Do I really need to review every ISIR transaction?
Often we look for shortcuts or quicker ways to complete our daily tasks, but reviewing every Institutional Student Information Record (ISIR) is one step we cannot skip. As Financial Aid Administrators (FAAs) we have an obligation to ensure the right aid is going to the right student. This includes carefully reviewing each ISIR transaction, even if all aid is already disbursed.
Why do I get multiple ISIR transactions?
There are three types of ISIRs; Daily, Requested and Pushed. Daily ISIRs are generated in response to new applications or corrections. Requested ISIRs are generated by you, the FAA. These are the ISIRs you specifically request. The third type, Pushed ISIRs are generated by the Central Processing System (CPS). Knowing the type of ISIR could help determine the best way to review.
Why do I need to review all ISIRs?
Each ISIR transaction is generated due to a change, update or correction. It is important that you review for changes in EFC, C flags and NSLDS information. You also need to check for any updates or corrections to the student and/or parent information. Multiple ISIRs could reveal conflicting information that needs to be resolved. Per federal regulations (34 CFR 668.16 (f)): An institution must develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for financial aid under Title IV, HEA programs. In determining whether the institution’s system is adequate, the Secretary considers whether the institution obtains and reviews:
- All student aid applications, need analysis documents, Statements of Educational Purpose, Statements of Registration Status, and eligibility notification documents presented by or on behalf of each applicant.
See also Volume 2, Chapter 3 of the Federal Student Aid Handbook: FSA Administrative & Related Requirements.
True or False: Since I’ve already verified the student’s file, I do not need to review her subsequent ISIR transaction.
False! Per Chapter 5 of the Application and Verification Guide (FSA HB June 2015: AVG-125), you are generally required to review all subsequent transactions for a student for the entire processing year even if you verified an earlier transaction. You must review the ISIR transaction for any conflicting information and should check for updates and/or corrections. If the EFC has not changed and there are no changes in the C flag or NSLDS information, no action is generally required. If the EFC does change but it either doesn’t affect the amount and type of aid received or the data elements that changed were already verified, no action is required. But if the EFC changes and the pertinent data elements were not verified, then you must investigate. Of course, any time the C flag changes or NSLDS data have been modified, you must fix any issues. The Department of Education regulations are clear that any conflicting information has to be resolved. Your actions will vary depending on the change. Keep in mind that your Student Information System may determine automatically which ISIR transaction is “active” in your system, but it is still the school’s responsibility to review for accuracy, then package and disburse off of the correct transaction.
True or False: Since I’ve already disbursed federal aid to the student, I do not need to review his subsequent ISIR transaction.
False! You may not disburse aid until conflicting info is resolved, and may need to recalculate aid that has been disbursed if the resolution results in eligibility change. If you discover a discrepancy after disbursing FSA funds, you must reconcile the conflicting information and require the student to repay any aid for which he wasn’t eligible, unless he is no longer enrolled for the award year and will not re-enroll.
Keep in mind that regulations on conflicting information do not distinguish between information that a school receives as a result of its own request and that which is unsolicited. ED has a broad definition of “received.” If anyone working in an official capacity at the institution receives information — via e-mail, regular mail, fax or in person — the information is considered received for financial aid purposes. A common question regarding conflicting information is: “May I ignore or shred unsolicited documents?” The school is not permitted to ignore or shred documents that may substantiate a students’ eligibility for federal aid.
Devoting resources to reviewing the subsequent ISIR transactions is important, not only for accuracy in awarding, but it could also save you from an audit finding! Happy reviewing!
2015-2016 Application and Verification Guide, Chapter 5 http://www.ifap.ed.gov/fsahandbook/attachments/1516AVGCh5.pdf
Federal Student Aid Handbook, Volume 1, Chapter 1
Federal Student Aid Handbook, Volume 2, Chapter 3
2015-2016 ISIR Guide
FSA’s online review of conflicting information policies
Department of Education presentation: Welcome to Applicant Data Resolution Part One
2006 FSA Conference Session 34 “The Institutional Information Record (ISIR)”
34 CFR 668.16(b)(3) and (f) – Standards of Administrative Capability: Conflicting Information
USA Funds Conflicting Information Webcast Manual and PPTs
This Tip of the Month was provided by your RMASFAA Training Committee