FAQ on 2024-2025 Federal Processing Changes for Regent Clients

FAQ on 2024-2025 Federal Processing Changes for Regent Clients

This page provides Regent clients with updates on Federal financial aid changes to Federal Student Aid plans for 2024-2025, information on what Regent is doing to address them, and actions clients can take in preparation for the changes. This page reflects our understanding of information received from the Department of Education and from utilizing other resources such as NASFAA, statute review, and industry publications. We encourage our clients to manage their own due diligence on these issues and to contact us via a Customer Zone ticket if that research raises new questions related to processing financial aid in Regent for the 2024-2025 FAY.

Each time this page is updated after initial publication to the Customer Zone Knowledge Base, the updates will be highlighted along with the date they are added.

Link to 2025-2026 FAQ: FAQ on 2025-2026 Federal Processing Changes for Regent Clients - Customer Zone Knowledge Base - Confluence

When will NSLDS Post-Screening be available on ISIRs? (Added 5/2/2025)

The Department has announced that NSLDS post-screening for 2024-2025 and 2025-2026 will resume on May 5, 2025.  ISIRs will be generated when a student’s eligibility status changes on NSLDS due to default, changes in LEU/aggregate totals, etc. as has been standard practice in previous years.  Please note that institutions may see a high number of ISIRs with NSLDS post-screening codes and/or ISIRs with multiple post-screening codes as the ED system resolves the backlog for the two processing years.  Expect to see post-screening codes already provided in the manual files ED uploaded to SAIG in recent months.  Please review General availability of National Student Loan Database System (NSLDS®) Post-screening functionality | Knowledge Center for more information. 

 

When will batch ISIR corrections processing be available?  (Updated 6/3/2025)

 ED updated the 1/17/2025 Electronic Announcement APP-25-01 about batch ISIR processing with the following information:

 Feb. 21, 2025 Update: We are concluding beta testing and will begin processing batch corrections via Electronic Data Exchange for all institutions at 12:01 p.m. ET on Thursday, Feb. 27. Please be reminded that we will clear the queue of batch corrections files for 2024–25 and 2025–26 transmitted before this time. We will post a follow-up announcement with additional guidance closer to the general release.

 Regent guidance is to continue making ISIR corrections for both years via the FAFSA Partner Portal (FPP) until Release 6.10 is in place with the following enhancements (as a result of ongoing Dept updates):

  • 6.10 will include some reject code logic that was communicated late by ED

  • 6.10 will include validation to ensure institutions do not send federal ISIR correction records with updated PII data. Only contributors are authorized to update those fields as they impact access to IRS data.

 Regent’s previous guidance to clients during the 2024-2025 and 2025-2026 implementation cycles has been to NOT send any ISIR correction batches prior to ED fully supporting them as those files may be deleted by ED. In the original 1/17/2025 Electronic Announcement, ED confirmed they will be deleting any batches already received prior to their full delivery of the functionality.

 As noted in the 2/21/2025 update to EA APP-25-01, ED has advised they will provide additional guidance related to their beta testing experience before the general release. We’ve heard this guidance will include topics such as updating FTI using a PJ flag, not allowing PJs against a rejected ISIR, and changes to means benefits questions and tax filing status.  As of this morning, this information has not been posted, so keep an eye out for it by checking the Department’s Knowledge Center.

(Added 6/3/2025) NOTE: 2024-2025 and 2025-2026 ISIR correction records created using Regent release 6.10.0.0 may reject at the FAFSA Processing System (FPS). The SAIG TDClient Host Communication Guide is not overtly clear on the requirements for correction file trailer records. Regent has been in touch with the Department on this and has now confirmed that record-level Carriage Return (CR) requirements in correction files also apply to trailer records for those files.  Regent is making this update in Release 6.11 via ticket RS-29773. ISIR corrections should be processed manually at the FAFSA Partner Portal (FPP) until the 6.11 Release upgrade.

 

Are there known gaps in current Regent 2024-2025 functionality? (Updated 6/5/2024)

There are a few outstanding known regulatory gaps that Regent is working to address in upcoming releases. It is important clients are aware of these gaps and any manual workarounds they may perform in the interim.

  1. Additional Non-Filer Requirements in the Verification Worksheet 

After receiving conflicting information regarding 2024-2025 verification requirements for non-filers, Regent has confirmed that Financial Aid Administrators are required to review ALL income and resources for non-filing contributors to confirm the total taxable items are indeed below the non-filing threshold. Scheduled for the 6.10 Release (subject to change), Regent will update the VWS to collect this information, but the FAA user will complete the analysis. 

 Until this is in place, Regent is advising clients to assign a .pdf form to V1 and V5 students for manual submission on non-filer income information.

  1. 2024-2025 VWS Logic Update when Manual Entries Override Successful IRS Match 

Even if IRS data is not used to calculate SAI, if it exists the IRS match still shows as successful and FTI is included in the ISIR. As a result, even if there is a successful IRS match, the VWS may need to be assigned to students selected for V1 or V5 verification in 2024-2025. Scheduled for the 6.10 Release (subject to change), Regent will update the VWS to display specific questions and persist 2024-2025 documents if certain criteria are met. 

Until this is in place, Regent is advising clients to manually review each V1 and V5 selected ISIR and manually assign any required documents that were not automatically assigned to the student. 

  1. New Pell Rounding Rules

The FSA Handbook updated rounding guidance that was published in February conflicts with previous information Regent received from ED. Regent has confirmed the new rules with FSA and NASFAA contacts, and we are working to analyze and address these updated rules in the 6.7.4 Release, targeted for mid-June, subject to change.


Why are changes planned for the 2024-2025 FAY?

On Dec. 21, 2020, Consolidated Appropriations Act amended the FUTURE Act and included the text of the FAFSA Simplification Act

  • The FUTURE ACT updates IRS code about the treatment of tax filer data and mandates FSA use of data directly from the IRS for FAFSA completion.

  • The FAFSA Simplification Act addresses changes to the FAFSA form, FAFSA application process and Pell eligibility calculations.

The majority of these changes are now slated for the 2024-2025 FAY. Federal Student Aid (FSA) has taken the need to meet related process changes as an opportunity for a ‘sweeping’ redesign and to overhaul their systems.

Which Federal Student Aid (FSA) systems are affected and how will this affect processing? (Updated 10/12/2024)

The old Central Processing System (CPS) will be reengineered as the ‘FAFSA Processing System’ (FPS). FPS will handle the Student Aid Index (SAI) calculations which will replace the current Expected Family Contribution (EFC) calculations.

ISIR files, while still flat files for at least one more year, are significantly different. They are so different that FSA will not provide their typical year-over-year mapping tool to assist software vendors with annual updates.

There will be aligning changes to COD Response and other files, but as the 2024-2025 COD files won’t be implemented until Spring 2024, very little information other than to ‘probably expect a new schema’ has been provided.

NSLDS has also been mentioned as an overhaul, but any changes to these files has not been part of our ongoing discussions with FSA. Any changes to these are likely to be less immediate than those to the other types of files.

(Added 6/1/2023) Student Aid Internet Gateway (SAIG): ED published initial communications about changes coming to SAIG to properly protect Federal Tax Information (FTI) data included in 2024-2025 ISIRs.

  • Resources:

  • It appears that the current SAIG mailbox will remain in place to handle all but ISIR files, and a new FTI-SAIG mailbox will handle ISIR files.  SAIG software will support connectivity to both mailboxes and all FAYs. 

    • (Updated 8/1/2023): Only ISIR output files from ED for FAYs beginning with 2024-2025 will be received via the new FTI-SAIG mailbox. 2023-2024 ISIR output files, ISIR correction files for all years, and all other files will continue to use the current SAIG mailbox.

  • In order to continue receiving ISIR data, each institution enrolled to receive ISIR records will be required to do the following before the 2024-2025 FAY opens:

    • Enroll for a new FTI-SAIG mailbox,

    • Sign an updated SAIG enrollment agreement, and

    • Install upgraded TD Client software. 

  • (Updated 7/7/2023) Regent is currently reviewing requirements for proper labeling of Federal Taxpayer Information (FTI) within Regent databases and user interfaces, etc. We will likely display banner notices at the top and bottom of sections containing FTI on screens within Regent and on printed ISIRs. We are still pending additional guidance for labeling FTI in dataviews, etc.

