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The IFAP online library contains technical publications, regulations, and policy guidance on the administration of the Federal Student Aid programs.
AwardYear: 1998-1999
EnterChapterNo: 2
EnterChapterTitle: Student Eligibility and Financial Need
SectionNumber: 2
SectionTitle: The Student's Financial Aid History
PageNumbers: 39-52

hb2-51~1.pdf  PDF
Generally, when a student transfers from one school to another, the
new school must receive a financial aid history for the student before
it disburses or delivers SFA funds. Exceptions to this rule are
discussed later in this section.

[[Purpose of obtaining a financial aid history]]
The financial aid history is needed to monitor two aspects of student
eligibility. First, it tells the financial aid administrator how much aid
a transfer student has received from the SFA Programs at other
schools. By using this information, the aid administrator can make
sure that the student does not receive an overpayment. Most of the
SFA Programs have annual maximum limits; the loan programs also
have cumulative maximum limits, as discussed in Chapters 6, 10,
and 11. Second, the financial aid history is used to prevent a student
from receiving any SFA aid if he or she is in default or owes a
repayment on an SFA grant or loan.

[[NSLDS alternative]]
In the past, a school was required to obtain a student's financial aid
history by requesting a paper financial aid transcript (FAT) from the
previous schools the student attended. Since 1996, schools have also
been permitted to obtain student financial aid histories through the
National Student Loan Data System (NSLDS), a comprehensive
database containing select financial aid history information. Schools
were notified that NSLDS could be accessed for this purpose in
"Dear Colleague" Letter GEN-96-13, published July 1996.
(Notification was also published in the Federal Register on
September 16, 1996.) This "Dear Colleague" Letter also provides
detailed information on how to access and use NSLDS as an
alternative to the FAT process.

Schools use NSLDS for a number of other functions besides
accessing financial aid histories, such as reporting the status of
Perkins Loans and completing required Student Status Confirmation
Reports (SSCRs). The Department has incorporated the SSCR
function into NSLDS beginning March 1997. (See "Dear Colleague"
Letter GEN-96-17 for more on the SSCR process.) All schools that
participate in the SFA Programs must enroll in NSLDS to use the
SSCR function, even if they choose not to use the database to obtain
financial aid histories. In this chapter, we will only be discussing the
use of NSLDS to fulfill the financial aid history requirement.

[[NSLDS optional]]
Presently, although schools are strongly encouraged to use NSLDS
for financial aid histories, they are not required to do so. NSLDS
may be used as an alternative to the paper FAT. Schools may still
request a student's financial aid history through a paper FAT, and a
school that receives a request for a paper FAT must still complete
and return the FAT to the requesting school. There are no changes to
the requirements for requesting or receiving a paper FAT.

[[On-line access required]]
[[NEW]]
Although the use of NSLDS for financial aid histories is optional, as
of January 1, 1998 schools are required to have on-line access to
NSLDS. Schools were notified of this requirement in a Federal
Register
notice published on September 19, 1997. The notice listed
deadlines for schools to participate in certain electronic processes.
The Department will issue further guidance on this topic at a later
date, in the form of an Action Letter. When issued, this up-to-date
information will also be available on the SFA BBS.


NSLDS MATCH
-------------

[[All schools responsible for default and overpayment information
from NSLDS
]]
A student's application information is matched against the NSLDS
database, and the results of this match are provided on output
documents on the NSLDS Financial Aid History page and in the
FAA Information Section. All schools are responsible for resolving
any default or overpayment problems reported through the NSLDS
match, even if they are not using NSLDS for financial aid histories.
As is the case for other matches, problems that must be resolved are
indicated by a "C" next to the student's EFC. The school must resolve
these eligibility problems before disbursing aid. (See Section 1 for
more on resolving default and overpayment situations.)

