Skip to content

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.

Students Intimidated by The FAFSA? This Worksheet May Help.

February 24, 2017

FAFSA deadlines are approaching across the country, which can leave many students (current or potential) biting their nails. With questions stacked on top of questions, the FAFSA can seem intimidating and many students may worry about not having all the information they need when they log in to fill out the form.

To those students, we say, “Have no fear, the FAFSA on the Web Worksheet is here.” (Financial Aid Awareness Month apparently feeds our rhyming side.)

The FAFSA on the Web Worksheet provides students with a preview of the questions that they may be asked when completing the FAFSA online. The printable form allows students to gather information at their own pace in order to have it ready to enter online at a later time.

Please feel free to share the FAFSA on the Web Worksheet with your students.

Latest from FSA: New Street Address for Mailing Paper Master Promissory Notes and Endorser Addenda

February 22, 2017

FSA recently announced that the street addresses for mailing paper Master Promissory Notes (MPNs) and Endorser Addenda will change on March 24, 2017. These address changes will affect documents sent via express and overnight delivery, and via regular postal mail.

The new address information follows:


FSA’s announcement further details the impact of these changes, noting that “Schools using the electronic version of the forms on the website are not impacted.”

Read FSA’s original release for more details.

Latest from FSA: Guide to Federal Student Aid Available for Download

February 16, 2017

Many students have questions about Federal Student Aid. Lots and lots of questions. FSA is here to help with its downloadable Guide to Federal Student Aid 2017-18.

The guide addresses many questions students may have about the Federal student aid process, including:

  • Where does my FAFSA information go once I submit it?
  • Should I accept all of the aid I’m offered?
  • How will I receive my aid?

The guide also includes an in-depth breakdown of different types of Federal Student Aid, including Grants, Work Study, and Loans.

Please share The Guide to Federal Student Aid 2017-18 with your students.

Celebrate Financial Aid Awareness Month with Resources from our Library

February 14, 2017


February is Financial Aid Awareness Month and we encourage you to celebrate. How? Streamers, confetti, and cake are a good start.

That said, the one integral piece of your celebration is Nelnet’s Resource Library. Our library offers helpful PDFs, videos, and recorded webinars that cover a wide range of financial aid topics. Many PDFs can be downloaded in color or black and white, and several are available in both English and Spanish.

A few popular resources in our library include:

  • Our Interest Rate Flyer covers Federal Direct Stafford and PLUS Loans first disbursed on or after July 1, 2016 and prior to July 1, 2017.
  • Our Loan Repayment Plan Comparison spells out eligibility, loan terms, advantages, and other good-to-know details.
  • Our Servicer Contact Information Sheet allows borrowers to keep all of their important student loan information in one place, including servicer contact information, account numbers, loan amounts, and more.

For these resources, and many more, check out our Resource Library.

Happy Financial Aid Awareness Month!

Nelnet’s Brand Used in Phishing Scam

February 7, 2017
tags: ,

We are aware of a phishing scam that involves consumers (not exclusively Nelnet borrowers) receiving an email from an individual claiming to be from Nelnet. In the email, the individual claims to work for Nelnet’s recruiting team and asks consumers for personal information.

Please be aware that these emails are not legitimate communications from Nelnet. They don’t represent how we approach recruiting new team members and they should immediately be deleted.

We are aware of these phishing attempts using the Nelnet name and we apologize for any inconvenience they may cause.

A portion of the phishing email text follows:



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.