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FAQ on 2025-2026 Federal Processing Changes for Regent Clients

FAQ on 2025-2026 Federal Processing Changes for Regent Clients

This page provides Regent clients with updates on Federal financial aid changes to Federal Student Aid plans for 2025-2026, 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 2025-2026 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 2024-2025 FAQ: FAQ on 2024-2025 Federal Processing Changes for Regent Clients - Customer Zone Knowledge Base - Confluence

 

Update to the 2025-2026 Standard Regent Review Document List (Added 5/5/2025)

The 2025-2026 Standard Regent Review Document List included in the 6.10 Product Brief was updated.

  1. The following documents now include more descriptive language to address the “an ISIR without a PJ”.  For these documents all comment codes should be selected except the 300. The language in Document Description now includes the section in red: Assigned by ISIR - VeriTrackFlag=V1 or V5, and All ISIR Comment Codes EXCEPT 300 (which translates to "an ISIR without a PJ"),

  • 2023 Student W-2s/1099s/Other Income for Unmarried Tax Filer

  • 2023 Student W-2s/1099s/Other Income for Married Tax Filer

  • 2023 Spouse W-2s/1099s/Other Income for Tax Filer

  • 2023 Parent W-2s/1099s/Other Income for Unmarried Tax Filer 2023ParentSpousePartner W-2s/1099s/Other Income for Tax Filer

  • 2023 Parent W-2s/1099s/Other Income for Married Tax Filer

 

  1. For the following documents, the option Successful Request was added to their associated IRS Response Code field(s). Currently these documents will be created in a Needed status when the IRS Response Code indicates they do not have a successful request. When a subsequent ISIR with a ISIR Response Code set to Successful Request is set as active, then the document will be auto waived.  Adding the Successful Request to the IRS Response Code field is optional and only needs to be included if the client would like the document to be created in a Waived status if the initial ISIR contains the ISIR Response Code of Successful Request. There is no action needed for this document, so it will only be added to the student's account for the client to see the document. 

  • 2023 Parent Joint Tax Transcript/Tax Return

  • 2023 Parent Tax Transcript/Tax Return

  • 2023 Parent Spouse or Partner Tax Transcript/Tax Return

  • 2023 Spouse Tax Transcript/Tax Return

  • 2023 Student Joint Tax Transcript/Tax Return

  • 2023 Student Tax Transcript/Tax Return

 

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 Regent Support 2025-2026 processing at COD? (UPDATED 3/24/2025)

IMPORTANT UPDATE 3/24/2025:

Certain unsolicited COD files, such as those for promissory notes and entrance counseling will be created by COD in the new 5.0c schema and will not be supported within Regent until 6.10 is in Production. Please update your SAIG message class configurations to Inactivate the following message classes in the list below until you have upgraded to 6.10. Any such files received to date or manually should be held and not imported until after 6.10 is in place.  Clients using Regent’s SAIG integration will need to reenable the affected message classes after the 6.10 upgrade.

Note: Any such files for which import was attempted and failed to import prior to a Regent 6.10 Production upgrade can be reattempted post-upgrade by downloading the files from the Process Log or from the sFTP location in the CODLoad folder.

  

  1. BN - Response - Booking Notification  CRBN25OP

  2. EC - Response - Counseling Acknowledgement  CRECMYOP

  3. ND - Response - Negative Disbursement  CRND25OP

  4. SP - Response - PLUS Application Acknowledgement  CRSP25OP  

  5. PN - Response - Promissory Note  CRPN25OP

  6. AT - Response - TEACH Grant Agreement  CRAT25OP

  7. AC - TEACH Counseling Acknowledgement CRAC25OP

  8. WB - Response - Web-Initiated  CRWB25OP

  9. CS - Response- Credit Status Change  CRCS25OP

  10. IB - Response- Informed Borrower  CRIB25OP

  11. DL-Response Documents Direct Loan CRDLMYOP  (rare)

  12. PG-Record Response Pell CRPGMYOP (rare)

 

(Posted 3/7/2026) COD currently plans to upgrade to the new 5.0c schema for 2025-2026 processing on March 23, 2025.  Regent’s aligning 6.10.0 upgrade release is scheduled for ~late March, March 31, 2025, subject to change.

