NASFAA AskRegs: Are Schools Required To Certify a Student's IASG and Children Of Fallen Heroes Eligibility?

This AskRegs Knowledgebase Q&A was updated on April 1, 2024 to reflect guidance provided by the U.S. Department of Education (ED) in the March 15, 2024 Electronic Announcement (GRANTS-24-03) related to eligibility under the Honoring our PACT Act of 2022.

Yes. Starting with the 2024-25 award year, the financial aid administrator (FAA) must certify the student’s eligibility for a Federal Pell Grant under the Special Rules for Pell Grants. Schools will no longer be making Iraq and Afghanistan Service Grant (IASG) awards. Rather than receiving an IASG, the student will receive a Pell Grant instead. Students who are eligible as Children of Fallen Heroes (CFH) have always been awarded with Pell Grants; that will continue.

See the following from Dear Colleague Letter GEN-23-11:

"The [FAFSA Simplification] Act changes eligibility for what were formerly called Iraq and Afghanistan Service Grants (IASG) and Children of Fallen Heroes (CFH) Awards as well as the resulting award amount. Beginning with the 2024-25 award year, students who meet the eligibility requirements for Pell Grants under the Special Rule in HEA Section 401(c) will receive Max Pell, regardless of their calculated SAI. To receive a Pell Grant based on eligibility under the Special Rule, a student must be--

The child of a parent or guardian who died in the line of duty while (a) serving on active duty as a member of the Armed Forces on or after September 11, 2001; or (b) actively serving as and performing the duties of a public safety officer; and
Less than 33 years old as of the January 1 prior to the award year for which the applicant is applying (e.g., for the 2024-25 award year, a student must be less than 33 years old as of January 1, 2024, to be eligible).

The Department of Defense is no longer able to provide confirmation that a service member killed in the line of duty meets the revised special eligibility criteria after the 2023-24 award year. Further, no comprehensive database exists to identify public safety officers killed in the line of duty. Therefore, students will self-identify potential eligibility on the FAFSA, and the school will be required to verify eligibility by collecting supporting documentation from the student. Schools will report Special Rule eligibility to the Department using the new FAFSA Partner Portal (formerly FAA Access to CPS Online) to generate an ISIR transaction reflecting the student’s eligibility. Schools will award eligible students Max Pell, regardless of SAI. Other aid for these students will be based on their calculated SAI.

Schools will be able to continue awarding funds to students who meet the current IASG or CFH criteria in the new FAFSA Partner Portal."

The U.S. Department of Education's (ED's) FAFSA Simplification Questions & Answers states:

"PEL-Q6: How will a school report eligibility for Pell Grants under the Special Rule in HEA Section 401(c)? Will schools distinguish between Special Rule eligibility and legacy eligibility for Iraq and Afghanistan Service Grants (IASG) and Children of Fallen Heroes (CFH) Awards?

PEL-A6: Schools will report Special Rule AND legacy eligibility for IASG and CFH Awards to the Department via the new FAFSA Partner Portal. Students who meet Special Rule eligibility will be reported as simply eligible. There will be a separate value for students who meet the requirements for legacy eligibility.

Students who were eligible for and received IASG funds OR received Pell Grant funds based on IASG or CFH eligibility criteria for the 2023-24 award year but are not eligible for Pell Grant funds under the Special Rule beginning with the 2024-25 award year are eligible to receive Pell Grant funds based on prior IASG or CFH eligibility criteria. Students remain eligible if they receive at least one disbursement of funds from the IASG or CFH programs during the award year."

Beginning with the 2024-25 FAFSA, there is a question asking the student to self-certify if their parent or guardian died in the line of duty. Schools will need to reach out to students who answer "Yes" to the FAFSA question and request documentation of the student's Special Rule eligibility. After an FAA certifies that the student is eligible under IASG or CFH in the FAFSA Partner Portal (formerly FAA Access), the FAA will then set either the IASG Indicator or the CFH Indicator accordingly:

IASG Indicator	1 = Eligible for IASG 2 = Eligible, grandfathered for IASG 3 = Not Eligible for IASG Blank = No Determination
CFH Indicator	1 = Eligible for CFH 2 = Eligible grandfathered for CFH 3 = Not Eligible for CFH Blank = No Determination

Once the indicator has been set, a new Institutional Student Information Record (ISIR) will be produced. The FAA will then submit that newly created transaction number in the Pell award in the Common Origination and Disbursement (COD) System; this will ensure the correct Scheduled Award is calculated based on the student's eligibility under IASG and CFH. The new ISIR transaction can be seen by any school that has its Federal School Code listed on the FAFSA.

NASFAA has clarified with ED that schools are required to certify eligibility for all students who answer "Yes" to the FAFSA question in 2024-25 regardless of whether the student qualifies under the new Special Rule or qualified under the old, legacy IASG or CFH rules. The school cannot use the receipt of IASG or CFH in 2023-24 or earlier to make the student eligible for 2024-25. Even if the student received an IASG or CFH in 2023-24 or earlier, the school must recertify the student’s eligibility in 2024-25. But, if the school already has documentation that certifies the student is still eligible under the new criteria, the school does not have to re-collect documentation for 2024-25.

Once set for 2024-25, the IASG Indicator and CFH Indicator values will carry forward to subsequent ISIR transactions for that same award year. After 2024-25, the school is not required to recertify or document this every year, but is always required to resolve any conflicting information in this regard.

According to the March 15, 2024 Electronic Announcement (GRANTS-24-03), students who qualified for a Pell Grant or IASG in 2023-24 under the expanded eligibility under the Honoring our PACT Act of 2022 (PACT Act), "remain eligible if they received at least one disbursement of funds from the IASG or CFH programs during the 2023-24 award year and continue to meet the age requirement for the Special Rule. Students who receive a maximum Pell Grant based on legacy IASG or CFH guidance continue to be eligible if the student received at least one disbursement of funds based on the grandfathered eligibility in each subsequent award year. If there is a break in disbursement of one award year, then the student must qualify under the Special Rule in HEA Section 401(c), as amended."

Documentation: ED does not specify documentation requirements, so the school will need to collect whatever documentation it deems necessary to certify that the student's parent or guardian died in the line of duty as noted above. This might include a death certificate along with written confirmation of active duty status at the time of death from the military command or public safety entity. It is NASFAA's understanding that a signed statement from the student would not suffice in this instance. If the school already collected documentation of the student's IASG or CFH status in a prior award year (other than the Department of Defense database match), it does not need to re-collect documentation.

Transfer Students: For 2024-25, an institution certifies a student is eligible under IASG or CFH criteria and sets the indicator accordingly. Then, the student transfers to another school. NASFAA has asked ED if the new school can accept the certification and indicator from the prior school without collecting certification documentation. As soon as we have an answer, we will update this Q&A.

More Information: Reference Section 401(c)(2) of the Higher Education Act of 1965 (HEA), as amended, [20 USC 1070A(c)(2)] and Electronic Announcement GENERAL-23-63. For more information on what data will be contained in the ISIR, reference the draft 2024-25 FAFSA Simplification Guide, Volume 6 – ISIR Guide and the 2024–25 FAFSA Specifications Guide Volume 4 – Record Layouts and Processing Codes.

For more information on certifying a student’s eligibility, see Volume 7 of the FSA Handbook when the 2024-25 version becomes available. See Electronic Announcement GENERAL-23-03 for more information.

Are Schools Required To Certify a Student's IASG and Children Of Fallen Heroes Eligibility?

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