Students who have previously attended other colleges may have a financial aid history that affects their eligibility for FSA funds at your school. You can review a student’s financial aid history by using the National Student Loan Data System (NSLDS) For Financial Aid Professionals online at https://nsldsfap.ed.gov; for questions call 1-800-999-8219. NSLDS will also help you track changes to the student’s financial aid history through the Postscreening and transfer student monitoring processes.
A student or parent generally isn’t eligible for Title IV funds if they are in default on a Direct Loan, FFEL Program Loan, or Perkins Loan or if they owe an overpayment on a Pell, TEACH, IASG, or FSEOG grant and have not made a repayment arrangement for the default or overpayment. Also, for a parent to receive a PLUS Loan, neither the parent nor the student may be in default on a Direct Loan, FFEL loan, or Perkins Loan or owe an overpayment on a Pell, TEACH, IASG, or FSEOG grant (though a parent in default on a loan does not make a student ineligible for Title IV aid). Exceptions to these general rules are noted in the discussion below.
Although there is a limited provision described in chapter 1 for regaining eligibility for Title IV aid on defaulted loans during the Fresh Start period, someone applying for Title IV funds must normally certify that they aren’t in default on any Direct Loans, FFEL Program loans, or Perkins Loans and don’t owe an overpayment on any Pell, TEACH, IASG, or FSEOG grant, or that they have made satisfactory arrangements to repay the overpayment or default. This certification statement is printed on the Free Application for Federal Student Aid (FAFSA). Parent PLUS borrowers make this certification on the Direct PLUS Loan Master Promissory Note (MPN). When reporting loans eligible for treatment under the Fresh Start Initiative, you should not change existing loan statuses, effective dates, or interest rates in NSLDS.
A student is also ineligible if they inadvertently exceed annual or aggregate loan limits. When this occurs, you must identify the loan(s) that resulted in the overborrowing and discuss the overborrowing with the student. The student can regain eligibility by repaying the extra amount borrowed or making arrangements, satisfactory to the loan holder, to repay it. See Dear Colleague Letter GEN-13-02 and Volume 8 for more details.
A student is ineligible if their property is subject to a judgment lien for a debt owed to the United States, and a parent can’t receive a parent PLUS loan if either the student or parent is subject to such a lien. For example, if the Internal Revenue Service (IRS) has placed a lien on a student’s property for failure to pay a federal tax debt or make satisfactory arrangements for repayment, the student would be ineligible for federal student aid.
A student who has been convicted of, or has pled no contest or guilty to, a crime involving fraud in obtaining Title IV funds must have completely repaid the fraudulently obtained funds to the Department or the loan holder before regaining aid eligibility. You don’t need to proactively collect certification from each student but you must restrict eligibility, as appropriate, if/when you become aware of fraud which has not been completely repaid.
When the FAFSA form is processed, the FAFSA Processing System (FPS) matches the student against the National Student Loan Data System (NSLDS) to see if they are in default, owe an overpayment, or have exceeded the loan limits. The FPS doesn’t perform any matches to determine whether or not the student is subject to a judgment lien for a federal debt, and you aren’t required to check for such liens. The FPS also doesn’t check for fund fraud, however, if you know that the person in question is subject to such a lien or has committed fund fraud, you can’t pay them Title IV funds.
NSLDS does not match Parent PLUS applicants against data in NSLDS. For more information about Parent PLUS applicants and default, see Volume 8.
When a student provides their parents’ tax return to the aid administrator, the financial aid administrator notices that the parents reported business income on their federal tax return but didn’t report a business asset on the FAFSA form. The student explains that they didn’t report the business as an asset because there’s a lien against the business for a federal loan. The aid administrator tells him that the asset must still be reported, and also that his parents won’t be able to borrow a PLUS Loan as long as they are subject to the lien.
The following current types of loans are listed in NSLDS:
Direct Subsidized Loans and Direct Unsubsidized Loans Direct PLUS Loans (for parents or for graduate/professional students) Direct Consolidation LoansThe following loan types from earlier programs also appear in NSLDS:
Federal Stafford Loans (subsidized and unsubsidized) Federal PLUS Loans Federal Perkins Loans Federal Consolidation Loans Federally Insured Student Loans (FISL) Guaranteed Student Loans Supplemental Loans for Students (SLS) National Direct Student Loans and National Defense Student Loans (predecessors of Perkins Loans) Income Contingent Loans (ICL) Financial aid history Loan limits and eligibilitySee Volume 8 for loan limits
Federal default and debtBecause Pell Grants have priority in packaging, aid overpayments can often be resolved by adjusting other types of aid in the package. If necessary, you can also adjust later grant payments for the same award year. But if a student receives more grant money than they are eligible for and the excess can’t be offset, the student must return the overpayment. As noted at the beginning of the chapter, a student with an outstanding overpayment is ineligible for aid until they repay it or make satisfactory repayment arrangements. See Volume 4, Chapter 3 for a complete discussion of resolving overpayments and overawards.