Please be advised about the following for the period between the March 23, 2025 upgrade at COD and the client’s upgrade to 6.10.0 in Production:

  1. Clients will continue to be able to process Pell and Direct Loan Common Record files originations and disbursements for 2024-2025. 

  2.  2025-2026 COD functionality will not be available in Regent until 6.10.0 is in place in Production, so no 2025-2026 origination or disbursement files will be created in Regent.

  3. FAY-specific reconciliation and rebuild files for 2024-2025 generated during this time should continue to process successfully during this period and into the future.  Due to changes in the creation of these files for years prior to 2024-2025, these types of files for years prior to 2024-2025 may not import correctly. Regent is scheduling work to address these changes.

  4.  Clients must ensure that no reconciliation, year-to-date or other rebuild files are requested for the 2025-2026 FAY until after upgrading to 6.10.0.  A change in format for the 2025-2026 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 2025-2026 data available to be returned as yet.

  5. (Obsolete - see above, as this section was updated above on 3/24/2025) Certain unsolicited COD files, such as those for promissory notes and entrance counseling will be created by COD in the new 5.0c schema and will not be supported within Regent during this period. These files will not be pulled in from SAIG with Regent automation until 6.10.00 is in place and those message classes are active.  Any such files received manually should be held and not imported until after 6.10.0 is in place. 

    1. CO -Credit Override 

    2. BN - Response - Booking Notification  

    3. EC - Response - Counseling Acknowledgement 

    4. ND - Response - Negative Disbursement 

    5. SP - Response - PLUS Application Acknowledgement  

    6. PN - Response - Promissory Note 

    7. SU - Response - SULA Acknowledgement

    8. AC - Response - TEACH Grant Counseling

    9. WB - Response - Web-Initiated 

    10. CS - Response- Credit Status 

    11. IB - Response- Informed Borrower

 

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.

 

What is the 2025-2026 Timeline? (Updated 1/24/2025)

(8/26/2024) Regent development for 2025-2026 awarding and ISIR support, as well as the Access application for our client states, is dependent on the availability of information from the Department of Education (ED).  Once published, the guidance must be reviewed and then used to drive business requirements, functional requirements, development work and then testing. Much of the guidance is not standalone and depends on other guidance.  For example, calculation of an SAI by Regent is dependent on more than just the updated SAI formula – all underlying ISIR tables and reject scenarios must also be in place before Regent can calculate an SAI.

  •  We at Regent are definitely aware of the importance of timely delivery of 2025-2026 functionality to our clients.  Our roadmap priorities are to ensure speed to release doesn’t cause us to lose our focus on compliant and correct processing, as well as on all the other support we provide to our clients. 

  •  ED 2025-2026 Release Strategy: ED has posted some initial information on the 2025-2026 FAFSA/ISIR processing timeline.  ED will make the 2025-2026 form available to a small number of users starting on 10/1/2024.  During the next two months, any bugs or issues will be identified/worked and additional functionality will become available.  The target is to have the application fully available ‘on or before December 1.”  The commitment is to launch ‘full functionality, including submission, processing, and corrections at the same time.’ 

  •  Note that Regent attended a call on 8/8/2024 where the commitment was clarified to have all functionality currently available for 2024-2025 available for 2025-2026 by 12/1/2024. Batch ISIR corrections would thus not be included under that umbrella, which aligns with previous ED information that batch ISIR correction functionality may not be available until 2026-2027.

  •  ED has not yet advised how this rollout will be structured nor if/how any software provider ISIR support is expected to be part of the process.

  •  Regent has been advised by ED that there will be no draft paper FAFSA published for 2025-2026 and that the final version will not be available until the FAFSA officially opens.