[[Partial match]]
If the student's SSN is in the database, but neither the first name nor
date of birth matches those the student reported, the output document
will have a comment explaining that the financial aid history is not
provided because the name and date of birth do not match, and
directing the student to work with the school to resolve any
discrepancies (Comment 138). This partial match may result when
students use nicknames. When there is a partial match, the output
document will not have the financial aid history or any information
on defaults or overpayments associated with the reported SSN, and
will have a "C" code. A partial match requires resolution,
as explained in the following paragraph; otherwise the school will
not have information from the Department on defaults and
overpayments.

[[Obtaining information through NSLDS]]
If the student originally reported incorrect information, the school
can have the student submit correct information; the student's
information will then be sent through the match again. The school
can also access NSLDS directly using the reported SSN to determine
if the NSLDS record belongs to the applicant. The school determines
whether the NSLDS record is the student's by considering whether
other information it has about the student is consistent with the
NSLDS data. For example, if the name reported on the application is
a nickname and the name in NSLDS is the actual name, the school
should determine that the record is the student's and use the NSLDS
data in determining the student's eligibility. Or if the school knows
that the student attended a particular school in a particular award
year, and NSLDS shows aid received at the school in that year, the
school may assume that the record belongs to the student. If the
school discovers the discrepancy is due to the student misreporting
the name or date of birth on the application, it should have the
student make a correction. However, the school may use the NSLDS
record to determine the student's eligibility; it does not need to wait
for the corrected data to be reported.

If the school determines that the financial aid history associated with
the student's SSN does not belong to the student, it may assume that
the student has no relevant financial aid information. The school (or
the student) may also contact the agency that reported someone else's
data using the student's SSN, but is not required to do so. See "Dear
Colleague" Letter GEN-96-13 for further discussion.


CHECKING PREVIOUS ATTENDANCE

[[Checking required if using FAT]]
A school not using NSLDS to obtain an applicant's financial aid
history must determine if a student who applies for aid from the SFA
Programs previously attended other eligible schools. The school
must make an active effort to find out if the student previously
attended other schools. For instance, most schools routinely ask any
prospective student to state previous academic experience, either in
the course of an admissions interview or on the school's application.
The financial aid administrator is responsible for ensuring the
"consistency of information" at the school regarding a student's
eligibility (see Chapter 3, Section 2), and therefore must have a
system to exchange such information with the admissions office.

[[Checking not required for NSLDS]]
A school using NSLDS for financial aid histories is not required to
determine if the student previously attended other schools. However,
in some cases a school using NSLDS will still want to contact
previous schools directly, and so will need to determine if the student
has attended other eligible schools. For example, if the student
begins enrollment during the award or academic year, the output
document might not have a completely current financial aid history,
and the school might decide to contact previous schools for the
current information. To do so, it will need to determine what schools
(if any) the student previously attended.


USING NSLDS FOR FINANCIAL AID HISTORIES
---------------------------------------------

There are five methods by which a school may obtain financial aid
history information from NSLDS. The school may

- use the NSLDS Financial Aid History page of Part 1 of the SAR;

- use the NSLDS Financial Aid History section of the ISIR sent to a
school through the Title IV Wide-Area Network (TIV-WAN);

- request an electronic file of financial aid history information for
specific students through the TIV-WAN;

- request a print file of financial aid history information for specific
students through the TIV-WAN; or

- log on to NSLDS directly and access the NSLDS data on-line for
an individual student.

An output document will contain the NSLDS financial aid history
information only if the student's identifying information matches the
database and there is relevant information for the student in the
database. The financial aid history will not be provided on a rejected
application. The school can check the NSLDS results flag reported in
the FAA Information Section to determine why an application has no
NSLDS financial aid history.

[[Partial match]]
A results flag of "2" indicates that the SSN was found in the NSLDS
database, but neither the name nor the date of birth matched what the
student reported. A school must resolve this partial match situation
(see page 2-40).