    • (Updated 9/5/2023) Per the 5/12/2023 Electronic Announcement, FTI data may be used for the application, award, and administration of financial aid to the applicant. However, FTI may not be redisclosed or used for any other purpose, such as for research in promoting college attendance, persistence, and completion.” Given the above and the associated FTI labeling requirements, Regent is not currently planning to include FTI in dataviews upon upgrade to 2024-2025 ISIR processing.

  • More information will be provided by ED on protocols for the treatment of FTI in upcoming months.

  • (Updated 11/8/2023) Regent is labeling Federal Taxpayer Information (FTI) as required for Controlled Unclassified Information (CUI) where that data is stored, viewed, and used within Regent. Clients are responsible for the security and labeling of such data if they export it from Regent into other systems or formats. Users are advised not to enter FTI elements into any manual remarks within the system unless they will also label it as required; and if those remarks are exported, the client must properly secure and label them.

  • (Updated 1/21/2024) FTI-SAIG Mailbox

As previously communicated, a new version of TDClient is required to access the new FTI-SAIG mailbox which will be used solely for FPS to send 2024-2025 ISIR files to schools. Schools have been executing the new FTI-SAIG enrollment agreements that are required to gain access to their new FTI-SAIG mailboxes. All other COD/ISIR/NSLDS/etc. files and ISIRs for FAY 2023-2024 will continue to use the current SAIG mailbox.

After extensive questioning and follow up with various ED entities, Regent has been advised that there will be no test FTI-SAIG mailbox functionality available to vendors.  Regent is working to develop support for client processing via the FTI-SAIG mailbox similar to that already in place for the current SAIG mailbox but will be unable to test this before clients attempt to draw down 2024-2025 ISIRs from their production FTI-SAIG mailboxes.

Regent plans to have this FTI-SAIG support in place in an upcoming release (updated 1/21/2024).  Until this is in place and functioning properly, clients will need to access the FTI-SAIG mailbox directly (not from within Regent) and then to place 2024-2025 ISIR files on a secure drive from which users can import them into Regent.

We anticipate that this will be a short-term workaround where current processing will continue as is within Regent except for the 2024-2025 ISIR files. However, there is a chance that clients will have to continue to use their TDClient setup to access 2024-2025 ISIR files once they take the 6.7 release. Without testing capability, Regent has limited capability to anticipate and address consequences of the TDClient upgrade within Regent. Important Note: Clients MUST provide RTM and INI files in order to use FTI-SAIG functionality in Regent for 2024-2025. Please work with your Account Manager/Project Manager to provide in secure manner.

  • (Added 7/14/2024) Regent attended a meeting with FSA on 7/12/2024 during which it was confirmed that ED will support neither individual ISIR requests nor ISIR Year-to-Date file requests for 2024-2025. The presenters noted that schools could still go into their FTI-SAIG mailboxes to update the status of previously-received files so they can be redownloaded.

Guidance for EDConnect and TDClient at EDconnect 8.6.1 User Guide includes that when viewing the Received File queue in the SAIG mailbox, a user can check the ‘Move to TQ’ checkbox to move selected files back to the Transmission Queue for redownload. If the needed files are not available but are less than 90 days old, the user should contact SAIG to have them restored.

HOWEVER, please attempt to minimize those one-off use cases where a student’s 2024-2025 ISIR might need to be reimported as that ISIR may not be available.  And, while re-downloading and importing an ISIR file that for some reason was never imported into Regent is supported, Regent is not intended to support reimporting a file with multiple students in an effort to isolate an ISIR for one individual student. Clients with mid-year implementations should retain all 2024-2025 ISIR files for potential use in the Regent Go Live process.

 (Added 8/4/2024) While the note above advising not to re-import files with multiple students in order to isolate an ISIR for one individual student is valid, please note that until ED supports individual ISIR requests at some point in a future FAY, the specific ISIR row for a student from a combined ISIR file can be copied into a new file and imported to provide a clean copy of the ISIR in Regent.

 

(Added 10/12/2024) Annual Certificate Update for FTI-SAIG Access

On October 8, 2024, ED published Annual Certificate Update for FTI-SAIG Software (EDconnect, TDClient) | Knowledge Center which announced that “the runtime certificate expires annually.  A new certificate will be assigned to your FTI-TDCommunity Manager (FTI-TDCM) account 30 days before your current one expires.  EDConnect 8.6.1 or TDClient 3.5.0 users must import the new certificate to maintain access to the FTI-SAIG and continue receiving ISIRs”.   Addendae to the announcement include Plain Language guides for importing the certificates for TD Client (TDClient3pt5pt0CertificateImport.pdf (ed.gov)0 and for EDConnect (EDconnect8pt6pt1CertificateImport.pdf).

 Clients who receive and import ISIR files directly within their Regent instances, or those who wish to do so, will need to work with their Account Manager or Project Manager to provide their updated RTM file and Approval code to Regent. This information will be used to update your FTI SAIG configuration on the back end to ensure no interruption in FTI SAIG Mailbox connectivity from Regent Award or Regent Review.

 Here are summarized steps for the annual runtime certificate update for Regent clients:

 

Guide for the annual runtime certificate import

ISIR recipients who use TDClient 3.5.0 to transmit with Federal Tax Information Student Aid Internet Gateway (FTI-SAIG) are required to update their expired certificates annually. To support our partners to continue their services, we are providing this guide that summarizes the steps for importing the new certificate in TDClient 3.5.0.

Expected time to complete the steps described in this guide: 30 minutes

Requirements and considerations

These instructions are written for organizations currently using TDClient 3.5.0 and wish to update their certificates to ensure uninterrupted receipt of ISIRs. We anticipate that most institutions reviewing this guidance fall within this category. If you are a new TDClient 3.5.0 user or require more detailed instructions, please refer to the FTI-SAIG TDClient Host Communication Guide.

Terms used in this document:

FT number: Used to identify an organization’s newly assigned FTI-SAIG mailbox. The FT number is unique and always begins with “FT” followed by five alphanumeric characters. “FTxxxxx” is used as an example FT number throughout this document; it should be replaced with an organizations actual FT number when following instructions.

Security Code: This is a six-digit code generated from your physical (or software) Security Token.

 

Instructions:

Section 1: Checking the Certificate Expiration in FTI-TDCM

The purpose of this section is to help you verify the expiration date of your current certificate. All FTI-SAIG registered mailbox users with an FSA User ID linked to an FT mailbox can check the expiration date of their FT Mailbox certificate by logging into their FTI-TDCM account. Please follow the steps outlined below to complete the process.

image-20241012-174812.png

Step 1: In your web browser, enter the URL https://ftisaigportal.ed.gov/tdcm in the address bar and press Enter. This will take you to the login screen shown below.

Step 2: Enter your FSA User ID in the FSA User ID field.

Step 3: Enter your FSA User ID Password in the Password field.

Step 4: Enter the six-digit Security Code from your Security Token in the OTP field.

Step 5: Enter your FT Number (e.g., FTxxxxx) in the Mailbox Id field.

Step 6: Click the Login button. All FTI-TDCM users will see the FSA Security Banner screen after logging in.

Step 7: Navigate to the Participants view and select the Security tab. Here, you can check the status of your certificate, including its expiration date, any expired certificates, your current certificate, and/or a pending certificate.

image-20241012-174928.png

Note: The options displayed may vary depending on when your certificate was issued and its expiration date, so you may only see one or two of the options mentioned above. Please refer to the examples below:

 Example of Current Certificate:

You will only see the "Current" certificate if your initial certificate is still active, and its expiration date is more than 30 days away. No action is required at this time. Please note the expiration date of your certificate and check back 30 days before it expires to download the newly assigned certificate.

image-20241012-175008.png

Example of Expired Certificate:

You will see both the "Expired" and “Current” certificates if your initial certificate has expired, and a new one has been assigned to your account. If you see this option in your Security tab, clicking on the "Export Runtime" button will download the current runtime file. You can then proceed to the next sections, which will guide you through downloading and importing the file.

image-20241012-175047.png

Example of Current and Pending Certificates:

You will see both "Current" and "Pending" certificates if your current certificate is still valid but set to expire within the next 30 days. . If you see this option in your Security tab, clicking on the "Export Runtime" button will download the new runtime file. You can then proceed to the next sections, which will guide you through downloading and importing the file.

image-20241012-175149.png

 

Section 2: Downloading the New Certificate from FTI-TDCM

The purpose of this section is to help you download the new certificate by logging into your FTI- TDCM account and placing it in the correct folder. Please follow the steps outlined below to complete the process.