  •  For more information on the FAFSA launch, see:

  •  On 8/23/2024, ED posted the first drafts of a few volumes of the 2025-2026 FAFSA Specifications Guide.  The Introductory volume (2025–26 FAFSA® Specifications, Introduction (ed.gov)) included a roadmap for when 2025-2026 technical guidance should be released. 

    •  Please note that some key items needed to fully process the 2025-2026 ISIRs (such as Comment Codes) are not planned for release until November 2024. 

image-20240826-111725.png

  • (Added 10/12/2024) Per the 2025–26 FAFSA® Specifications Guide, Volume 1 – Summary of Changes (ed.gov) published on 10/8/2024, ED plans to support Batch ISIR Corrections at some point during the 2025-2026 processing cycle.   “Until this functionality is available, institutions can use the FAFSA Partner Portal to submit individual corrections.”  The Regent Roadmap includes work to support 2025-2026 correction files based on specs published to date. We will update the Roadmap as necessary when ED publishes more information on the timing of this support and to address any additional specifications or requirements.

  • (Added 1/24/2025) General release of Batch ISIR Corrections functionality is now expected to occur before the end of February for both 2024-2025 and 2025-2026.  See the Update on timeline for batch corrections processing for 2024–25 and 2025–26 FAFSA forms | Knowledge Center for the 1/17/2025 Electronic Announcement on this topic.

    • With 6.9.1, Regent already supports batch processing for both 2024-2025 and 2025-2026.

    • Clients were advised during the 2024-2025 implementation cycle that they should NOT send any ISIR correction batches prior to ED fully supporting them as those files may be deleted by ED. In the 1/17/2025 Electronic Announcement, ED confirmed they will be deleting any batches already received prior to their full delivery of the functionality. We recommend clients disable any ISIR Correction-related SAIG message classes within Regent to ensure no files are inadvertently sent, and if there are any pending ISIR correction files waiting to be sent, please review these and confirm the corrections are still needed.

  • (Added 1/24/2025) The target for ED to implement NSLDS Postscreening has been pushed back to ‘Spring 2025’.

    • For the next few months, schools will still not receive new ISIRs when there are significant post-screening changes to a student’s financial aid history at NSLDS. The 1/17/2025 Electronic Announcement NSLDS Post-screening and new data files | Knowledge Center notes that the “Department recognizes the ongoing administrative burden that this delay represents.” 

    • Starting at the end of January, ED will provide a monthly Excel report to schools via the COD Reporting Website (not SAIG) to identify students with such changes so the school can request FAH (FA History) records on them or research them manually at the NSLDS website. 

    • Regent generally recommends that schools request FAH data regularly on all their Active students so Regent can adjust awarding as appropriate for aggregate/lifetime amounts and such, but we also encourage our clients to visit their COD reporting sites to access the new monthly reports until post-screening ISIRs are in production for 2024-2025 and 2025-2026. 

When will we start receiving 2025-2026 ISIRs? (Updated 4/16/2025)

On 9/30/2024, ED published Launch of 2025–26 FAFSA Beta and Implications for Institutions and State Agencies.

 Of critical importance to our client institutions is that even if they are not participating in the initial Beta rounds for the 2025-2026 FAFSA, a student who is participating with another organization may list the school code of a non-participating institution.  If this happens, the resulting 2025-2026 ISIRs will be placed in the FTI-SAIG mailbox for all institutions listed on the ISIR beginning this week.

 For our Access clients, you should likewise receive 2025-2026 ISIRs for participating students in your states.

 These are official, production ISIRs.  You are not obligated to pull them down now, and in any case, Regent Award and Review are not yet ready to receive, import, or process ISIRs for the new year. But, if you receive any 2025-2026 ISIRs from FTI-SAIG, be sure to retain them safely for use when you do start processing for the new year.  Do not discard any 2025-2026 ISIRs received from FTI-SAIG under the assumption that they are ‘just beta’.