[[No history]]
A results flag of "3" indicates that the student's SSN is not in the
database; therefore, the student has no financial aid history. The
student will also receive a comment on the output document
explaining that NSLDS confirmed that the SSN is not associated
with any previous financial aid history (Comment 140). The school
can assume the student has no financial aid history unless it has
conflicting information.

[[No relevant history]]
A results flag of "4" indicates that the student's SSN is in the
database, and the name or date of birth (or both) match what the
student reported, but there is no relevant data to report. For example,
no data would be reported if the only information for a student was
for a Pell Grant received in the previous year, because that
information is not needed to determine the student's eligibility for aid
for the current year. The student will receive a comment explaining
that his or her record was matched with NSLDS, but no information
was found to print on the NSLDS page (Comment 137).

[[Changes to NSLDS data]]
[[NEW]]
Once the school has received the financial aid history through
NSLDS, it is not required to check for changes to the data before it
disburses or delivers funds to the student. However, if the school
learns (from NSLDS or another source) that the student was not
eligible or is no longer eligible, it must not deliver or disburse any
more SFA funds and must help make sure the student arranges to
repay the aid that he or she was not eligible for. For 1998-99, the
Department will introduce a new process, called postscreening.
Under postscreening, the CPS will generate new SARs and ISIRs
when the student's eligibility may have changed due to a change in
NSLDS data, so that schools that are listed in the student's
application information will automatically be notified.

[[NSLDS Transaction Number]]
To help schools identify when they have received an output
document with changed NSLDS data, the Department provides the
NSLDS Transaction Number. This number can be found in the FAA
Information Section with the other match flags. The NSLDS
Transaction Number is the number of the last transaction on which
the NSLDS data changed. If a school receives an output document
with an NSLDS Transaction Number later than the one on the output
document the school used to determine the student's eligibility, the
school should review the NSLDS data on the new document to be
sure there are no changes affecting the student's eligibility. Note that
if a student or school requests a duplicate output document, the
request is also sent to NSLDS for matching. If the NSLDS data have
changed, the request will be treated as a system-generated correction,
and both the output document transaction number and the NSLDS
Transaction number will be updated.


REQUESTING FAT INFORMATION
-----------------------------

If the school does not obtain financial aid history information from
NSLDS, and discovers that the student did attend another eligible
school, the school is required to obtain FAT information from that
school (or schools, if the student attended more than one eligible
school) directly. The FAT information must be sent directly from the
previous school to the current school (not to the student). The student
may request that a transcript be sent, or the current school may make
the request. In either case, the current school must document that a
request was made. (Neither the school nor the student is required to
request a financial aid transcript from a foreign school.) Note that
although a student may make the request that a transcript be sent, it is
the school, not the student, that is required to obtain the FAT.

A school is not required to use a paper FAT to obtain the FAT
information directly from another school. A school may use any
reasonable method to obtain the information, as long as the school
obtains all of the FAT information required by regulations and the
school maintains proper documentation. In addition to a paper FAT,
a school may obtain the information through written documentation,
such as letters or faxes. All documentation must contain the signature
of the official authorized by the previous school to provide FAT
information. The use of electronic mail messages is not allowed
because signatures cannot be attached to such messages.

[[Closed school]]
If it appears that the student's previous school has since closed, the
current school can request the Department's assistance by writing to
the following address:

Federal Student Aid Information Center
Financial Aid Transcript Request
P.O. Box 4129
Iowa City, IA 52244

The current school will receive one of the following responses from
the Department's FSAIC:

- No transcript is required for this student because his or her school
has closed, is no longer eligible to participate in the SFA
Programs, or does not appear to be actively participating in the
SFA Programs;

- The transcript must be requested directly from the school, which is
currently in operation and is participating in the SFA Programs
(the school's current name and address will be included in this
response); or

- The request did not provide the needed information; the school
must resubmit the request, providing the name of the student, the
name and address (city, state) of the previous school, and the
specific years of attendance in question.

