RESOLVING “C” CODES ON INSTITUTIONAL STUDENT INFORMATION RECORDS

RESOLVING “C” CODES ON INSTITUTIONAL STUDENT INFORMATION RECORDS (ISIRS) Tonya R. Hsiung Assistant Director of Financial Aid Franklin & Marshall College

PROCESS OF FILING A FAFSA Paper FAFSA FAFSA Processor FAFSA on the Web FAA Access to CPS Online Central Processing System (CPS) Student Aid Report EFC ISIR EFC Data Matches Social Security DHS NSLDS DOD DOJ Selective Service Veterans Affairs

WHAT ARE “C” CODES? The “C” code is generated by the CPS as an indicator, in addition to comment codes, and match flags, when FAA resolution is required on results from data matches.

SEVEN (7) C-CODE AREAS 1. 2. 3. 4. 5. 6. 7. Selective Service Match Department of Homeland Security (DHS) Match Social Security Administration (SSA) Citizenship Status Social Security Number Match Veterans Affairs Status Match National Student Loan Database System (NSLDS) & Overpayments of Federal Grants Drug Conviction Question

SELECTIVE SERVICE Comment 30: Applicant not in Selective Service database Student must answer question, “Are you male or female” – if s/he does not, it is assumed s/he is male and the record will go through match with Selective Service – if no match – a C-Code is generated, regardless of gender Male students, ages 18 - 25 are required to register with Selective Service. Females are not required to register Any student who is born before 1960, is not required to register. You can satisfy the C-Code by: Verifying registration at www.sss.gov Obtaining a copy of the student’s Selective Service Registration card – this happens in the cases of misspellings on registration. Receive a letter from Selective Service that student was not required to register.

SELECTIVE SERVICE Comment 33/57: Registration not conducted because of missing information, out of age range, or did not confirm he is male Submit correction with missing information to CPS – must have student’s name, SSN, DOB, Signature, indicated gender as “male” Register with Selective Service at www.sss.gov Present appropriate confirmation of registration to FAA If student is over 26 – he must get confirmation he was not required to register when he was between ages 18 and 25. If he cannot get this confirmation, he will not be eligible for Federal Aid!

DHS Comment 144 – DHS did not confirm eligible non-citizen claim (Item 14) Wait for results from automated/CPS secondary confirmation. Not eligible until otherwise notified. The process usually takes about two weeks – you will get a new transaction from CPS. Comment 141 – Applicant changed response to citizenship question (Item 14) or Alien Registration Number (Item 15) Submit proof of citizenship to the financial aid office

DHS Comment 142 - Invalid or missing Alien Registration Number (DHS could not confirm noncitizen status) Submit proof to financial aid office within 30 days or may lose federal aid eligibility – update Alien Registration Number and send correction to CPS Comment 105 – in continuance at DHS Wait ten business days for another ISIR with updated status. If no response, conduct paper (G-845) Secondary Confirmation process.

DHS Comment 46 – DHS did not confirm eligibility Begin paper (G-845) Secondary Confirmation process. Comment 109 – DHS needs additional information Begin paper (G-845) Secondary Confirmation process.

DHS CITIZENSHIP PROOF Documents acceptable to establish student’s Citizenship: U.S. Passport – current or expired – cannot accept “limited passports” Birth Certificate – from a state in the U.S. Certificate of Citizenship Certificate of Naturalization See FSA Handbook, Volume 1, Chapter 2 for more information

ELIGIBLE NON-CITIZEN PROOF Documents acceptable to establish a student is an Eligible Non-Citizen: Permanent Resident Card Alien Registration Receipt Card (I-151) Resident Alien Card (I-551) Be sure the A# number on cards match the number provided on FAFSA – if not, update it to the correct number and the C-Code flag should be removed. See FSA Handbook, Volume 1, Chapter 2 for more information

SOCIAL SECURITY ADMINISTRATION CITIZENSHIP STATUS When applicant indicates U.S. Citizen on FAFSA Comment 146 – SSA did not confirm Citizenship status Collect documentation that proves citizenship U.S. Citizens born abroad, usually to military, State Department or Foreign Service parents generally have a valid birth certificate. SSA does not automatically update their database with this information If eligible non-citizen, submit correction to CPS with appropriate status and Alien Registration Number

SOCIAL SECURITY NUMBER MATCH Comment 63 – Date of Birth (Item 9) inconsistent with SSA records If incorrect, submit date of birth correction to CPS If correct, student must Contact SSA 1-800-772-1213 or www.socialsecurity.gov to update information. Supply FAA with proof of DOB (birth certificate, driver’s license) Comment 64 – Name inconsistent with SSA records If incorrect, submit name correction to CPS Supply FAA with documentation explaining discrepancy Most often this is due to marriage – would need copy of marriage certificate Copy or court order if it was due to a legal name change not through marriage Sometimes it is caused because student transposed first and last name – you can correct this and send correction to CPS, which should fix the problem.