Step 1: Follow Steps 1-7 outlined in Section 1 to prepare for the next steps.

Step 2: Click the Export Runtime button to download the runtime file. You should now have a runtime file (certificate) associated with your institution's name and FT number ( E.g.: “School Name FTXXXXX.rtm”). For most users, the downloaded file will be located in the Windows Downloads folder.

image-20241012-175413.png

Step 3: Record the Approval Code displayed on this screen. You will need it when importing the

runtime file in TDClient in Section 3-Step 5 and Section 4-Step 5.

Additional Questions

If you have questions or need additional assistance, please contact the FPS Help Desk (formerly CPS/SAIG Technical Support) at 1-800-330-5947 or by email at support@fps.ed.gov.

 

 What is happening with the FAFSA? (Updated 1/13/2024)

  1. The FAFSA completion process will be simplified for applicants, but that doesn’t necessarily mean it will be simplified for those of us who process the results. In a meeting with FSA, we were told the FAFSA would have ~180 data elements including new questions on race/ethnicity and gender identity. There will be 30+ options for Race, and applicants may multi-select options or may write-in their response.

  2. Rather than the current Data Retrieval Tool (DRT) process, where the student essentially requests data from the Internal Revenue System (IRS) and provides it to FSA, Direct Data Exchange (DDE) will bring over Federal Tax Information (FTI) directly from the IRS to the FAFSA form. On the new ISIRs, there will be separate fields for IRS data and any manual entry for the same data element. The IRS data will always trump any manual entries except in the case of a professional judgment.

  3. Instead of just student and parent, there will be up to four separate ‘contributors’, each of whom will -- at a minimum -- need to provide consent to participate in the new IRS process. We have been told by FSA that if all required contributors do not provide consent, the FAFSA will process with a reject code. The four roles are (1) the student, (2) the student’s spouse, (3) the parent, and (4) the parent’s spouse. The 2024-2025 ISIR file is broken up into modules with sections for each of the (up to) four contributors. See the 2024-25 FAFSA Specifications Guide: Volume 4 - Record Layouts and Processing Codes (ed.gov) for a DRAFT of the new ISIR format. We have been advised that there will be changes to this format and it is not final.

    • (Added 6/1/2023) For Regent Access clients: We anticipate that the 2024-2025 questionnaire will generally follow the structure of the new FAFSA. However contributors will not have to provide consent for the IRS data exchange. The official FAFSA-based ISIR records will have fields for both IRS data and manual entry for the key financial and tax filing information, the latter to be used for SAI calculation under certain conditions. The Regent Access questionnaire will continue to rely on manual entry of financial and tax filing information by each contributor.

  4. We understand there will be no more skip logic for the dependency questions on the FAFSA. Applicants will need to answer all of them, even if the response to an earlier question has already established the student’s independence for FAFSA completion purposes. Also, FPS will not be making assumptions about field content, and there will be no more assumptions to review and resolve on ISIRs.

  5. Students will be able to list up to 20 institutions on the FAFSA, rather than being able to list only 10 as in current state.

  6. Housing status choices are not included in the 2024-2025 FAFSA and as a result, the draft ISIR Record Layouts document does not include any mention or housing status or whether the student will live on or off campus. However, institutions are required to utilize the student’s housing status for Cost of Attendance calculations. Clients will need to find an alternative means of collecting housing information for provision to Regent.

    • (Added 7/7/2023): Current business requirements include support for an ‘assumed’ housing status configuration option in Cost of Attendance Setup.

    • (Added 1/24/2024) Housing Status: As student Housing Status is not available on the 2024-2025 ISIR, users will need to provide a student’s housing status using at least one of three ways to have a Room and Board component in COA and have Pell COA properly assigned: 1) a configurable ‘Assumed COA’ option for Independent vs Dependent students, 2) a User Defined Field (UDF) sent via the Student Batch Load (SBL), or 3) a manual update.  A manual update will take precedence over the other two methods, and an SBL/UDF entry will take precedence over an ‘assumed’ housing status. 

      Specifics on the above will be in the 6.7 release notes, but we are providing initial information now on the SBL option available for 2024-2025 and forward. If a ‘Student Housing Status’ UDF is present with one of the following values, the value will be used to determine the student’s housing status for the period within the UDF’s effective start and end dates. If no effective dates are sent, the ‘Student Housing Status’ UDF will determine the student’s housing status for 2024-2025 forward.

1 - On-Campus

2 - On-Campus with Dependents

3 - With Parent

4 - Off-Campus

5 - Military Housing

6 - Blank

Other Updated SBL Values; Additionally, SBL values for the following are being updated to include new 2024-2025 ISIR values:

A Student Marital Status values added: SingleNeverMarried, MarriedNotSeparated, Remarried

High School Type values added: StateRecognizedHighSchoolEquivalent, NoneOftheAbove

Parent/Spouse information Type values added: Parent, ParentSpouseOrPartner

  • (Updated 5/1/2023) It appears several additional questions will not be included on the 2024-2025 FAFSA, including those listed below. If you use this information for your processes, start thinking about alternative means of meeting your needs in case the data is no longer available to you via ISIR.

    • Whether student is interested in Federal Work Study.

    • Date of Marital Status

    • Driver’s License Number and State

    • Highest educational level for parent - draft question asks if parent attended college

  • (Updated 6/1/2023) Gender, race, and ethnicity information collected via the 2024-2025 FAFSA will not be provided to institutions via the ISIR.  This has been confirmed by NASFAA and the most recent ‘almost final’ draft version of the 2024-2025 ISIR layout notes that these fields have been removed.  Regent is reviewing potential changes to the values accepted via SBL for these fields to support clients wishing to collect this information by another means and make it available within Regent.

  • (Added 7/7/2023) While certain dependency-related fields will prepopulate on the 2025-2026 FAFSA based on the previous year’s ISIR, the fact that ISIR data will be housed in separate federal systems for 2023-2024 and 2024-2025 means there will not be any such prepopulation for the 2024-2025 FAFSA. FAAs will have to manually update a 2024-2025 ISIR to reflect a previous year’s Unusual Circumstances determination to make a student Independent.

  • (Added 8/1/2023) There has been an update to the NASFAA Conference ED announcement regarding rollover amounts for IRAs and pensions. The rollover amount will not be provided by the IRS and will be supplied by the FAFSA contributor in response to a prompt.

  • (Added 10/10/2023) Grade Levels: Instead of the traditional values of zero through seven, the 2024-2025 FAFSA college plans question will now accept values of one through four:

    • 1 = First Year/Freshman

    • 2 = Second Year/Sophomore

    • 3 = Other Undergraduate/Junior or Senior

    • 4 = College Graduates, Professional or Beyond (MB, M.D., Ph.D, etc.)

We have received confirmation that there is no plan for the foreseeable future for COD or NSLDS to start using the new (1-4) grade levels. Thus, Regent functionality will continue to utilize the 0-7 grade level values for all processing.

(Updated 11/8/2023) As the ‘will you be working on a master’s or doctorate program' question is not on the 2024-2025 FAFSA, the logic has been updated to use the ISIR Grade Level when determining if an ISIR is Undergraduate (1, 2, or 3) or Graduate (4).

How is Federal Work Study (FWS) information provided for SAI calculations? (Updated 8/4/2024)

The Law does not allow FAFSA to ask applicants about their prior prior year FWS earnings, but those earnings are part of the SAI calculation. FSA is developing a file submission process by which institutions will provide their gross calendar year FWS student earnings via the Student Aid Information Gateway (SAIG). This must be accomplished before FAFSA filing opens for the new year. FSA has targeted ‘sometime in February’ to provide software vendors with draft specs for the FWS file. As yet, FSA has finalized neither what data will be required nor what format will be used.

Update 3/8/2023: FSA has published COD Technical Reference 2023-2024 Volume 4 - Campus-Based Record Layout with information on the file institutions will use to provide 2022 FWS data for use in calculating 2024-2025 SAIs. Regent has confirmed that the SEOG fields are not to be used at this time, and the amounts of Federal vs Institutional FWS funds for each student are optional this year. Regent will focus on providing a means for client institutions to report the required fields to COD via SAIG.

Update 4/6/2023: Further update from FSA is that business practice policies are still being determined, so it is unknown whether the dollar amounts of Federal vs Institutional FWS payments will be required.

Update 6/1/2023: Calendar year 2022 Federal Work Study reporting requirements to COD in support of 2024-2025 SAI calculation have been updated to clarify that institutions will NOT have to provide the dollar amounts of federal vs institutional funding for each student’s awards.