[[NEW]]
If no transcript is required, either because the previous school is
foreign, has closed, or does not participate in the SFA Programs, a
school is not required to take further steps to obtain the financial aid
history information. However, the school must use any information it
is aware of to ensure that the student in question has not defaulted on
an SFA loan. A school is required to check any ISIRs it receives as a
result of the new postscreening process. Also, to prevent an
overaward for the current award year, the school should secure the
student's signed statement of the amounts of SFA Program funds that
were awarded and disbursed to him or her for the current award year.


NSLDS AND MIDYEAR TRANSFERS
------------------------------

[["Dear Colleague" Letter GEN-96-13]]
In some cases, NSLDS might not provide timely financial aid history
information for students who attended another school during the
same award year (midyear transfers). Because NSLDS data providers
are on a monthly submission schedule (except Pell, which is weekly),
the student's current information may not be available immediately
when he or she transfers. The school has several options for
obtaining financial aid history information for midyear transfer
students.

1. The school can determine if the student previously attended other
schools (as it normally would if it was relying on paper FATs) and
obtain financial aid history information for a midyear transfer
directly from the previously attended school or schools. If the
previous school has closed, the school may check NSLDS or write
to the FSAIC, as described on the previous page.

2. The school can use NSLDS for the financial aid history for
previous years, and request only current year information from the
previous school. The necessary current year information is: the
student's name and SSN, the award year which the transcript
covers, the student's scheduled Pell Grant, the amount of Pell
funds disbursed, the amount of Perkins loan disbursed, and the
amount of, and period of enrollment for, the most current loan
made to the student under the FFEL and Direct Loan programs.

3. The school may use NSLDS and disburse aid if it checks NSLDS
no earlier than 60 days after the student's last date of enrollment at
the other school. Waiting for 60 days after the student's previous
enrollment has ended should allow enough time for all the data
from the previous school to be reported. If the school later
discovers that the student should not have received all or some of
the aid, the school would not be liable, but the student would be
responsible for repaying any amounts for which he or she was not
eligible.

4. The school could review the NSLDS data from the student's
output document and then make an initial disbursement of Pell and
campus-based funds or certify or originate loans as is permitted
when a school is waiting to receive an FAT it has requested (see
the next page). The school would then check NSLDS no earlier
than 60 days after the student's last enrollment at the previous
school; it may then make subsequent disbursements or release loan
funds, if the student's eligibility is confirmed.


PAYMENT AND CERTIFICATION OPTIONS
-------------------------------------

[[Pell and campus-based programs]]
Once the school has requested the FAT information, the school may
pay the student under the Pell Grant and campus-based programs for
one payment period only. If a school exercises this option, after it
receives the transcript information the school must make any
necessary adjustments to the student's aid package before making
another payment. Also, the school must have documentation that the
FAT information was requested. The school is not liable for the
amount of the first payment if the school never receives the FAT
information (or if the information arrives and shows that the student
is ineligible). However, the school may not make any subsequent
payments to the student without receiving the transcript information,
and the school must attempt to collect any overpayment from the
student.

[[Federal Stafford]]
After requesting the transcript information, the school may certify a
Stafford loan application for the student, but the school may not
release the proceeds from the loan until after the transcript
information is received. If the school does elect to certify a Stafford
loan application and then receives FAT information that shows the
student to be ineligible for payment, the school must return the loan
proceeds to the lender. In addition, beginning with the 1997-98
award year, the school may not hold FFEL proceeds for more than
10 days (this changes to three days beginning with award year 1999-
2000). If the FATs still have not arrived at the end of the 10 days, the
school must return the loan proceeds to the lender. For more
information on the return of FFEL Program funds to a lender, see
Chapter 10.

[[PLUS]]
Under General Provisions regulations, the school may not certify a
PLUS application until the school has received the FAT information.

[[Direct Loan]]
After requesting the transcript information, the school may originate
a Direct Loan award for the student, but the school may not disburse
funds to the student until the transcript information is received.