To help you identify students with problems such as defaulted loans or overpayments, the FPS matches the student against the NSLDS database to obtain their financial aid history. You must resolve any conflicts between NSLDS and other information you have about the student before disbursing Title IV funds (for example, if NSLDS shows that a student isn’t in default but you have documentation showing that they are in default). The results of the NSLDS match are provided on the FAFSA Submission Summary and Institutional Student Information Record (ISIR) (referred to as “output documents”) on the NSLDS Financial Aid History page. As with other matches, an FPS “C flag” code next to the student’s Student Aid Index (SAI) indicates problems that must be resolved.
Once an overpayment is reported to NSLDS, the student’s future FAFSA Submission Summary/ISIR will show that they have an overpayment. The financial aid history section of the FAFSA Submission Summary/ISIR will have information on the overpayment, including whether the student has made satisfactory repayment arrangements.
See Volume 4 of the FAFSA Specifications Guide for the complete tables of NSLDS match results.
The FAFSA Submission Summary and ISIR will contain the NSLDS financial aid history only if the student’s identifying information matches the database and there is relevant information for the student in the database. If the student has no defaults or overpayments or has made satisfactory repayment arrangements on a defaulted loan, the NSLDS match flag will be 1 and no C code will appear on the output document. A match flag of 2, 3, or 4 indicates that the student has defaulted loans, owes an overpayment, or both. You will need to document that the problem has been resolved before disbursing aid. Note that for “real-time” processing—if a student uses Corrections on the Web or an aid administrator uses the FAFSA Partner Portal (formerly FAA Access to CPS Online)—the FPS does not match against the NSLDS database (except when a school is added), but the output document will show NSLDS data from the last transaction that did match against NSLDS. The ISIR might not, therefore, reflect the most current information.
As noted above, you must resolve any conflicts between NSLDS and other information you have about the student before disbursing Title IV funds. If you can document that the student is eligible for FSA funds despite the information shown on NSLDS, you may award and disburse aid. For example, if the NSLDS Financial Aid History page of the FAFSA Submission Summary or ISIR shows that the student has a defaulted loan, but you have obtained documentation from the holder of the loan that the borrower has made satisfactory arrangements to repay the defaulted loan, you may disburse aid. You must retain all applicable documentation supporting the student's eligibility to receive FSA funds in the student's file.
A first-year undergraduate at School T has never attended college before. When School T receives the student’s ISIR, it shows that there was a partial match, and there is some data associated with her SSN. School T checks with NSLDS and learns that a guaranty agency is reporting a loan made years ago (when the student was in elementary school) under her SSN but with a completely different name and date of birth. School T determines that this isn’t the student’s loan, so she has no financial aid history in NSLDS. Turner also suggests that Lydia provide documentation that the SSN belongs to her so the school can request that NSLDS data be corrected to prevent problems for her later.
When the school receives Ben’s ISIR, it shows that there was a discrepancy with the NSLDS database, so no financial aid history information is provided. The FAA asks Ben if he provided the correct name and date of birth on the application. Ben says he wrote in the wrong month for his date of birth, but his name is correct. The FAA checks the NSLDS database using Ben’s first and last name, SSN, and date of birth. NSLDS shows the correct birth date, but the first name of the student is Warren, not Ben. She checks again with Ben, who explains that Ben is a nickname and Warren is his real name. The FAA determines that the financial aid history associated with the SSN belongs to Ben. If the ISIR was not rejected, the FAA could disburse aid without requiring a correction, but may also wait for the ISIR correction before disbursing aid. Note that race, ethnicity, and gender data will not be reported on the FAFSA Submission Summary or ISIR.
There are several reasons why an output document may not have financial aid history information: for example, if the application was rejected for lack of a signature or if identifying information was missing. For other cases, you can check the NSLDS flags reported in the “FAA Information” section.
