What Action Is Required When the Student Has Comment Code 405 Or 406 But May Have Been Incorrectly Identified As Incarcerated?

If you have confirmed that the student is not incarcerated, remove the Incarcerated Applicant Flag by changing the dropdown value to blank and submitting a correction in FAA Access to CPS Online. This is true if the student was never incarcerated or the student was formerly incarcerated but has been released. Incarcerated Applicant Flag "4" indicates that the flag has been removed. Then, since Comment Code 405 or 406 is not a Reject Code, you can continue to process Title IV aid as any other non-incarcerated student, including full verification if selected. Technically, no resolution is required even if there is a C Code.

According to guidance NASFAA has received from the U.S. Department of Education (ED), there is no specific documentation requirement, so the school can just indicate in the student's file that the flag was set incorrectly and move on.

If the student is adding your school to the FAFSA/ISIR, the student needs to add your Title IV School Code. Once you get a new ISIR generated from adding the school code, then you can remove the flag. Do not have the student submit a new FAFSA.

Remember: There is no requirement to provide the prison or correctional facility address on the FAFSA, so the confined or incarcerated individual still could provide a home or non-prison address on the FAFSA. Just because the address is not a prison address does not mean they are not in prison. However, if a correctional facility address is provided on the FAFSA, the Incarcerated Applicant Flag will be set.

Note: NASFAA is aware that there may an issue with students being incorrectly identified as being incarcerated. ED has been notified. We recommend that schools continue to report incorrectly assigned flags to CPS/SAIG Technical Support at 800.330.5947 or [email protected] for troubleshooting.