[[Payment without transcript: no SFA funds received, records unavailable]]
In several cases, the regulations permit the school to pay a transfer
student without receiving a financial aid transcript. The school may
pay the student as usual if the previous school certifies that the
student did not receive SFA Program funds or certifies that the
record retention period for the student's period of attendance has
expired and the previous school no longer has the student's records.
(See Chapter 3, Section 7 for recordkeeping requirements). As
mentioned earlier, the new school may also pay without transcript
information if the new school discovers that the previous school has
closed and the requested information is not available.


SENDING A TRANSCRIPT
-----------------------

[[Reasons for not sending transcript]]
When a school receives a request for FAT information, the school
must promptly provide the requested information. If the student did
not receive assistance from the SFA Programs, or attended the school
so long ago that the record retention period has lapsed and the school
no longer has those records, the school must notify the requesting
school in writing that the transcript information will not be sent and
specify the reason. (See Chapter 3, Section 7 for recordkeeping
requirements.)

[[Listing other schools attended]]
If the school sending the transcript information has any information
indicating that the student had attended any other schools, it must
include the names of those schools with the transcript information (or
in the written response, if the school is not required to send transcript
information). When the school requesting the transcript information
finds that the student has attended another school, it must also
request transcript information from that school.

A school cannot withhold FAT information for a student who owes a
debt to the school (such as unpaid tuition and fees, or a library fine or
parking fine). However, the Department does not discourage the
withholding of official academic transcripts in compliance with
applicable state laws.

[[Signature requirement]]
All FAT information must be signed by the person the school
authorizes to sign transcripts and other financial aid documents; the
transcript does not need to be certified. Using a signature stamp to
validate transcript information is also acceptable if the stamp's use is
restricted for use by specific financial aid personnel. In either case, a
school is liable for any inaccurate information provided. Note that a
school may accept a facsimile of transcript information, provided it
is properly completed and signed.


REQUIRED INFORMATION ITEMS
------------------------------

The transcript information must include

- the student's name and Social Security Number.


- whether the student is in default on an NDSL, or Perkins Loan, or
owes a repayment on a Pell Grant, Perkins Loan, or
FSEOG at that school.
The school should always be able to tell from its own records if
the student is in default or owes a repayment for any of these
programs.

- if known, whether the student owes a repayment on an SSIG or is in
default on a FFEL or Direct Loan received at that school.
In many
cases, the holder of the debt (the guaranty agency, the state
agency, or the Department) will have informed the school if the
student is in default or owes a repayment.

- for the award year in which the transcript is requested, the amount of
Perkins funds disbursed.

- the total amount of any loans received by the student under the
Perkins and NDSL programs at that school.


- whether the student had an outstanding balance on an NDSL (either
Defense or Direct) from that school on July 1, 1987.
This will affect
whether the student may be considered a new borrower in the
Perkins Loan Program. New Perkins borrowers are given a nine-
month grace period, rather than the six-month NDSL grace period
and are eligible for a deferment or cancellation for volunteer
service in the Peace Corps.

- whether the student had an outstanding balance on an NDSL (either
Defense or Direct) from that school on October 1, 1992.


- the amount and period of each loan made to the student under the
FFEL and Direct Loan programs at that school.
This includes PLUS loans
taken out by the student's parents on the student's behalf.

- the student's Scheduled Pell Grant and the amount of Pell Grant
funds disbursed to the student for the current award year.


[[FSEOG]]
Schools do not have to report information on FSEOG awards with
the transcript information because annual FSEOG maximums apply
only to the amount that the school may award during an award year,
not to how much the student may receive from multiple schools.

[[Information about aid at other schools attended]]
When responding to an FAT request, a school is not required to
include information about the amount of aid awarded at other
schools or the student's default or overpayment status at other
schools. However, the school sending the transcript must list these
other schools with the transcript information, and the new school
must make sure that it has received transcript information from those
schools.