(Added 8/1/2023) Regent is planning to pull the FWS data from the Regent FWS Earnings tab into the required COD file format, and to support export of the COD file for transmission via SAIG.

  • There is an existing process to import basic FWS payroll data into Regent. If you are not using this now, we expect that a single upload with a payment date in 2022 containing the full FWS amount paid for each student during the calendar year 2022 will be all Regent needs to create the COD file. Stay tuned!

  • While COD has been upgraded to accept this data, the deadline for reporting of 2022 data is when the 2024-2025 FAFSA opens - sometime in December. Regent plans to provide this functionality in the upcoming Fall Release, giving schools plenty of time to complete reporting by the December deadline.

  • Populating this Earnings detail information in Regent Award will not affect the packaged amounts for FWS on the students' plans. There are Standard Reports available to compare the reported earnings against the awarded amounts.

  • (Updated 9/5/2023) The current .CSV upload process by which clients can supply FWS payroll details to Regent is expected to be updated to include FAY. This information will be needed in order for Regent to determine which ISIR transaction is to be reported to COD for the 2022 FWS payments. Current requirements will ask clients to provide at least one gross amount entry for each FAY for which students were paid FWS during the calendar year 2022 either via the upload process or via the Regent UI. Regent will add up all entries for each FAY paid during 2022 for reporting to COD via a new Export process within the system.

  • (Updated 10/10/2023) Regent is currently testing our updated CSV schema for use in getting paid FWS amounts from client systems into Regent for the necessary reporting to COD. We are supporting the Award Year level reporting for 2022 payments. If you paid FWS to any students during 2022 and if those students are in Regent, this file will provide the necessary data for Regent to create the appropriate COD files for export.

    Required fields include the following:

    • FAY (schools should report a total amount of FWS paid in 2022 separately for each of the 2021-2022 and 2022-2023 FAYs. There should be two entries for a student paid from both FAYs during the 2022 calendar year)

    • External Student ID1

    • Fund External ID

    • Paid Date (Critically, this date must fall somewhere within 2022 so the amount will be reported to COD as 2022 FWS earnings.  This date does not have to reflect any actual payment date for the student)

    • Gross Paid Amount (Lump together all gross payments for the FAY paid in 2022

    Recommendations:

    • Make sure you know where this data is for your 2022 students so you are ready to utilize it when Regent publishes the schema.

    • If you already have data in Regent for the period, ensure that you do not double report it via this process.

    • There is also to be an option for direct data entry of the 2022 FWS earnings via COD-on-the-web. If you have a small FWS population or if the students are not in Regent this may be a good option for you.

  • (Updated 11/8/2023) Please see 6.6 Product Brief Early Draft - Customer Zone Knowledge Base published to clients on November 3rd for updated information on the schema and process in 6.6 to report FWS earnings paid in 2022 to COD via Regent.

    • Remember to set up the related message classes for SAIG processing.

    • Ensure your data is correct in Regent before exporting to COD. Any subsequent edits should be made at COD Online.

    • If you will be using the CSV upload process to add 2022 data for students in Regent Award, prepare the CSV file in advance of the 6.6 Regent upgrade so it is ready to go once you have upgraded.

      • Disregard if you do not participate in Federal Work Study (FWS), if your 2022 FWS data is already in Regent Award, or if you will be entering the 2022 FWS data manually at COD Online.

  • (Added 8/4/2024) After consulting with our clients, Regent discovered that most clients elected to report 2022 FWS earnings to COD manually last year rather than exporting from Regent and that, given fairly low volume, there was not a pressing need for Regent to invest resources in providing automated file-based reporting capability for 2023 earnings this year. Clients who paid FWS wages during 2023 will report those earnings manually for each student via the COD website.

What is a Provisional Independent Student? (Updated 3/28/2024)

Otherwise dependent students who do not have access to parental data may self-identify and complete the FAFSA as Provisional Independent Students. The FAFSA will process fully without the parental information, and institutional follow-up and final determinations will occur more after-the-fact. We are pending more information about how this is expected to take place.

  • (Added 9/5/2023) Regent is planning to support the following for Provisional Independent students:

    • ED’s Provisional SAI is calculated by ED as if Independent, but the ISIR is considered to be rejected.

    • Independent Awards must be made based on the Provisional SAI, but the awards are to be in Estimated status (these can display in Student Experience even if estimated awards are not typically displayed for the Institution).

    • A “Confirm Student Circumstances” task will alert users to follow-up promptly with the student about the Unusual Circumstances professional judgment process at the Institution.

      • Clients will either approve the student for a Dependency Override to Independent, or

      • Clients will advise students to have their parent(s) complete their sections of the FAFSA.

    • The decision will carry over to future FAYs:

      • This is not yet automated by ED, so upon receipt of the task, users should check the record for a previous year decision.

    • Separately, the triggering logic for the current ‘Review Dependent Record Unsub Only' Task will be updated from the current special circumstances flag to align with the student’s response to the “Unsubsidized Loan Only” question on the 2024-2025 FAFSA.

    • (Added 3/28/2024) The financial aid community is reporting a high incidence of students requesting ‘Unsub Only’ on their FAFSAs so as to not provide parental information. There is a concern that a good number of these did not intend to skip consideration for Pell Grant and other need-based awards. Clients may assign a document to communicate options to these students by configuring a document requirement associated with Comment Code 049: “You indicated that your parents are unwilling to provide their information on your FAFSA form. Therefore the only federal student aid you may be eligible to receive is a Direct Unsubsidized Loan. The financial aid office at your college or career school may contact you to complete your application. If you want to be considered for other types of federal student aid, you must log in to http://StudentAid.gov , select “Make a Correction,” and add your parent to your application.”

What is expected for 2024-2025 ISIR Verification (Updated 10/12/2024)?

For the first year, students will be selected ‘randomly’ for verification. FSA needs data on which to base future selection algorithms.

The same Verification Tracking Groups in use for 2023-2024 will be used for 2024-2025.

We have no information as yet about which fields will be selected for verification, what percentage of applicants will be selected, nor whether the verification process will remain much as it is today.

(5/1/2023 Update): Comment Codes: We have been advised informally that beginning with 2024-2025, Comment Code numbers will be reassigned. The same numbers will be used, but they will be associated with different comments - we assume some that are currently in use and others that are new. We provided unsolicited feedback indicating this will add another layer of complication to implementation for both software vendors and institutions. We await official updates on the 2024-2025 Comment Codes.

  • (9/5/2023 Update): The 2024-2025 comment codes have been published in Volume 7 of the FAFSA Specifications Guide. The previous comment codes have been completely redone, reusing the previous numbering system. This will affect client document assignment configurations. Additionally, Regent is in the process of analyzing the impact of these new codes on the Active ISIR Logic. Review the new comment codes at: https://fsapartners.ed.gov/sites/default/files/2023-08/202425FAFSASpecVol7CommentCodesAugust.pdf

  • (10/10/2023 Update): Initial 2024-2025 verification requirements have been published: Federal Register :: Free Application for Federal Student Aid (FAFSA®) Information To Be Verified for the 2024-2025 Award Year

  • (11/8/2023 Update) Please see  DCL GEN-23-12:  2024-2025 Verification for more information on 2024-2025 verification requirements.

    • Regent will be providing Regent Review clients with the standard documents configurations as usual, along with an updated Verification Worksheet

  • (1/13/2024 Update) NASFAA has confirmed that whenever corrected or updated ISIR data is sent that will override FTI, the ‘PJ Flag’ should be flipped to ensure the SAI is recalculated using the manual entries. ED has indicated the increased use of the PJ flag should not trigger program reviews, and NASFAA is advocating that this be a one-year use of the flag, hopefully returning to the more limited traditional use in the future.

  • (Added 3/28/2024) There are three ways Family Size can be reported on the ISIR.

    • If there is a value for Updated Student Family Size (or Updated Parent Family Size for dependent students) field, this is the value provided by the contributor and is always the number used to calculate SAI.

    • If the ‘updated’ field is blank but there is a number in the Assumed Student Family Size (or Assumed Parent Family Size) field, this number was used for the SAI.

    • If both Updated and Assumed values are blank, then IRS exemptions are used to calculate the Family Size.

    • Non-filers do not have any of the Family Size values on the ISIR as this is not used to calculate their SAIs.

