Resolving Conflicting Information | Knowledge Center (2024)

This Electronic Announcement clarifies a number of instances when institutions are required to identify and resolve conflicting information and discrepant data that would affect a student’s eligibility for Title IV funds, especially pertaining to the 2024-25 award year and FAFSA processing year.

In order to meet the standards for administrative capability at § 34 CFR 668.16(f), a school must have an adequate internal system to identify conflicting information that would affect a student’s eligibility. An institution is required to resolve conflicting information regardless of the source or whether the student is selected for verification. Common examples of conflicting information include questions on the status of a student’s high school diploma, academic progress, enrollment, and tax filing status. It can also arise from other offices such as admissions, the registrar, or academic affairs. If your school has conflicting information concerning a student’s eligibility or you have any reason to believe the student’s application information is incorrect, you must resolve the discrepancies before disbursing Title IV funds. If you discover discrepancies after disbursing Title IV funds, you must still reconcile the conflicting information and take appropriate action under the specific program requirements. Depending on the outcome, funds may have to be returned.

Though the requirements surrounding a school’s requirement to resolve conflicting information have not changed, the U.S. Department of Education (the Department) acknowledges the unique circ*mstances institutions are facing for the 2024-25 FAFSA processing year and announced in Electronic Announcement (GENERAL-24-11) that it would be significantly reducing verification requirements, while continuing key measures focused on avoiding identity fraud. The Department reminds institutions that they have the authority to select any Institutional Student Information Record (ISIR) for verification if they suspect incorrect information or to resolve conflicting information.

As announced in Electronic Announcement (GENERAL-24-29), the Department identified data issues that resulted from data received from the IRS via the FUTURE Act Direct Data Exchange (FA-DDX) that impacted a subset of FAFSA forms. The Department has also previously noted ISIRs that were impacted by calculation errors within the FAFSA Processing System (FPS). The following issues do not create conflicting information for the 2024-25 award year:

The Department has received questions from schools regarding instances when FTI and manually entered tax and income information is present on the same ISIR, but the manually entered information was used instead of the FTI to calculate the student’s SAI. To clarify, there are circ*mstances where this occurrence is not conflicting information, and other circ*mstances where it may be.

There are certain circ*mstances in which manually entered tax and income information and FTI may be present on the same ISIR based on the student’s or contributor’s marital status, including in the following scenarios:

In the circ*mstances described above, the manually entered information is not conflicting information.

There are instances where FTI indicates that a student is a “non-filer,” but the student indicates they have foreign income. In these circ*mstances, the ISIR would have the IRS Response code of 214 (did not file) along with self-reported tax and income data.

However, some schools have observed situations where it appears that an applicant or contributor who had FTI data reported on the ISIR also manually indicated that they did not file a U.S. tax return in 2022, resulting in a SAI and Pell Grant calculation based on the manually entered non-filing status. The FAFSA Processing System (FPS) does not use the FTI in the SAI and Pell eligibility calculations for students that incorrectly indicated “did not file” when FTI is transferred. If this occurs and the data indicates that the person is a U.S. tax filer, but the appropriate FTI was not used in the SAI calculation, schools should consider these cases as conflicting information that must be resolved.

When resolving the conflicting information, a school may use the FTI retrieved from the IRS via the FA-DDX to correct the manually entered income and tax information by re-entering the FTI in the appropriate manual entry data fields and submitting the correction to FPS. Schools must update all the manual entry data fields associated with the taxes, including tax filing status. Changing the tax filing status from “did not file” to “filed” is not enough to trigger FPS to use the FTI in the student’s calculations.

More information on the requirements around resolving conflicting information are outlined in Chapter 5 of the Application and Verification Guide in the Federal Student Aid Handbook.

The Department’s has also received questions about scenarios when the amount of taxable grants and scholarships manually reported by an individual on the FAFSA form is equal to their AGI. Similar to manually entered income information, there are circ*mstances where this occurrence is not conflicting information, and other circ*mstances where it may be depending on other information in the institution’s possession. Although it is uncommon, it is possible for a student, or their contributor, to have grants, scholarships, or AmeriCorps benefits as their only sources of taxable income. While schools are not required to select FAFSA records for verification that report a large amount of taxable grants and scholarships, schools must take action to review and correct the amount if they receive conflicting information that indicates it may be incorrect.

For technical issues related to ISIR processing:

To request assistance with financial aid management systems configuration or processing applications: