reconcile	the	conflicting	information	and	take	appropriate	action	under	the	specific	program	requirements	(depending	on
the	outcome,	funds	may	have	to	be	returned).
Subsequent	ISIRs
You	are	generally	required	to	review	all	subsequent	transactions	for	a	student	for	the	entire	processing	year	even	if	you
verified	an	earlier	transaction.	An	exception	to	this	requirement	is	if	a	later	transaction	comes	in	after	the	student	is	no
longer	enrolled	at	your	institution.	Review	the	SAI,	C	flag,	or	verification	tracking	group	for	changes.	Review	new
comments	or	NSLDS	information	that	impacts	eligibility	for	aid.	Check	any	updates	or	corrections.	If	the	SAI	has	not
changed	and	there	are	no	changes	in	the	C	flag,	verification	tracking	group,	or	NSLDS	information,	no	action	is	generally
required.	If	the	SAI	does	change	but	it	either	doesn9t	affect	the	amount	and	type	of	aid	received	or	the	data	elements	that
changed	were	already	verified,	no	action	is	required.	But	if	the	SAI	changes	and	the	pertinent	data	elements	were	not
verified,	then	you	must	investigate.	Of	course,	any	time	the	C	flag	changes	or	NSLDS	data	have	been	modified,	you	must
resolve	any	conflicts.
Discrepant	Tax	Data
Financial	aid	administrators	do	not	need	to	be	tax	experts,	but	there	are	some	issues	that	even	a	layperson	with	basic	tax
law	information	can	evaluate.	Because	conflicting	data	often	involve	such	information,	FAAs	must	have	a	fundamental
understanding	of	relevant	tax	issues	that	can	impact	the	need	analysis.	You	are	obligated	to	know	(1)	whether	a	person
was	required	to	file	a	tax	return	and	(2)	what	the	correct	filing	status	for	a	person	should	be.	The	IRS9s	online	Interactive
Tax	Assistant	can	help	with	these	and	other	issues	by	walking	the	user	through	a	series	of	questions.	IRS	Publication	17	is
also	a	useful	resource.
Resolution	of	Conflicting	Information
You	must	resolve	conflicting	information	prior	to	disbursing	aid	to	a	student	enrolled	at	your	school.	Even	if	the	conflict
concerns	a	previous	award	year,	you	must	still	investigate	it.	You	have	resolved	the	matter	when	you	have
determined	which	data	are	correct;	this	might	simply	be	confirming	that	an	earlier	determination	was	the	right	one.	You
must	document	your	findings	and	include	an	explanation	that	justifies	your	decision.
The	verification	page	on	the	FSA	Assessments	site	has	guidance	to	help	you	review	your	conflicting	information
procedures;	see	Activity	1.
Referral	of	Fraud	Cases
Requirement	to	Verify	Questionable	Data
34	CFR	668.54(a)(2)
Discrepant	Tax	Data	Example
AVG,	Chapter	5,	Example	7:	An	FAA	notices	that	a	dependent	student9s	parents,	who	are	married	and	live
together,	have	each	filed	as	head	of	household	(which	offers	a	greater	tax	deduction	than	filing	as	single	or
married).	The	FAA	must	ask	if	that	is	the	right	status.	Resolution	of	the	conflict	could	be	the	parents	refiling	and
submitting	a	copy	of	the	amended	return	or	a	reasonable	explanation	of	why	there	is	no	conflict	under	IRS	rules.
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