  • (Added 3/28/2024) There is no 2024-2025 reject code or C-code associated with a marital status change, so the 2-step marital change process currently in place does not apply to the new year. Beginning with 2024-2025, the process within Regent Review when a marital status change is noted in the Verification Worksheet is as follows for schools wishing to allow such changes:

    • Enable Marital Status Change via Portal Setting

    • Student answers yes to the marital status changed question on the VWS.

    • VWS goes to signature the page.

    • Marital Status Documentation document persists in a Needed status.

    • Student provides documentation.

    • FAA determines if student can change their marital status.

    • If yes, a correction is made to the ISIR, which will trigger a new ISIR.

    • FAA adds a Verification Worksheet (VWS) Revised Request document.

(Added 5/23/2024) The Department of Education (ED) published new information on the availability of 2024-2025 ISIR corrections for schools: 2024-25 FAFSA: Update on Processing Paper FAFSA Forms, Implementing School-Initiated Corrections, and Temporary Changes to Process for Reporting Disbursements to Provide Institutional Flexibility | Knowledge Center

 Summary:

  • School users will be able to access manual corrections via the FAFSA Partner Portal (FPP) by the end of June.

  • The batch ISIR correction process will not be available with ED until some weeks after the above noted manual FPP correction process goes live (~July).

 Important notes:

  1.  Given the FPP will be open for manual updates well in advance of batch corrections, it will be quicker for schools to make corrections online and receive a subsequent ISIR transaction rather than using batch processing in Regent.   

  2.  Do not send any 2024-2025 ISIR correction files via SAIG until ED announces their systems are prepared to process the files. 

    1. Any 2024-2025 ISIR correction files received prior to that announcement will be deleted by ED.

  3.  Regent suggests schools not make verification entries within Regent if they plan to make those entries via the FPP.

    1. This will avoid duplicative correction data entry.

    2. The ISIR resulting from the corrections entered at FPP will update Regent with the corrected values.

    3. Cleaner approach to track in one place and import a subsequent ISIR transaction from FPP.

  4.  If there is urgency to make corrections in Regent before they can be made via FPP, ED notes that you should advise students the offers may change once the official ISIR is processed by ED.

  5.  If 2024-2025 is a header for your school, you have summer terms beginning before FPP will accept corrections, your school has received an initial Pell Current Funding Level (CFL), and you cannot wait for ISIRs from FPP corrections in order to disburse Pell to affected students, you may make interim Pell and SEOG disbursements to those students using a Regent-calculated SAI.

    1. Ensure you advise these students their awards may change once the official ISIR is processed by ED.

    2. Awards must be adjusted per the official corrected ISIR once it is received.

    3. Do not use overrides to pay Direct Loans prior to receiving the valid corrected ISIR from ED.

    4. Students for whom the current ISIRs are valid will follow the normal processes and do not need the advisement that their awards may change.

 Please reach out to your Account Manager / Project Manager with any questions.

 

(Added 7/16/2024) Interim Processing for NSLDS Post-Screening and for Subsequent Identification of Potential Abuse/Fraud Cases

ED will not be completing standard NSLDS post-screening for 2024-2025 ISIRs until later this year, nor is their process to update Verification Tracking groups for students identified as potential fraud or abuse cases after the initial ISIR is processed going to be in place until some later date.  While the initial NSLDS check will still occur, the subsequent checks when additional ISIRs are created will not be happening. And, some students who will ultimately be V4 or V5 on subsequent ISIRs may not yet be identified as such via the normal ISIR process.

Regular importing of NSLDS FA History files into Regent Award should help mitigate the first scenario (the lack of NSLDS post-screening) as this will catch updates to Pell and Direct Loan activity after the initial ISIR was created.

 In order to assist schools with the latter scenario (ED-identified concern with fraud or abuse), ED will provide lists of these students via the SAIG mailbox of any newly identified potential fraud or abuse concerns so identify verification and Statement of Educational Purpose (SOEP) can be completed for them in advance of the V4/V5 ISIRs that will be generated at some later date. 

To mitigate the possibility of awarding and disbursing aid to individuals who are suspected of identity fraud for the 2024-25 Award Year, a report containing the list of students who should undergo identity verification will be sent to an institution’s FTI mailbox. A new SAIG message class, AHSI25OP, has been created to identify this report. Schools may use this file—which will be delivered to SAIG mailboxes every two weeks starting the week of July 15th—to identify applicants and request acceptable documentation to complete V4 or V5 verification.

The comma delimited file contains only the information needed to identify the student and whether the student will be V4 or V5.  This should affect only a small number of students who were initially NOT V4/V5 and who would subsequently fall into one of those tracking groups. The Department later updated the notice to indicate the first file would be available a few days sooner. As this file is a short-term solution that was implemented with no previous warning, and as it is in a format easily opened with Excel, Regent will not be adding support for AHSI25OP to the development roadmap.

If AHSI25OP files are created for a school, they will be in the school’s regular SAIG mailbox.  If using SAIG automation within Regent, the user would need to configure to import ‘All’ files to receive the AHSI25OP files, which could interfere with their normal runbook processing. We recommend using TDClient or EDConnect outside of Regent to access and review the available files in the SAIG mailbox and select any AHSI25OP files for download. Once received, the files should opened using Excel.

Users will manually assign required documents to students are newly identified via the AHSI25OP file for V4/V5.  If the student is identified for a V4, the user can add the SEOP for the student to complete. If the student is identified for a V5 the student will also need to complete a PDF Verification Worksheet which can be attached to a configured verification document as is done for students institutionally selected for verification. Other verification documents can be assigned as needed.

Once ED brings their processing fully online, new ISIRs should be issued with the appropriate V4/V5 tracking group.

(Added 10/12/2024) As the ISIRs for the V4 and V5 students in the AHSI25OP files do not include the verification flags or tracking groups, the standard flow for reporting verification status for Pell to COD does not apply. Once completed, the verification status for these students can be updated by the user to ‘Verified’ directly at COD. These updates will trigger Web Response files which can be viewed in the student’s COD tab in Regent and will reflect the Verification Status as reported at COD.

(Added 7/18/2024) Conflicting Information when Federal Tax Information (FTI) is returned for a contributor who indicated ‘non-filer’ on the FAFSA.

In cases where a contributor indicated ‘non-filer’ but the ISIR also contains FTI returned from the IRS for the contributor, ED (FPS) is currently treating the contributor as a non-filer when determining Pell eligibility and when calculating the SAI. School users have been advised to enter the FTI data from the ISIR in the corresponding manual ISIR fields in order to trigger correct calculations by FPS. The information below will assist clients in identifying ISIRs which require this treatment.

Recommended document requirement setup steps:

Clients can create an ‘Office Use Only’ document that will trigger a review task upon ISIR import to identify cases requiring resolution of conflicting information between a non-filing contributor tax filing status and data received from the IRS. The steps below show how the document for each contributor should be configured.

 Please note users can create their own document name and settings on the General and Restricting tabs.  The only settings that are required in order to trigger the document based on the conflicting information (manually entered tax filing status and the FTI information) are the settings on the ISIR tab.

 Student

  • General tab settings

    • Document Name:  Resolve Student's Conflicting Tax Filing Information

    • Description:  Assigned by ISIR if the student’s entered tax filing status does not match the FTI data       

    • External Document ID:  (InstitutionID)Conflict25_1   

    • Office Use Only: Yes

    • Select the Process that this document facilitates:  Review Conflicting Information

    • Set Initial Document Status to: Received – (A task will trigger upon the ISIR import for the FA to resolve the conflicting information)

    • Activity Type: ISIR Related

    • Scope:  Federal Award Year

    • Selected FAY Years:  2024-2025 (if ED does not resolve this for 2025-2026,  the 2025-2026 FAY can be added when setting up documents for the new FAY)

    • Date Used for Document Expiration Date Assignment:  Static Date

    • Month:  September

    • Day:  15

    • Year:  FAY Year

    • Expiration Status:  Incomplete and Needed

    • Change to Selected Status:  Unsatisfied

    • Message: (sample message) The applicant and or contributor who had 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 eligibility 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.

 To resolve the conflicting information, 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. You 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. (See the 7/25/2025 and 8/4/2024 updates below for new guidance on resolution).

