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Department issues guidelines for awarding aid based on student FAFSA record with errors

By Catherine Mueller

April 11, 2024

Financial aid professionals have some leeway in awarding financial aid when it comes to using student records – as long as some guidelines are met.

In a April 11 Electronic Announcement (EA), the Department of Education provided additional information about how to treat Institutional Student Information Records (ISIRs) affected by errors when making financial aid offers and disbursing funds during the 2024-25 award year.

Over the last several weeks, the Department has been sending the records to institutions, Some of those records were affected by calculation errors and inconsistent tax data.

The Department said it intends to reprocess all of the affected records in the coming weeks, adding however, schools and states do not need to wait for those reprocessed records.

For the purposes of packaging and disbursing aid expeditiously, schools and states may, based on data provided by the Department, use their judgment to rely on the original ISIR sent—not the reprocessed record—if the following three conditions are met:

• The ISIR is based on a 2024-25 FAFSA form and is the basis for aid offered and disbursed during the 2024-25 award year.
• The original ISIR results in greater financial aid eligibility for students. (If the reprocessed ISIR results in greater financial aid, schools may make estimated offers now but must use the more accurate, reprocessed record for final offers and disbursement of funds.)
• The ISIR is subject to reprocessing by the Department due to one of the errors described in Electronic Announcement (GENERAL 24-38). For more information on these issues, see the Technical Frequently Asked Questions and Known Issues document.

The EA provides additional information about the use of professional judgment, required documentation of decisions, and compliance with the Title IV Higher Education Act.

The Department said it “maintains final authority to determine the extent of an institution’s compliance with Title IV, HEA requirements, including when resolving non-federal audits. However, following the instructions in this document will not, in and of itself, create compliance concerns. In addition, using judgment to proceed with original ISIRs or to use reprocessed ISIRs as described in this announcement will not, on its own, lead the Department to initiate a program review.”