently provided these updates:bartnicki

Early FAFSA/Prior, Prior Year

I have gotten lots of questions from schools regarding their inability to view 17/18 ISIRs due to system upgrades/issues. ED recently posted an electronic announcement on 11/18/16 that addresses these concerns. Please note that we assume this is a temporary situation and that once the ISIRs are available for viewing, schools will start reviewing them (especially for the 399 code). Here is an excerpt from the EA:

“…we are providing special consideration for instances when an institution is not yet ready to move 2017-2018 ISIRs from its designated SAIG mailbox into a “production database”. Only in instances where the institution’s systems are not yet ready for 2017-2018 ISIRs (and not simply because the institution chooses to delay its start-up or loading of 2017-2018 ISIRs) the institution may continue to make 2016-2017 Title IV disbursements to otherwise eligible students, notwithstanding that there could be a 2017-2018 ISIR for a student with a Comment Code 399. Once the institution is able to load its 2017-2018 ISIRs, it must promptly do so and then determine which have a Comment Code 399. The institution should not make any additional 2016-2017 disbursements until it determines if corrections need to be made to the 2016-2017 record…”


On October 31, 2016 ED posted an electronic announcement that discusses several key scenarios where an applicant’s Verification Tracking Group can change and when Title IV funds may have to be returned. A chart is attached that covers situations where an applicant was disbursed Title IV aid and was later selected for verification or their verification tracking group changed or filed an income tax return extension. The guidance in this Electronic Announcement and the attached chart applies to both the 2016-2017 FAFSA processing year and to all subsequent years, including the 2017-2018 FAFSA processing year.

Please review the announcement and chart for more information:

Also, please do not forget to update your V4 and V5 students in FAA Access to CPS Online for 2016-2017 and 2017-2018. Our November 18, 2016 electronic announcement reminds schools that the V4/V5 tracking process will continue in 2017-2018 and that we have added a new value 6 as a possible outcome when reporting students – problems with both identity and high school completion.

In addition, we recently updated several verification Q&As on the program integrity website:

General Questions (VER)


Acceptable Documentation for FAFSA Information Selected for Verification (DOC)


To access all of the Program Integrity Q&As, please visit: (upper right-hand side of IFAP).

Borrower Defense

A final federal register was posted on November 1, 2016 regarding the much talked about borrower defense regulations. Aside from a few areas, the regulations become effective July 1, 2017. A few highlights include:

  • Clarify that borrowers with loans first disbursed prior to July 1, 2017, may assert a defense to repayment under the current borrower defense State law standard
  • Establish a new Federal standard for borrower defenses, and limitation periods applicable to the claims asserted under that standard, for borrowers with loans first disbursed on or after July 1, 2017
  • Establish a process for the assertion and resolution of borrower defense claims made by individuals
  • Establish a process for group borrower defense claims with respect to both open and closed schools, including the conditions under which the Secretary may allow a claim to proceed without receiving an application
  • Provide for remedial actions the Secretary may take to collect losses arising out of successful borrower defense claims for which an institution is liable
  • Add provisions to schools’ Direct Loan Program participation agreements (PPAs) that, for claims that may form the basis for borrower defenses, prohibit participating schools from using certain contractual provisions regarding dispute resolution processes and require certain school notifications /disclosures regarding arbitration
  • Clarify that a limitation may include a change in an institution’s participation status in title IV, HEA programs from fully certified to provisionally certified
  • Amend the financial responsibility standards to include actions and events that would trigger a requirement that a school provide financial protection, such as a letter of credit, to insure against future borrower defense claims and other liabilities to the Department
  • Require proprietary schools at which the median borrower has not repaid in full, or paid down by at least one dollar the outstanding balance of, the borrower’s loans to provide a Department-issued plain language warning in promotional materials and advertisements
  • Require a school to disclose on its Web site and to prospective and enrolled students if it is required to provide financial protection, such as a letter of credit, to the Department

For a detailed discussion and the actual regulations, please review the 11/1/16 federal register –

2017-2018 Shopping Sheet

Due to the early FAFSA process for 2017-2018, I am happy to announce that for those schools using the shopping sheet, the 2017-2018 shopping sheet is now available. On November 14, 2016, we posted an electronic announcement that contained the new 2017-2018 shopping sheet template, file layouts, data file schema and HTML specifications. Please see the 11/14/16 EA for more information –

Gainful Employment

As noted in the GE EA #98 dated 11/18/16, please do not forget that if you plan to challenge any draft GE Debt-to-Earning Rates you need to do so by December 7, 2016. It is important to note that all draft GE D/E rates challenges must be submitted and confirmed on the NSLDS Professional Access website by 11:59 P.M. (ET) on December 7, 2016 in order to be considered by the Department. For all challenges, both the “Submit” and “Confirm” buttons must be clicked to complete the challenge submission process; otherwise, the corrections will be lost.