  •  Restrictions tab settings

    • Enable Restrictions:  Yes

    • Restrict Process:  Restrict Packaging

    • Restrict Process: Title IV funds (schools to determine if any of the funds should be included for restriction)

  •  ISIR tab settings

    • Enable ISIR Process:  Yes (updated 7/22/2024)

    • Student Filed 1040 or 1040NR = No

    • Student IRS Response Code = Successful Request

 Student Spouse

  • General tab settings: Use same setting used for the student except for the following:

    • Document Name: Resolve Spouse's Conflicting Tax Filing Information

    • Description:  Assigned by ISIR if the student’s spouse entered tax filing status does not match the FTI data

    • External Document ID:  (InstitutionID)Conflict25_2 

  • Restrictions tab settings: same as Student’s setting as above 

  • ISIR tab settings

    • Enable ISIR Process:  Yes (updated 7/22/2024)

    • Marital Statuses: 

      • Married (Not Separated)

      • Remarried

  • Spouse Filed 1040 or 1040NR = No

  • Spouse IRS Response Code = Successful Request

Parent

  • General tab settings: Use same setting used for the student except for the following:

    • Document Name: Resolve Parent's Conflicting Tax Filing Information

    • Description:  Assigned by ISIR if the parent entered tax filing status does not match the FTI data

    • External Document ID:  (InstitutionID)Conflict25_3 

  • Restrictions tab settings: same as Student’s setting as above 

  • ISIR tab settings

    • Enable ISIR Process:  Yes (updated 7/22/2024)

    • Dependency Status :  Dependent

    • Parent Filed 1040 or 1040 NR = No

    • Parent Filed non-U.S tax return =

      • Did not and will not file a U.S. tax return – earned U.S. income below the tax filing threshold

      • Did not and will not file a U.S. tax return – reasons other than low income

      • Did not and will not file any tax return – no earned income

    • Parent IRS Response Code = Successful Request

Parent Spouse or Partner

  • General tab settings: Use same setting used for the student except for the following:

    • Document Name: Resolve Parent, Spouse or Partner Conflicting Tax Filing Information

    • Description:  Assigned by ISIR if the parent spouse or partner entered tax filing status does not match the FTI data

    • External Document ID:  (InstitutionID)Conflict25_4 

  • Restrictions tab settings: same as Student’s setting as above 

  • ISIR tab settings

    • Enable ISIR Process:  Yes (updated 7/22/2024)

    • Dependency Status :  Dependent

    • Parents’ Marital Statuses =

      • Married (Not Separated)

      • Remarried

    • Parent, Spouse or Partner Filed 1040 or 1040 NR = No

    • Parent, Spouse or Partner Filed non-U.S tax return =

      • Did not and will not file a U.S. tax return – earned U.S. income below the tax filing threshold

      • Did not and will not file a U.S. tax return – reasons other than low income

      • Did not and will not file any tax return – no earned income

    • Parent, Spouse or Other Partner IRS Response Code = Successful Request

(Added 7/25/2024) - NEW GUIDANCE for Resolution when FTI is Returned for a ‘Non-Filer’:

On 7/24/2024, ED reversed guidance provided the previous month on how to resolve scenarios when a contributor indicates ‘non-filer’ and FTI is returned on the ISIR for that contributor.  Schools must now request tax filing documentation from the affected contributor and use information from that documentation rather than the IRS FTI from the ISIR to make corrections.  There are discussions within the higher education community about whether updates/corrections completed from June 17 through July 23 based on the old guidance need to be redone.  Some schools are electing to only apply the new guidance beginning July 24 when it was published while others are electing to redo the work done using the original guidance.  Barring more specific requirements from ED, Regent does not offer an opinion on whether corrections/updates made per the original guidance must be redone and refers clients to their compliance/legal teams for direction.

  •  June 17 Guidance:  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.

  • July 24 Guidance:  When resolving the conflicting information, a school must confirm the student’s or contributor’s tax information by requesting documentation from the student or applicable contributor. Appropriate documents to collect include either IRS tax transcripts or signed copies of the 2022 income tax return and applicable schedules. The school must use the collected documentation to correct the conflicting financial information and submit it as a correction to the FPS. Schools must update all the manual entry data fields associated with financial and tax information (e.g., tax filing status, AGI, foreign income exclusion, and earned income credit). While the action is not a professional judgment (PJ), the school must also set the PJ flag to force the FPS to use the manually entered financial and tax information in the SAI calculation. 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.

  • Resolving Conflicting Information (Updated July 24, 2024) | Knowledge Center

(Added 7/25/2024):  There are instances where FTI indicates that a student is a “non-filer” for US taxes but there is income from foreign sources reported manually. In these circumstances, the ISIR would have the IRS Response code of 214 (did not file) along with self-reported tax and income data. If the reported income was foreign, this is not considered to be conflicting information.

  • Some Students/Student Spouses in this category can be identified reviewing students assigned an Office Use Only document who did not file a US tax return but entered ‘yes’ for filing a non-US tax return. There is no setting or ISIR field to specifically identify an amount of foreign income.

  • Parent/Parent Spouses or Partners have more granular settings in this section (aligning with the FAFSA) to identify whether a non-US tax filer had foreign income.

 (Added 8/4/2024) On August 1, 2024 ED further clarified the requirements for document collection and review when a ‘non-filing’ contributor has FTI returned on the ISIR. This update noted that it is incorrect to assume that any blank FTI fields are actually zero and also requires schools to review any corrections made prior to implementing the 7/24/2024 guidance to ensure they comply with current requirements.

(Added 8/4/2024) ED announced on 7/30/2024 that they will NOT support the batch ISIR Corrections process for 2024-2025. Clients will not be able to export and send to FPS any updates or corrections made in Regent.

  • In May, we recommended that schools make ISIR changes via the FPP portal rather than waiting for the batch ‘Export ISIR Corrections' process in Regent to be supported by ED. With this update, ALL updates or corrections must be made manually via the FPP portal. Regent systems will receive the changes upon import of the resulting ISIR transactions from FPS.

  • ED confirmed guidance is still forthcoming on how schools are to complete the required V4/V5 updates for 2024-2025.

  • Clients using automated SAIG file processing may wish to inactivate the message class for 2024-2025 ISIR correction files. ED has indicated that any such files received will be deleted.

image-20240804-143201.png

 

What is the Student Aid Index and how is Pell Grant eligibility determined? (Updated 3/28/2024)

Information about SAI calculations and Pell Grant scheduled award calculation is available at 2024-25 Draft Student Aid Index (SAI) and Pell Grant Eligibility Guide

The SAI can be negative, with possible values from -1500 to 999,999. Needs analysis will still subtract the SAI and Other Financial Aid from the Cost of Attendance, but the impact of a negative SAI on needs analysis is still being studied by FSA. ED has announced that a student cannot be awarded above COA because of a negative SAI.

  • (Added 5/1/2023) We have been advised that if the SAI is negative, a ‘zero’ will be used in place of the SAI in need analysis. This is something that Regent will manage.

  • (Added 7/7/2023) The Law does not support alternate SAI calculations for 2024-2025 enrollment periods that are not 9 months in length. However, Cost of attendance must still be adjusted to cover the actual awarding period. This can result in significantly lower need than expected for shorter periods and unexpectedly high need for longer periods. ED has promised guidance on how this should be handled for the 2024-2025 FAY.

    • (Updated 9/5/2023) For 2024-2025, the SAI as calculated will be used in all cases even if the period being packaged is not a full academic year. The Cost of Attendance must still be prorated to cover only the period being packaged. This means that for shorter periods, need may be less than anticipated and it may be greater than expected when periods longer than an academic year are packaged.

Non-tax filers will have -1500 SAI. If a tax-filing student is eligible for Maximum Pell and the calculated SAI is greater than zero, the SAI will be zero.

  • (Updated 9/5/2023) If the Maximum Pell determination was due to IASG or Children of Fallen Heroes eligibility, the SAI as calculated will be used when awarding funds other than Pell.

Pell eligibility determination is closely tied to SAI calculation and is a 3-step process using key FAFSA elements, tax filing marital status, the number of child dependents, and poverty threshold qualifications per the Health and Human Services Federal Guidelines for the FAFSA tax year.

  • Step 1: Does the student qualify for ‘Maximum Pell’, if not, then…

  • Step 2: Is the Calculated Pell (Maximum Pell minus SAI) greater than or equal to the Minimum Pell Amount, if not, then…

  • Step 3: Check to see if the student might still be eligible for Minimum Pell.

Below is a summary of the 3 steps and the eligibility requirements.

