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Ask a Fed: Verification, 399, CDRs, and Training

March 1, 2017

Federal Training Officer David Bartnicki recently shared these updates:


Federal Training Officer David Bartnicki

Title IV information:

Usually I am able to provide some insight into various Title IV topics but due to our current period of transition I am limited in my discussions.  Consistent with prior Administration transitions, it takes a little time to bring new leadership up to speed on the issues of the Department. The new Administration has now begun their review of issues. As soon as the briefing sessions are complete with the new Administration, we expect to have a full complement of federal student aid topics and Federal Update sessions at upcoming conferences. 

Please note that you may ask me a question on a certain topic like GE, state authorizations, borrower defense or other newer regulations that I may not be able to provide guidance on at this time.  With that said I am simply going to point out some new information on IFAP.  Please make sure you are staying up on the latest and greatest EAs, DCLs, manuals, and FSA HDBK sections updated on IFAP.

399 Codes

As a reminder we implemented two key changes to the CPS on February 5, 2017 to modify the assignment of SAR comment code 399 to 2017-2018 records:

  • For students with an automatic-zero EFC for 2017-2018, the CPS will now compare financial information provided for 2017-2018 to the student’s 2016-2017 financial information; SAR comment code 399 will only be assigned to the transaction if the EFC difference calculated by the CPS is over a certain threshold.
  • We added a condition for student records with a professional judgement on the 2016-2017 transaction to be excluded from the cross-year edits that set SAR comment code 399.

Affected ISIRs were reprocessed on February 6, 2017.  For more information on this reprocessing, including specific ISIR identification, please see the January 30, 2017 electronic announcement.  

Pell Grant Reconciliation

We often discuss Direct Loan reconciliation but please do not forget the importance of Pell Grant reconciliation.  On February 7, 2017 ED posted an electronic announcement reminding schools of the importance and necessity of reconciling their Pell funds.  The EA reviews common definitions, deadlines and basic processes.  For more information, please see the February 7, 2017 electronic announcement.

FY 2014 3-Year Draft Cohort Default Rates

On February 27, 2017, the Department of Education distributed the FY 2014 3-Year Draft cohort default rate (CDR) notification packages to all eligible domestic and foreign schools only.  Please note that the time period for appealing the FY 2014 3-Year Draft Cohort Default Rates under 34 C.F.R Part 668, Subpart N begins on Tuesday, March 7, 2017 for all schools.  This challenge period is extremely important and can impact your final CDRs.

For more information on the CDR distribution protocol, the challenge process and contact information, please see the February 27, 2017 electronic announcement.


The most asked question I currently receive around verification is what documentation is allowed to verify a nonfiler with the IRS.  I am happy to announce that on February 23, 2017, ED posted an electronic announcement and chart that shows the methods by which an individual can request and receive verification documents from the IRS, including documents that can be used to support nonfilers.  The chart provides information about the verification documents that can be requested from the IRS, the IRS document or response that will result from each request, where the response will be sent, and an estimate of the time for the IRS to respond to the request.

For more information please review the February 23, 2017 electronic announcement and chart.


In case you missed it, I wanted to bring your attention to ANN-17-01 which discusses some new training on our Federal Student Aid E-Training website, located at  This letter announces the availability of a new FSA Coach course for 2016-2017. The Intermediate Training course is designed for more experienced financial aid administrators and includes a closer look at packaging awards, Return of Title IV Funds (R2T4), Direct Subsidized Loan interest benefits, monitoring Pell Grant Lifetime Eligibility Used (LEU), resolving Unusual Enrollment History flags, and administering federal student aid in nonstandard terms.

For more information regarding the training modules and training access, please see ANN-17-01.

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