For specific information on how to properly submit challenges and for additional resources, please see the November 18, 2016 electronic announcement –

Campus-Based Funding

On November 18, 2016, ED provided an electronic announcement outlining the Title III and Title V waiver process for the non-federal share of earned compensation paid to students under the FWS Program and of FSEOG funds awarded to students for the 2017-2018 award year.

OPE/IS has automated its designation process by using existing data to determine an institution’s eligibility for Title III and Title V Programs.

Once the 2017 OPE/IS process is complete, institutions may verify their Title III and Title V eligibility status by going to the Application on the OPE/IS website (

A notice will be published in the Federal Register on or around December 1, 2016, announcing the availability of the 2017 Title III and Title V eligibility designations and the waiver application deadline.

Note: Historically Black Colleges and Universities (HBCUs), Tribally Controlled Colleges and Universities (TCCUs), and institutions with an active Title III or Title V grant (current throughout Federal Fiscal Year 2017) automatically qualify for the waiver of the Campus-Based non-federal share requirement. These waivers are granted unless Federal Student Aid’s Grants and Campus-Based Programs Division receives information from OPE/IS that the institution has lost its grant funding and/or HBCU or TCCU status.

For questions about Title III or Title V eligibility, contact:

Christopher Smith
Tel: (202) 453-7946
Jason Cottrell
Tel: (202) 453-7530

Pre-Majors or Pre-Programs

We have had lots of questions of late around “pre” programs (pre-biology, pre-nursing, etc.) and how Title IV aid is affected.

Policy recently provided some guidance to NASFAA that I wanted to share with my SASFAA schools.

  • An otherwise eligible student enrolled in a “pre-program” (includes pre-majors) may be considered a regular student enrolled in an eligible program if, provided the appropriate academic requirements are met, enrollment in the pre-program assures the student admission to the full program at a later point. If this is the case, we would consider the “pre-program” to be the first part of the formal program in which the student will ultimately matriculate. This is similar to how we treat “undeclared” students enrolled in degree programs.
  • However, if admission to the “pre-program” does NOT (presuming the student has met all applicable academic requirements) guarantee admission to the actual or formal program, then we treat the “pre-program” as not considered leading to a credential, and therefore not an eligible program. For example, a pre-nursing program consists entirely of coursework acceptable toward completion of a BSN program at the institution. Students must successfully complete all of these courses with a grade of “B” or higher, and pass a written exam in order to transition into the BSN program. However, admission of even those pre-nursing students who have met all academic requirements is contingent on the availability of clinical slots, with the result that not all of them will matriculate into the BSN program. Accordingly, students who successfully complete the pre-nursing requirements must apply to the BSN program with no guarantee of acceptance. Those students who are not admitted to the BSN program will have effectively been “parked” in a program that does not lead to a degree or other credential and is therefore not an eligible program.
  • This guidance does not, in any way, obviate the requirement that, to be eligible, a student must be enrolled as a regular student in an eligible program. In this regard you could draw an equivalency to undeclared students in a BA/BS program. That is, with a few exceptions (teacher certification, preparatory coursework etc.) a student must always be enrolled in an eligible program. Hence the reason for requiring that, provided the student meets all of the academic requirements while in the pre-major, he or she is admitted into the full program. In that way the student really can be considered to have been enrolled in the eligible program throughout. As stated in our response, the pre-program then becomes part of the formal program. It has always been permissible for a program to have associated with it, enrollment which is conditional to the extent that certain academic standards must be achieved in order to remain in that program-perhaps an exam at a certain point. However, if a student meets all academic requirements and is then told she will not be admitted to the full program, that student is considered to have not been enrolled in an eligible program while in the pre-major.

I hope everyone has a wonderful Thanksgiving. We have lots to be thankful for and it is nice to take a moment and remember all the good things in our lives…even if that good thing is a FED!

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