There is a Flag on the ISIR

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By Robin Getzelman and Scott Elesh, CPA

Just like in football, when there is a flag on the field there is a foul play. Under the FAA Information section of the ISIR (Institutional Student Information Record) it will also indicate “foul play” with a flag. The flag will show “plays” of rejected codes, match flags, intermediate values, etc. Some flags are more common than others, and in the 2012 – 2013 and 2013 – 2014 award years new flags, new values, and new fields are being used on the ISIR.

Starting on July 1, 2012 students enrolling in higher education are required to have a high school diploma or recognized equivalent to be eligible for federal student aid. If the high school information reported is not successfully matched to the valid high school file the ISIR will have a “Y”, which means the High School Flag is in play. Remember just because the high school was not matched does not automatically mean that the high school is invalid. The school is responsible for determining if the student has a valid high school diploma.

In the 2012 – 2013 award year new limits were placed on the amount of Federal Pell Grant funds a student may receive over his or her lifetime. The new limit is equal to six years of full funding. Since the maximum amount receivable in each year is equal to 100%, the six year equivalent is 600%. The two flags that are thrown on to the ISIR include Pell Eligible Flag and Overpayment Flag. These flags are not new; however with the changed requirement they are flags to avoid by tracking the amount and rate of Federal Pell awarded per student. The Pell Eligible Flag states if the student is eligible with a “Y” or is not eligible (blank) for the Federal Pell. The student will receive a “Y” to confirm they are eligible for the Federal Pell grant if the student correctly indicates on the FAFSA they are an undergraduate student and based upon the student’s EFC they are eligible for Pell.

The Overpayment Flag fields for Pell Grant, FSEOG, Perkins, etc. will contain a “Y” where an overpayment exists. When this occurs the school will have access to the NSLDS for more information because it is possible to have more than one overpayment exist within a specific aid type. If the student does not have any overpayments next to the specific aid type it will have “N/A”.

Another change to the ISIR flags for the 2012 – 2013 award year is the two fields that are options for the Student IRS Request Flag and Parent IRS Request Flag. The two values are “05” for presented with the option to use the IRS Data Retrieval Tool in FAFSA on the Web, but did not elect to use it, and “06” for IRS data was transferred from the IRS, but a subsequent change made him or her ineligible to use the IRS Data Retrieval Tool. This tool allows students and parents to access their IRS tax return information to fill out the FAFSA. The students who are ineligible for using this tool are student and/or parents who are Married Filing s=Separately, Married and filed as Head of Household, any amended tax returns, or filed a foreign tax return. If the tax returns were filed in the last three weeks or filed by paper instead of electronically the student may have to wait to use the IRS Data Retrieval Tool or enter the information in manually.

In award year 2013 – 2014 there is a new field on the ISIR called, Pell Lifetime Eligibility Used (“LEU”) which will provide a percentage (in the format of 9999.999%) of the total Pell Grant eligibility already used. To go along with this new field, a new flag will be presented, the Pell Lifetime Limit Flag. When the LEU percentage is close to or has exceeded the student’s total Pell Grant eligibility limit the following flag values will be displayed; the values include “C” Close to Pell limit, “E” Met or Exceeded Pell limit, “H” High Pell percentage, “N” No problem or it is blank meaning record not sent for match.

For the 2013 – 2014 award year a new field, Unusual Enrollment History, has been added to the NSLDS Financial Aid History section. There are five flag values, “N”, “Blank”, “1”, “2”, and “3”. A value of “2” indicates a possible enrollment pattern problem which the school may need to resolve; a value of “3” indicates a questionable enrollment patter the school must resolve. If there is an “N” or the field is blank no action from the school is required.

In order to avoid flags on your students’ ISIR make sure that students are educated on filling out their FAFSA and use the different tools that are made available to them on the FAFSA website, including the IRS Data Retrieval Tool. In football, less flags on a team usually leads to a higher winning percentage. In financial aid, less flags on an ISIR usually leads to a more efficient administration of Title IV and less findings come audit time. Now that’s a real win!  For further information, contact Robin Getzelman at rgetzelman@koscpa.com, Scott Elesh at selesh@koscpa.com  or call 847.580.4100.