Are We Required To Resolve Comment Codes 405 and 406 If They Have C Codes?

Award Year: 2023-24 KA-36786 Helpfulness Rating 210 page views

This guidance is specific to the 2023-24 award year and later.

No. According to the July 22, 2022 Electronic Announcement, Comment Codes 405 and 406 incorrectly state that these comments do not produce C Codes. These two comment codes indicate the student is incarcerated, and a C Code will be generated. The guide is correct in stating that no resolution is required.

Even though no resolution is required, you do have to process the student's Title IV aid as a confined or incarcerated student in an approved prison education program (PEP) or experimental sites initiative. In addition, there may be instances when the student may have been incorrectly identified as incarcerated. In these instances, you remove the Incarcerated Applicant Flag as explained in AskRegs Knowledgebase Q&A, How Do We Resolve Comment Codes 405 And 406 When the Student May Have Been Incorrectly Identified As Incarcerated?

Also see the ED PEP Questions and Answers - Student Eligibility website.

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