We understand that the current Pell formulas will continue to apply, but we will no longer adjust awards for Full-Time, Three-Quarter-Time, Half-Time, or Less-Than-Half-Time enrollment levels. We will be using ‘more of a formula’ to calculate the 'level of intensity of participation. FSA has not yet shared this formula with software vendors and our last report is that they are still working on it. (Update follows)

  • (Updated 5/1/2023) Once the Scheduled (full year, full time) Pell Award is determined for term or subscription-based programs, it is adjusted by the Enrollment Intensity Percentage (EIP) to get the Annual Pell Award.

    • The EIP is determined by dividing the number of units the student is taking for the payment period into the number of units required for full-time study for the payment period.

    • The Scheduled Pell Award is multiplied by the EIP to get the Annual Pell Award.

    • Current rules are applied to the Annual Pell Award to determine the amount for the payment period (such as dividing the amount by 2 in a semester-based program). Formulas 1, 3, 4, and so forth continue to apply.

    • Pell Rounding rules: (Updated 9/5/2023)

      • (Updated 9/5/2023) Standard Rounding for Pell Disbursements: After careful review of sample students in the ED Webinars, it appeared that the Pell rounding rules have changed. We checked with ED and received the following: “The up/down rounding is traditionally when you have the same disbursement amounts across several payment periods and you are trying to maximize Pell without exceeding the full-time scheduled Pell award.  With different disbursement amounts in each payment period, you should just follow the normal (round up if .5 or greater and round down if less than .5) rounding rules (unless you pay in cents). “ Regent has updated business requirements accordingly.

    • Current rules for Pell Recalculation Dates/Census Dates have not changed.

  • (Added 6/1/2023) For Year-Round Pell, At Least Half-Time Enrollment will no longer be required to award the additional 50% Pell. The new Enrollment Intensity Percentage will be applied when awarding all term-based Pell.

  • (Added 6/1/2023) ED published Draft 2024–25 FAFSA Specifications Guide (May 2023 Update) | Knowledge Center yesterday evening. This documentation more consistently excludes Alternate SAI calculations from the ISIR layout than has previous guidance. NASFAA and others have requested guidance on this, as has Regent. We will keep you posted. (Please see 7/7/2023 update near the top of this section).

  • (Added 7/7/2023) Beginning with 2024-2025, a FAFSA question asks whether students meet the requirements for Iraq and Afghanistan Service Grant (IASG) or Children of Fallen Heroes (CFH). Depending on whether or not a comment code will reflect a positive response, Regent will bring these to user attention either via a comment-code-triggered document or with an updated IASG task. Users will make an ISIR correction to set an IASG or CFH flag for an eligible student. An otherwise Pell eligible student (hasn’t exceeded LEU, etc.) with an IASG or CFH flag will be eligible for Maximum Pell. There will no longer be a separate IASG federal fund. (Update 1/12/2024 - the flag update will be via the new FAFSA Partners Page which is replacing FAA Access)

  • (Added 3/28/2024) Regent’s SAI calculations reflect the updated Income Protection Allowance table and related changes published on January 30, 2024.

  • (Added 3/28/2024) The 2024-2025 Pell Grant Maximum Award amount will be the same as it was for 2023-2024: $7395. The Pell Grant Minimum Award for 2024-2025 is $740.

How will the upcoming COD upgrade affect processing until the aligning 6.7.2 Regent upgrade? (Added 4/3/2024)

COD currently plans to upgrade to the new 5.0b schema on April 21, 2024.  Please be advised about the following during the short period before Regent’s aligning 6.7.2 upgrade will be released:

 Clients will continue to be able to process Pell and Direct Loan Common Record files originations and disbursements for 2023-2024.

 2024-2025 COD functionality will not be available in Regent until 6.7.2 is in place in Production, so no 2024-2025 origination or disbursement files will be created.

 FAY-specific reconciliation and rebuild files for 2023-2024 and prior years should continue to process successfully.  However, clients must ensure that no reconciliation, year-to-date or other rebuild files are requested for the 2024-2025 FAY until after the Regent upgrade.  A change in format for the 2024-2025 FAY could cause data issues should such a file be requested, generated, and imported prior to the Regent upgrade, although there is likely no such data available to be returned as yet.

Certain unsolicited COD files, such as those for promissory notes and entrance counseling will be created by COD in the new 5.0b schema and will not be supported within Regent during this period. Clients must store these files and not import them until the aligning Regent upgrade

Ensure the ‘Transmit/Import Manually’ box IS checked for any of these files available in Processes à SAIG à Message Class Setup no later than April 21, 2024:

  • CO -Credit Override 

  • BN - Response - Booking Notification  

  • EC - Response - Counseling Acknowledgement 

  • ND - Response - Negative Disbursement 

  • SP - Response - PLUS Application Acknowledgement  

  • PN - Response - Promissory Note 

  • SU - Response - SULA Acknowledgement

  • AC - Response - TEACH Grant Counseling

  • WB - Response - Web-Initiated 

  • CS - Response- Credit Status 

  • IB - Response- Informed Borrower

Upon upgrade to 6.7.2, clients should revert the unsolicited COD file Message Class setups as desired

 

What has Regent been doing to prepare for the upcoming 2024-2025 changes (Updated 3/28/2024)?

  1. Financial aid compliance staff have been briefing the Senior Team with information and anticipated impact as it becomes available.

  2. Regent staff have been meeting with FSA every two months since July 2022 and attend all available NASFAA and Department of Education webinars.

  3. Product Managers have been leading internal planning discussions and have developed an internal issue tracker as the scope of these changes will impact many aspects of our current Regent products.

  4. Published materials are under review and analysis.

  5. Team members are being given analysis assignments for the currently available materials:

    1. 2024-25 FAFSA Specifications Guide: Volume 4 - Record Layouts and Processing Codes (ed.gov)

    2. 2024-25 Draft Student Aid Index (SAI) and Pell Grant Eligibility Guide

    3. COD Technical Reference 2023-2024 Volume 4 - Campus-Based Record Layout (added 3/8/2023)

  6. (Updated 5/1/2023) The Product Management team is drafting Business Requirements for development as information becomes available.

  7. (Updated 7/7/2023) As Business Requirements are drafted, the Regent team is estimating resources and prioritizing work for 2024-2025 regulatory needs. However, we are still pending significant guidance from ED. Department presenters announced during the NASFAA Conference that volumes 2 and 3 of the FAFSA Specifications Guide are now expected ‘this month’ (previously we were expecting these in June), and there is an 18-page FAFSA Simplification Implementation Dear Colleague Letter in the final stages of review. We hope the DCL will address a high number of the open questions which have been presented to ED.

  8. (Updated 9/5/2023) We have received some new updates to the draft FAFSA Specification Guide in Volumes 4, 7 and 8. These updates are currently under review at Regent. FAFSA Specification Guide links are:

(Updated 11/8/2023) The 6.6 Product Brief Early Draft - Customer Zone Knowledge Base was published to clients on November 3rd. Please review this document for 2024-2025 implementation information related to Regent’s 6.6 release.

(Updated 3/28/2024) Regent continues to meet regularly with Department of Education staff and to review the daily updates now being provided by the Department for the financial aid community. Business Requirements are updated to reflect any changes and those with immediate impact are slotted into our product development roadmap.

(Updated 3/28/2024) Please see 6.7.0.0 Release Notes for the most recent updates on the next Regent release.

What can Institutions do to prepare for the upcoming changes? (Updated 3/28/2024)

(Added 4/6/2023): Additional federal resources:

(Added 5/1/2023): Consider the impact of the SAI on any of your institution’s awarding rule sets. If you currently use the EFC for awarding funds like SEOG, how will you adjust for SAI’s that could be as low as -1500? The requirement to use the Enrollment Intensity Percentage (EIP) only applies to Pell. You can continue to use traditional enrollment levels such as Full-Time or Half-Time for other funds, including SEOG.

(Added 6/1/2023)

  • See the FAFSA Changes section above and plan how you will adapt to data needs that will no longer be met by the 2024-2025 FAFSA. For example, housing status and marital status date are not included in the draft materials for the 2024-2025 FAFSA and ISIR layout..

  • Additional Federal resources:

  • (Added 8/1/2023) Our most recent correspondence from ED confirms that SAR/FSS comment codes are going to be updated and renumbered. A comment code number meaning one thing for years up through 2023-2024 may mean something else beginning with the 2024-2025 FAY. Recommend clients identify any active FAY-scoped documents configured for ‘All FAYs’ with ISIR assignment triggers such as comment codes. Once final information is available from ED on comment codes and ISIR fields,, these documents may need to be sunset with the 2023-2024 FAY and new document requirements configured for 2024-2025 forward. ('FSS' is FAFSA Submission Summary - the new name for the Student Aid Report or SAR).