Partial match. If the student’s Social Security Number (SSN) is in the NSLDS database but the first name or date of birth don’t match what the student reported, no financial aid history will be reported and the output document will have an NSLDS match flag of “7” and a C code. There will also be a comment explaining why the financial aid history isn’t given and directing the student to work with the school to resolve any discrepancies. A partial match requires resolution; otherwise you won’t have information from the Department on defaults and overpayments. If the student originally reported incorrect identifying information, you can have them submit correct information, which will be sent through the match again. If the student did not submit incorrect identifying information, you can call the NSLDS customer support center for help with determining the identifiers associated with the SSN in the NSLDS database. If you discover the discrepancy is due to the student misreporting the name or date of birth on the FAFSA form, you should have the student make a correction. However, you may use the NSLDS record to determine the student’s eligibility; you don’t need to wait for the corrected data to be reported. If you find that the financial aid history associated with the student’s SSN doesn’t belong to the student, you should assume that the student has no relevant financial aid information. You may request that the data in NSLDS be corrected by providing relevant supporting documents. NSLDS will work with the previous data providers to correct the identifiers. You aren’t required to request a correction; however, doing so will prevent the same FAFSA response in subsequent award years.
Student not in database. If a match with NSLDS is completed but there’s no information on the student in the database, the output document will comment that the student’s SSN is not associated with any financial aid history. You can assume this is correct unless you have conflicting information. If you believe NSLDS should show a loan history, help the student by contacting the appropriate loan servicer or, for a FFEL Program loan, guaranty agency.
No relevant history. If a student’s SSN matches a record in the NSLDS database but there’s no relevant financial aid history to report, no information will be on the output document, because it isn’t needed to determine the student’s aid eligibility for the current award year. Conversely, if a student has relevant prior data, for example a prior Pell award, that will appear on the FAFSA Submission Summary/ISIR. The FAFSA Submission Summary and ISIR will have a comment that the student’s record was matched with NSLDS but no information was found to print on the NSLDS page.
Processing problem. If there was a problem with the match, the FAFSA Submission Summary and ISIR won’t include financial aid history information. The output document will have a C code and a comment explaining that the FPS couldn’t determine whether the student has loans in default and will direct them to contact the financial aid administrator. You must get the student’s financial aid history before disbursing aid. If the student must make corrections of any kind, their information will go through the match again when the corrections are submitted, and you can use the results of that match to determine eligibility.
Once you receive the financial aid history through NSLDS, you aren’t required to check for changes to the data before disbursing funds to the student. But if you learn from NSLDS or another source that the student was not or is no longer eligible, you must not disburse any more Title IV funds and must help make sure the student arranges to repay the aid for which they weren’t eligible.
NSLDS uses a postscreening process to let you know when there are significant changes (such as a defaulted loan or an overpayment) to a student’s financial aid history. If postscreening identifies changes that may affect the student’s eligibility, the FPS will generate new output documents so schools that are listed for receipt of the student’s FAFSA information will automatically be notified. Items that have changed since the last transaction are marked on the output document with a “#” sign, and the reason code for the postscreening will be given.
To help you identify when NSLDS data has changed, the document will include an NSLDS transaction number in the “FAA Information” section with the other match flags. This is the number of the last transaction on which NSLDS data changed, so if you receive an ISIR on which that number is higher than the one on the ISIR you used to determine the student’s eligibility, you must review the NSLDS data on the new ISIR to be sure there are no changes affecting the student’s eligibility (be aware of the Pell Lifetime Eligibility Used (LEU) limits and codes; for more on Pell LEU, see Volume 7). There will be postscreening codes (see The FAFSA Specifications Guide, Volume 4, for the list) to help determine what changed.
NSLDS Support Center NSLSDS Support Center Phone Number 1-(800)-999-8219There is a flag in NSLDS for students whose pattern of enrollment and/or award history for either Federal Pell Grants or Direct Loans (other than a Direct Consolidation Loan or Parent PLUS Loan) is identified as unusual. You are required to respond to the unusual enrollment history (UEH) status for Pell Grants and/or Direct Loans as described below.
The FPS will flag the UEH on the student’s FAFSA Submission Summary/ISIR. A value of “N” requires no action, as it denotes no unusual history. A value of “2” or “3” in the UEH field (represented as FAFSA Submission Summary comment codes 276 and 277, respectively) requires review and resolution by your school (see below). UEH flags 2 and 3 do not necessarily mean the student has improperly received Pell Grants or Direct Loan funds, but it is a sign of unusual activity, for example, receiving Pell Grants and/or Direct Loans at multiple schools in the same semester, or receiving aid and then withdrawing before earning any credit.
