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

January 31, 2017

Federal Training Officer David Bartnicki recently provided these updates:bartnicki

Gainful Employment

I am pleased to announce that the 2017 GE disclosure template is now available and must be used by schools to update their GE program disclosures by April 3, 2017. The new template contains the new disclosures and modifications to existing disclosures. 

Some of the disclosure items for the 2017 template will not be from the most recently completed award year. The completion rate calculated on the 2017 template is based on the most recent cohort of students for whom sufficient time has passed for the cohort to complete the program within its scheduled length. 

In addition, generally, information to be reported on the 2017 GE Disclosure Template will be for students who are Title IV recipients. The one exception is for calculating the percentage of students who, during the most recently completed award year, borrowed for attendance in the GE program. That cohort is the number of individuals, both Title IV and non-Title IV recipients, who were enrolled in the GE program between July 1, 2015 and June 30, 2016.

Please note that certain warnings will have to be provided to prospective and enrolled students if the GE program, based upon the GE rates, is in danger of losing eligibility (GE EA #99/#101). However, separate from warnings, all schools will now have to distribute the 2017 GE Disclosure Template to prospective students as a separate document before the student signs an enrollment agreement, completes registration, or makes any financial commitment to the institution. 

For more information please review the January 19, 2017 GE electronic announcement #103.

In addition, remember that if you plan on appealing any final GE rates based on alternative earnings, please be sure to turn in all documents by the March 10, 2017 deadline. For more information, please see the GE Electronic Announcement #101.

FSA Training Conference

In case you missed it, FSA has announced that the 2017 FSA Training Conference for Financial Aid Professionals will be held from Tuesday, November 28 to Friday, December 1, 2017 at the Walt Disney World Swan and Dolphin in Orlando, Florida. We are extremely lucky that we will have this great conference held in the SASFAA region two years in a row. I hope many in the SASFAA region will be able to attend. Hotel and registration information will be coming out later this summer. For more information please see our conference website.


The Department recently posted the 2017-2018 Tax Return Transcript Matrix. Aside from a few date updates, the matrix is essentially the same as the 2016-2017 Matrix since we are using the 2015 tax year for both award years. The matrix is a cross-walk of FAFSA questions, tax transcript line items, and tax return data to help a school verify verification tracking group income items. 

Please see the January 12, 2017 electronic announcement and attached matrix for more information.

In addition, ED posted new and revised verification Q&A’s on the program integrity website (upper right-hand side of IFAP). A couple key Q&A’s are highlighted below:

  • DOC-Q18. Must an institution complete verification for students placed in verification groups V4 or V5 who are only eligible for unsubsidized student financial assistance?
  • DOC-A18. An institution should verify only high school completion and identity/statement of educational purpose for a student who is only eligible for unsubsidized student financial assistance and who was placed in Verification Tracking Groups V4 or V5 (see the exception for high school completion for a graduate student under Q&A DOC-Q31/A31). This will help ensure that only eligible students receive aid and will improve the integrity of the Title IV, HEA programs. Institutions need not verify any of the other FAFSA information listed under Verification Tracking Group V5 for such students. [Guidance issued 04/25/2013; revised 1/13/2017]
  • DOC-Q30. The Department has provided guidance on how to obtain verification of non-filing from the IRS. What do individuals who are subject to foreign tax authorities do?
  • DOC-A30. If another tax authority can provide documentation similar to the IRS that indicates the individual did not file taxes for the appropriate tax year, we expect the individual to request such documentation and provide it to the institution. If such documentation does not exist, or if the individual is unable to obtain the documentation, the institution may accept a signed and dated statement from the individual stating either that the tax authority does not provide such documentation or that the individual was unable to obtain the documentation after contacting the tax authority.

Since nontax filers selected for verification are already required to provide a signed and dated statement related to their claim of being a nonfiler, those nontax filers may also include in that statement the attestation specified above. [Guidance issued 1/13/2017; and applies beginning with the 2017-2018 award year]

  • DOC-Q31. Must an institution collect documentation of an applicant’s high school completion status for graduate students placed in Verification Tracking Groups V4 or V5?
  • DOC-A31. An institution is not required to collect proof of high school status if admission into the graduate program requires the completion of at least two years of undergraduate coursework as provided in Q&A RED-Q1/A1. [Guidance issued 1/13/2017]

Updated guidance on IRS documents acceptable to verify nonfiling statuses will be forthcoming. We are looking to be as flexible as possible. Please stay tuned to IFAP.

Enrollment Status in Graduate Program

Policy recently clarified that a school decides what the full-time credit enrollment definition is for all students in a graduate program and that the full-time definition can be different in the summer term, then in the regular academic year terms (i.e. fall and spring). In either case, half-time enrollment must be one-half of the number of credits determined to constitute full-time enrollment.

399 Code

I am continuing to get lots of questions around why the 399 code is appearing when all of the DRT items appear the same in both award years (16/17 and 17/18). Please remember that the 399 code can appear when any of the FAFSA items related to income and required to be from the 2015 tax year (child support paid, other untaxed income, IEFW, etc.) differ between 16/17 and 17/18 and causes a significant impact on the EFC. The 399 code is impacted by more than differences in the DRT items.

In addition, ED is working to provide updated guidance and processing with the 399 code on PJ situations and Autozero scenarios. Updated information should be posted to IFAP in the near future.

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