From the desk of...

Robert Weinerman, Director of Training

Conflicting Information in a Post-FAFSA Simplification World

Now that we are starting our third year of the FAFSA Simplification era and the Future Act Direct Data Exchange (FA-DDX), I’ve been thinking about conflicting information. 

During the chaotic launch of FAFSA Simplification, we were given a lot of confusing guidance about FA-DDX data and unexpected behaviors within the FAFSA Processing System (FPS). This created pain points for Financial Aid Administrators (FAAs) that we are still dealing with. There were so many changes that it was tough to know where the final guidance landed. I’ve been thinking about this, and wonder whether we might start thinking about some processing a bit differently. 

Now, as a taxpayer, I am all for FAAs checking lots of FAFSAs for conflicting information to avoid awarding more aid than the applicant is eligible for. But as FAAs, we are only required to check applications if Federal Student Aid (FSA) (1) selects them for verification, or (2) defines something as conflicting information (like comment codes 283 and 284), or (3) if we have information from outside the FAFSA that suggests that data being used is incorrect (which could lead to an incorrect allocation of financial aid). 

Are FAAs reflexively defining certain FAFSA issues as conflicting information without external data suggesting the data is incorrect? I think some may be, and it may be possible to reduce the amount of conflicting information reviews as a result.

For example, FSA has been clear that there is no inherent conflicting information in an ISIR if a contributor has manually entered income tax data, even when the FA-DDX returns an IRS Response Code of 214, indicating that the IRS does not have a tax return for 2024 on record for the contributor. We do not need to review manual tax data for accuracy unless...