VETERANS AFFAIRS STATUS MATCH Comment 162 and 173 – VA did not confirm Veteran status, so CPS assumes Dependent status If student believes this is an error – s/he needs to contact a regional VA office to have VA records updated. White student is resolving discrepancy with VA, FAA can collect documentation that student is a veteran of the U.S. Armed Forces (DD214). DD-214 must show “Character of Service” is other than “dishonorable.” Student must have been on active duty for purposes other than training. May have to process a dependency override to push record through as independent student. If student does not meet requirements, must update the Veteran question to “no” and provide parental information and signature.

DEPARTMENT OF VETERANS AFFAIRS Comment 180 – Applicant is on active duty and CPS assumes Dependent status Student must provide documentation to the school that shows upcoming release orders from a military branch, typically in memorandum format or letter, stating intent to release. There is no requirement to reconfirm actual separation during the award year.

NSLDS C-CODES Comment Codes Categories Potential Overpayments (133) ACG Codes: 240, 241, 242, 243, 244, 246 Pell Codes: 020, 038, 039, 041, 042, 043, 346, 347 FSEOG Codes: 010, 065, 066, 067, 077, 079 Perkins Codes: 086, 090, 100, 101, 102, 107 National SMART Codes: 261, 262, 263, 264, 265, 266 TEACH Codes: 289, 290, 291, 292, 293, 294 Iraq/Afghanistan Codes: 309, 310, 311, 312, 313, 314 Unusual Enrollment History: 359, 360 Loan Codes Default: 124, 132, 134, 135, 136 Discharge: 115 Active Bankruptcy: 116 Loan Limit Reviews: 254, 255, 256, 260 MOST COMMON CODES REVIEWED ON NEXT SLIDES

POTENTIAL OVERPAYMENT Comment 133 – Applicant received overpayment of federal student aid funds and are required to repay the money FAA must contact the school associated with the overpayment. The FAA may have to access NSLDS for additional information. If held by Department of Education (DOE), applicant must contact DOE for guidance on how to resolve.

POTENTIAL OVERPAYMENT-PELL LEU Comment 346 – Applicant’s Pell Lifetime Eligibility Used (LEU) amount is close to the Pell limit (600%) Check NSLDS or COD for percentage used and adjust Pell, if necessary, to not exceed 600% LEU used. Comment 347 – Applicant’s Pell Lifetime Eligibility Used (LEU) amount is met or has exceeded the limit (600%) Check NSLDS or COD for percentage used and adjust Pell, if necessary, to not exceed 600% LEU used.

NSLDS - UNUSUAL ENROLLMENT HISTORY See Dear Colleague Letter GEN 13-09 Comment 359 Unusual Enrollment History (NSLDS UEH Flag 2) The institution must review the student’s enrollment and financial aid records to determine if, during the three award year review period (i.e. for 2013-2014 review 2010-11, 2011-12, 2012-13), the student received a Pell Grant at the institution that is performing the review. If yes, no additional action is required unless the institution has reason to believe that the student is one who remains enrolled just enough to collect student aid funds. In this case, the institution must follow the guidance that is provided for a UEH Flag 3. If not, the institution must follow the guidance provided for a UEH Flag 3

NSLDS - UNUSUAL ENROLLMENT HISTORY Comment 360 Unusual Enrollment History (NSLDS UEH Flag 3) The institution must review the student’s academic records to determine if the student received academic credit at the institutions the student attended during the three award year period (i.e. for 2013-2014 review 201011, 2011-12, 2012-13). Using information from NSLDS, the institution must identify the institutions where the student received Pell Grant funding over the past three award years. Based upon academic transcripts or grade reports, the institution must determine, for each of the previously attended institutions, whether academic credit was earned during the award year in which the student received Pell grant funds. Academic credit is considered to have been earned if the academic records show the student completed any credit or clock hours.