 You may elect to review these production ISIRs in the FAFSA Partner Portal and/or, in Regent after our initial 2025-2026 regulatory release is certified. If you do so and find any issues, please report them to us via CZ tickets and report to ED per the instructions in the 9/30/2024 communication noted above.

(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.

 

What are some changes for the 2025-2026 Verification Worksheet? (Updated 6/20/2025)

(Added 1/17/2025) Regent will provide the 2025-2026 Verification Worksheet (VWS) to clients out of band as a standalone smart form update (meaning no release is required for this initial update). 

 There are 3 enhancements that cannot be delivered out of band and these are slated for Release 6.10, targeted for certification ~mid-March.  These enhancements are intended to further automate verification review that financial aid administrators have managed with manual oversight for ISIRs received before the 6.10 upgrade.

  1.  A 2025-2026 student or parent contributor is not required to verify Family Size if the number of manually reported Family Size members is the same as the number of Exemptions provided by the IRS on the ISIR. The VWS Family Size information grid will no longer be presented to applicants after Release 6.10 when these numbers match on 2025-2026 ISIRs selected for verification. The grid will still be presented to all V1/V5 applicants in the out of band VWS smart form, but with the 6.10 enhancement it will only display when the IRS and manual numbers do not align.

  2.  A non-student contributor without an SSN/ITIN will be asked to confirm they do not have an SSN/ITIN (will also be added to the 2024-2025 VWS) rather than having the verifying official request confirmation via a means determined by the institution.

  3.  A student or parent who filed Married Filing Joint (MFJ) for the base year but is now married to a different spouse and is selected for V1 or V5 verification will automatically be assigned W2/1099 document requirements. (Existing document requirement configuration options can take care of this if the MFJ student or parent is currently unmarried).  Prior to 6.10, the verifying official manually assigns these document requirements when the scenario is identified during verification review of ISIR data.

(Added 6/20/2025) New Identity/SOEP Verification Requirements

On June 6, 2025 ED published changes to Identity Verification requirements in Significant Actions to Prevent Fraud through Identity Verification | Knowledge Center  and 

U.S. Department of Education to Implement New Identity Validation Processes to Combat Student Aid Fraud | U.S. Department of Education

  • Stop SOEP Assignment: While some of the changes are pending additional guidance from ED, clients can now stop assigning the Statement of Educational Purpose (SOEP) to V4/V5 students by disabling the ISIR Process for the 2025-2026 Proof of Identity/Statement of Educational Purpose document via the ISIR Assignment tab in Document Setup.

  •  Assign Proof of Identity Document Requirement: In order to continue collecting the Proof of Identity for V4/V5 students we added a new 2025-2026 Proof of Identity document to the:

    • Regent 2025-2026 Standard Document List:

    • Regent 2025-2026 Verification Document List (Updated):

    • Please check either list for the setup requirements and edit the messaging to reflect your institution’s approach to notary and video call completion when the student cannot appear in person.

  • 2024-2025 ISIRs: If clients still have significant volume of new 2024-2025 ISIRs to import, similar steps can be taken for aligning 2024-2025 documents. Our assumption is that as the 2024-2025 FAY is ending at the end of this month, even with the bump up in subsequent selections for V4/V5 earlier this week at some schools due to ED’s policy changes, those ISIRs have already been imported.

  • Regent Roadmap:  Regent has added the following aligning updates to the Roadmap:

    • Update the Verification Worksheet (VWS) to remove the Statement of Educational Purpose (SOEP) (RS-29840)

    • Update ISIR Correction Wizard to remove the SOEP Checkbox   (RS-29841)

 

What are some Key 2025-2026 Resources? (Updated 10/12/2024)

 SAI Calculations/Pell Eligibility

 ISIR Record Layout and Processing Codes (updated periodically at these links):

ISIR Layout Standalone Excel Document

ISIR Rejects and Edits

 (Added 10/12/2024) 2025-2026 Verification Requirements