  • (Added 9/5/2023) “All FAY' Document Requirements: Review any document requirements at your institution that are configured for ‘All FAYs’ to identify any for which the ISIR Assignment criteria may be changing beginning with the 2024-2025 FAY. Start planning to sunset document requirements that will no longer apply after the 2023-2024 FAY and for tracking configuration of any new documents for the 2024-2025 FAY. The ‘All FAYs’ setting may no longer be appropriate for some of your documents due to ‘FAFSA Simplification’ changes.

  • (Updated 11/8/2023) 2024-2025 document requirements should be in place in your system before you start importing 2024-2025 ISIRs. We recommend reviewing your ISIR-assigned documents now to determine what will be needed for the new FAY.

    • The General tab of Document Setup in Regent is being enhanced with a new checkbox so the user can elect to configure documents assigned at ISIR import for FAYs up through 2023-2024.

    • A script will run automatically when you upgrade to 6.6 to update all current ISIR-assigned documents so the checkbox is checked.

    • If the checkbox is checked, the user will be presented with the current (2023-2024) ISIR assignment options.

    • The option’s default is unchecked, which means the user will be presented with ISIR assignment setup options reflecting the new 2024-2025 ISIR layout, comment codes, etc.

    • Please see 6.6 Product Brief Early Draft - Customer Zone Knowledge Base for more detail on setting up 2024-2025 document requirements in Regent.

    • 2024-2025 FAFSA Specifications Guide Volume 7 - Comment Codes contains the current version of the 2024-2025 comment codes. As noted above, the numbers have all been reassigned this year.

    • (Added 8/20/2024) Clients must configure new document requirements for 2024-2025, including if the requirements use any ISIR assignment options. However, this excludes Student Scoped documents that are not assigned by the ISIR. In this case, clients should not create a new 2024-2025 document.

  • (Added 8/1/2023) For your reference, here are the most recent draft volumes of the FAFSA Specification Guide.

Introduction 2024–25 FAFSA Specifications Guide Introduction in PDF Format, 8 Pages, 332KB

Volume 2 – FPS Schedule and Getting Help 2024–25 FAFSA Specifications Guide Volume 2 – FPS Schedule and Getting Help in PDF Format, 16 Pages, 748KB

Volume 3 – Electronic Data Exchange and FAFSA Processing 2024–25 FAFSA Specifications Guide Volume 3 – Electronic Data Exchange and FAFSA Processing in PDF Format, 17 Pages, 588KB

Volume 4 – Record Layouts and Processing Codes 2024–25 FAFSA Specifications Guide Volume 4 – Record Layouts and Processing Codes in PDF Format, 196 Pages, 2MB and 2024–25 Draft ISIR Record Layout in Excel Format, 91KB

Volume 5 – Edits and Rejects 2024–25 FAFSA Specifications Guide Volume 5 – Edits and Rejects in PDF Format, 39 Pages, 605KB

Volume 6 – ISIR Guide 2024–25 FAFSA Specifications Guide Volume 6 – ISIR Guide in PDF Format, 46 Pages, 915KB

Volume 7 - Comment Codes 2024-2025 FAFSA Specifications Guide Volume 7 - Comment Codes

Volume 8 - Agency Matches 2024-2025 FAFSA Specifications Guide Volume 8 - Agency Matches

  • (Added 9/5/2023) Custom Scripts and Communications: Review custom scripts and communications in production at your institution to identify any that may need to be updated to accommodate changes to ISIR fields for 2024-2025. Open CZ tickets to initiate review of any affected items and identification of next steps.

  • (Added 11/8/2023) Ensure you have complied with requirements in EA GEN-23-86: Actions Required for New E-App Site

    • ECAR corrections must be made by 11/17/2023 on the current E-App website to ensure they are processed before the changeover to the new site.

    • Third Party Servicers should do the same for their TPS Data Forms.

    • ED recommends that users should download or print the following by the 11/24/2023 as that is the last day they can access the current system. These will be copies for the student files and will be available should there be any need to re-enter data in the new online system:

      • Current ECAR

      • Any acknowledgement and approval notices and letters that the school has not already saved.

      • The school’s Application data (for cases in which a school recently applied, but that application has not been processed)

    • Also, in order to receive 2024-2025 ISIRs, be sure your institution has completed the new FTI-SAIG Enrollment Agreement. See Updated SAIG Enrollment Agreement Available Oct. 23, 2023 – Required Steps to Receive 2024–25 ISIRs

  • (Added 12/1/2023) - Review two new resources NASFAA has provided in the ‘Tools and Resources’ section of their FAFSA Simplification Web Center (nasfaa.org):

    • Comment Codes Crosswalk: Maps the new 2024-2025 Comment Codes back to their 2023-2024 counterparts.

    • Campus Partners Brief on FAFSA Simplification: Provides a summary for those outside of the financial aid office about the potential impact of the 2024-2025 changes.

What is the timeline for these changes? (Updated 4/16/2025)

These changes are required by Law to be in place for the 2024-2025 FAY and FSA has committed publicly to being ‘on track’ for a 2024-2025 implementation. That said, FSA has not yet committed to opening the FAFSA to applicants on October 1, 2023. As the FAFSA must be available by January 1, 2024, implementation will fall somewhere between October 1, 2023 and January 1, 2024.

Software vendors, NASFAA, and institutions of higher education are among those who are very concerned about the rapidly narrowing window for FSA to make related policy and process decisions, for technical specifications to be published, etc. Regent is planning significant development efforts during Q3 and Q4 2023.

(Added 4/6/2023): The 2024-2025 FAFSA will be made available to applicants in December 2023. Given the complexity of the underlying development required to support the new FAFSA and its processing systems, we have also heard ‘before January 1, 2024’. We anticipate a late December go live for the 2024-2025 FAFSA.

(Added 8/1/2023): Capability to create and transmit the COD Federal Work Study data files is scheduled for the Fall release so schools can submit data by the FAFSA opening date in December.

(Added 11/8/2023) The 6.6 Release includes full 2024-2025 ISIR import functionality. However, due to delays in the provision of technical guidance for the new TD Client version in support of the FTI-SAIG mailbox, the 6.6 Release does not support the 2024-2025 SAIG Mailbox integration.

  • The TDClient upgrade and technical guidance is scheduled to be released early/mid-November from the Department. Therefore, clients will not be able to download 2024-2025 ISIRs via the SAIG mailbox until the Department’s guidance is released and implemented. Once Regent has reviewed the new version, guidance will be provided to clients on any enhancements or special treatment required for the new TD Client version. SAIG integration for prior years will continue to work as expected.

  • In the meantime, clients must sign and submit new FTI SAIG Enrollment Agreements with the Department of Education and those agreements must be approved before 2024-2025 ISIRs will be made available to them. Please see Updated SAIG Enrollment Agreement Available Oct. 23, 2023 – Required Steps to Receive 2024–25 ISIRs (Updated Oct. 23, 2023) | Knowledge Center for instructions.

(Added 12/1/2023): Electronic Announcement General 23-100 published on November 15th provides the following timeline updates:

  • The 2024-2025 FAFSA will open by December 31, 2023.

  • Schools will begin receiving 2024-2025 ISIRS by the end of January 2024

  • Students can begin making corrections and updates by the end of January 2024.

  • Institutions will be able to make corrections in the ‘weeks following’ the January date.

  • The (unpaid) Preparer role for FAFSA on the Web is deferred until the 2025-2026 FAY.

(Added 3/28/2024): Electronic Announcement General 24-27 published on March 25th provides the following timeline updates:

  • Students will be able to make FAFSA corrections in the first half of April

  • ISIR reprocessing for ISIRs where dependent assets were not properly treated in SAI calculation will begin ‘shortly after student corrections are made available’

The date when schools are expected to be able to make corrections was not noted in this communication.

(Added 4/16/2025): On April 14, 2025, ED announced that institutions can now request specific ISIRs or groups of ISIRs for 2024-2025 and 2025-2026 from FPS.  They are asked to limit requests to a one-month time range for the present.  Specific steps are on page 11 of 2025-26 FAFSA Specifications Guide: Volume 3 - Electronic Data Exchange and FAFSA Processing.  See 2024-25 and 2025–26 FAFSA® Updates | Knowledge Center for the announcement.