UEH SAMPLE FORMS Baker College Ivy Tech Community College Metropolitan State University of Denver Solano Community College University of Houston Virginia Western Community College Wayne State

NSLDS C-CODES Comment 138 – SSN match, but name and DOB did not match Access NSLDS online to determine if NSLDS data is for the applicant. If so, determine student aid eligibility based on NSLDS data If not, award process can continue while appropriate data provider updates NSLDS – you do not need to wait for NSLDS to be updated Sometimes you may need to send documentation to NSLDS to resolve the conflicting information – they will issue you a ticket # and give you a fax number to send the documents to – they will notify you when it is resolved – usually by email. NSLDS Customer Support is available for help: 1800-999-8219

NSLDS – LOAN DEFAULT Comment 132 – Applicant has at least one loan in default. Applicant needs to contact the Guaranty Agency, Direct Loan Servicers or ED Regions that are holding the defaulted loan(s) to make satisfactory arrangements to repay. Appropriate contacts are indicated in ISIR comment text/codes. You can view the defaulted loan(s) and get contact information on the NSLDS website as well. Collect documentation of satisfactory repayment arrangements. If loan is already repaid, collect documentation showing payoff information.

NSLDS – LOAN DEFAULT Comment 134 – Applicant has at least one federal loan in Default and has receive at least one overpayment of federal student aid funds. Student is NOT eligible to receive any federal aid funds until these items have been resolved. Loan holder information and School codes are provided on ISIR comments or NSLDS Aid History page. See guidance for comments 132 and 133

NSLDS – LOAN BANKRUPTCY Comment 116 – Applicant has at least one loan in Active Bankruptcy If the loan is defaulted, borrower must provide FAA with documentation from the holder stating that the debt is dischargeable. If the loan was not defaulted, documentation is not required.

NSLDS - LOAN LIMIT REVIEWS Comment 254 – Based on database provided by NSLDS and your reported grade level, student may have received subsidized student loans in excess of loan limits established for the federal loan programs. Comment 255/260 – Based on database provided by NSLDS and your reported grade level, student may have received a total amount of undergraduate student loans that exceeds the loan limits established for the federal loan programs.

NSLDS - LOAN LIMIT REVIEWS Comments 256 - Based on database provided by NSLDS and your reported grade level, student may have received a total amount of student loans (undergraduate and graduate) that exceeds the loan limits established for the federal loan programs. Determine if student is dependent or independent, if independent, check based on undergraduate or graduate with new loan limits. If dependent and there are Parent PLUS loan denials, check limits. If ok, process aid as student is eligible. (Excel Spreadsheets for ease of calculation)

RESPONSE TO QUESTION 31-DRUG QUESTION Question pertains to drug conviction Only pertains to convictions while receiving federal aid funds Students are required to answer this question If left blank – it is assumed “Yes” Comment Code (053) Student can update FAFSA with an answer

RESPONSE TO QUESTION 31-DRUG QUESTION Comment 056/058 - Applicant reported a drug conviction, or doesn’t know If response in incorrect, submit correction to CPS. Student can complete worksheet provided by Department of Education to determine eligibility for federal aid – we usually send that form to students and keep a copy in their file. Not eligible unless applicant completes an acceptable drug rehabilitation program: program that includes at least two unannounced drug tests, and receives, received or qualifies to receive funds from a federal, state or local government program; is recognized by a federal, state or local government program; receives, received or qualifies to receive payment from a federal or state licensed hospital, health clinic or medical doctor.

PREVENTATIVE MEASURES FAFSA Completion Day – obtain free help in completing the FAFSA Open Houses / Financial Aid Nights – warn students and parents about the importance of completing the forms with accurate information or it could delay the processing of the student’s aid. If parents and/or students have questions – they should contact FAA.

CONTACT INFORMATION Department of Education (DOE): 1-800-621-3115 NSLDS for FAAs: 1-800-999-8219 www.NSLDSfap.ed.gov COD Customer Service (Grants): 1800-474-7268 COD Customer Service (Loans): 1800-848-0978

QUESTIONS? Tonya R. Hsiung Assistant Director of Financial Aid Franklin & Marshall College 717-291-4395 [email protected]