To resolve a UEH flag of “2,” (FAFSA Submission Summary comment code 276) you must check the student’s enrollment and financial aid records to determine if, during any of the four award years prior to the current award year (i.e., 2020-21 , 2021-22 , 2022-23, and 2023-24 ), the student received a Pell Grant or Direct Loan at your school. If so, no further action is required unless you have reason to suspect that the student in question remains enrolled just long enough to collect student aid funds before withdrawing. In such a case, you must follow the guidance below for UEH flag “3.” If not, using information from NSLDS, you must identify all schools where the student received a Pell Grant or Direct Loan for any of the 2020-21, 2021-22, 2022-23, and 2023-24 award years. You must then determine whether academic credit was earned at each of those schools during the award year for which the student received a Pell Grant or Direct Loan. Based on those determinations, you may need to discuss further with the student. See for additional information.
To resolve a UEH flag of “3,” (FAFSA Submission Summary comment code 277) you must check the student’s academic records to determine if they received academic credit at the schools attended during any one of the four award years prior to the current award year (i.e., 2020-21, 2021-22 , 2022-23, and 2023-24 ). Using data from NSLDS, you must determine, for each prior attended institution for each student, whether academic credit was earned during the award year in which the student received Pell or Direct Loan funds. Academic credit is considered for this purpose to mean completing one (or more) clock-hour or credit-hour.
For UEH flag 3, if the student did earn academic credit at all of the schools previously attended for a relevant award year, no further action is required unless you have reason to believe that the student has had a practice of enrolling just long enough to receive credit balances before withdrawing. In such cases, follow the guidance below for cases when academic credit is not earned (next paragraph). Please note that when reviewing academic completion, you are not required to obtain official academic transcripts. You can use unofficial transcripts, letters from the school, grade reports, etc.
For UEH flag 3, when academic credit is not earned at a previously attended school, and, if applicable, at your school, you must obtain documentation from the student explaining why the student failed to earn academic credit. You must determine whether the documentation provided supports the reasons described by the student and that the student did not enroll only to receive credit balance funds. Acceptable reasons may include personal illness, a family emergency, a change in where the student lived, and military obligations, or an academic complication, such as unexpected academic challenges, or the student having determined that the academic program in question did not meet their needs. You should, to the maximum extent possible, obtain third party documentation to support the student’s claim.
In similar fashion to the exercise of professional judgment, you must determine whether the circumstances of the failure of the student to receive academic credit, as evidenced by the student’s academic records and documentation, support the continuation of Title IV eligibility. If the student with a UEH flag of 2 or 3 fails to provide compelling reasons and documentation for a failure to receive academic credit for a period for which they received Title IV funds, you must conclude that their eligibility is terminated. Your determination is final and is not subject to appeal to the Department. You must document and maintain a file of reason(s) for the decision for possible review. For the full discussion of your options in using professional judgment, see Application and Verification Guide, Chapter 5.
When a student’s eligibility is terminated in this way, you must provide information to the student on how they may subsequently regain eligibility, and the student must be given an opportunity to question and appeal the decision to your school, consistent with the opportunities to question and appeal similar determinations such as SAP and professional judgment determinations. Since the basis for denial is lack of academic performance, successful completion of academic credit may be considered basis for renewing the student’s Title IV eligibility, assuming they are in all other ways eligible for the aid in question. This could include meeting the requirements of the plan that you established with the student, although such a plan is not necessarily required. When a student regains eligibility after losing it in this manner, the student’s eligibility is retroactive to the beginning of the current period of enrollment, for Direct Loans, and for all other types of Title IV aid, retroactive to the beginning of the current payment period.
If you approve the student’s continuing eligibility, you may choose to require the student to establish an academic plan, similar to the type of plan used to resolve SAP appeals. You may also wish to counsel the student about the Pell LEU limitation and the impact of the student’s attendance pattern on future Pell Grant eligibility (see Volume 7 and Dear Colleague Letters GEN-12-01 and GEN-12-18).
When a student receives a UEH flag that includes an award year(s) that was resolved by the reviewing school for a previous award year, that school must determine if there was a change in the schools the student attended for that award year(s). If there were no changes to the schools the student attended, no further action is necessary. If the student attended another school(s) that was not previously reviewed and received Pell Grant and/or Direct Loans at that school(s), the reviewing school must determine if the student earned academic credit at the additional school(s) under review. If the student did not earn academic credit at the additional school(s) under review, the student must provide documentation explaining why academic credit was not earned.
UEH is assessed separately for undergraduate enrollment and graduate enrollment. This reduces the number of UEH flags, but still correctly flags students whom the UEH flags are intended to flag for further scrutiny. For more details on UEH and graduate students, see the Electronic Announcement of January 20, 2016.