A school may decide to provide additional information such as types
of work-study or cooperative-education study performed,
institutional scholarships awarded, or Pell awards received in prior
years. A school may also include any information about a student's
eligibility for, or receipt of, financial aid if the school considers that
information useful to the school the student will be attending.

NSLDS Information

The NSLDS Financial Aid History page includes information similar
to that in the list above, as well as additional information:

- The student's name and Social Security Number.

- Whether the student is in default on loans received at any school.
Note that an output document for a student who has defaulted loans
will have a "C" next to the EFC.

[[NEW]]
- Whether the student owes an overpayment at any school. Beginning in 1998-99,
NSLDS also provides contact information for the holder of the overpayment.

- Whether the student filed for bankruptcy protection on a SFA debt.

[[NEW]]
- Whether the student has had a loan discharged due to death or disability,
or has made satisfactory repayment arrangements on a loan.
For 1998-99,
the Department has added a flag to the page for each of these categories

- The aggregate amounts the student borrowed under FFEL and Direct Loans
at all schools.
In addition to reporting the outstanding principal, NSLDS provides
the amount of pending disbursements and a total loan amount (the
sum of the outstanding principal plus pending disbursements). If
Consolidation Loan amounts are listed and if the outstanding
principal balance may affect student eligibility for additional loan
amounts, the school must determine what portions of the
Consolidation Loan should be attributed to each of the loan types
by logging into NSLDS or contacting the loan holder.

- The cumulative amount of Perkins Loans disbursed to the student and,
for the current award year, the annual amount of Perkins Loans disbursed.

Note that NSLDS does not report whether loans were disbursed prior to 1987.

- Indicators showing if any Perkins Loans were awarded under the Expanded
Lending Option (ELO), which changes the annual and cumulative maximum allowed.


[[NEW]]
- The student's Scheduled Pell Grant, the amount of Pell Grant funds
disbursed to the student for the current award year, and the
percentage of the Scheduled Award used.
In previous years, this
information was not provided on the NSLDS page itself, but was available
if the school accessed NSLDS directly.

- Details on up to 12 loans. This list is a combination of
two lists (defaulted loans and most recent loans) provided in
previous years. The list includes the type of loan, the current loan
status and date of that status, the outstanding principal balance, the
loan period, identifiers indicating the guaranty agency (if a FFEL),
the school that administered the loan, the current servicer, and--if
the Department is holding the loan--the regional office holding it.
The loans are listed in order by the date the loan period began
(most recent loan first); loans with the same beginning date are
sorted by principal balance (largest balance is first). If more than
12 loans exist, the NSLDS Information page will include a
message stating "Access NSLDS for additional loan records." The
school may access NSLDS directly (through TIV-WAN) for
additional information.

MODEL TRANSCRIPT

Although there is no official form for the required FAT information,
the National Association of Student Financial Aid Administrators
(NASFAA) has developed an FAT form that schools may use as a
model (see the following pages). Financial aid administrators may
receive a copy by writing to NASFAA at 1920 L Street N.W., Suite
200, Washington DC 20036.

[[Part I]]
Part I of the transcript contains identifying information about the
student and may be filled out either by the student or by the
requesting (current) school. The student's signature is optional.
However, the transcript must include the student's name and Social
Security Number.

[[Part II]]
Part II of the transcript gives the student's financial aid history, as
completed by the financial aid office at the prior school. Section
A
gives information about other schools the student attended.
Section B is used when the school is not providing the student's
financial aid history either because the student did not receive SFA
funds at the school or because the record retention period has expired
and the records are no longer available. Section C contains several
statements regarding the SFA funds received by the student,
including outstanding loan balances, repayments owed, and defaults.
The school should check all statements that are true for the student in
question. Sections D and E are used to report amounts of aid
received from the SFA Programs. Section F is the signature block
for the school sending the transcript.

[[This file contains the model Financial Aid Transcript found on pages
2-51 and 2-52, in Portable Document Format (PDF). It can be viewed with version
3.0 or greater of the free Adobe Acrobat Reader software.]]

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