Comment Code 399

There has been a significant change to income and tax information that students should be aware of when they complete their 2017-2018 Free Application for Federal Student Aid (FAFSA). Previously, students have been required to provide their most recent tax year information on their FAFSA. For example, the 2015-2016 FAFSA required 2014 income data and the 2016-2017 required the use of 2015 income data. The 2017-2018 will also require 2015 income and tax information as we transition to a new federal methodology known as “prior-prior” year income (PPY). This is a one-time situation where two award years will use the same 2015 income and tax information when completing the FAFSA.

With the change to PPY income, income data needs to be accurate and consistent between both the 2016-2017 and 2017-2018 FAFSA applications. This includes (but is not limited to): federal tax return type, tax filing status, adjusted gross income, income tax paid, exemption numbers, tax exempt interest income, untaxed portions of pension and IRA distributions, education benefits, and other forms of untaxed income.

The change to PPY may result in conflicting information or discrepancies in income and tax data between the two FAFSA application award years. If this happens, a student’s 2017-2018 FAFSA application will be flagged by the U.S. Department of Education with a Code 399. The Office of Student Financial Aid is required by law to review these applications and compare 2015 income and tax related items for both award years to determine the accuracy of reported information.

The Office of Financial Aid will review all FAFSA applications that have been flagged with a Code 399. In some cases, we will be able to resolve discrepant income and tax information from one aid year to another. If we are unable to clear conflicting information, the student will be notified via a missing information letter that will include a list of required documents for the award year (or years) in question. We ask that students reply promptly to our request for additional information. This will allow us to review income and tax data and make applicable adjustments if warranted.


Once a student is flagged with a Code 399, if resolution is required, all future 16-17 or 17-18 award year disbursements of financial aid will be suspended. This is true even if a student has already received a disbursement of financial aid or a refund of excess financial aid dollars. If it is determined that the student is no longer eligible for the full amount of his or her need based award, and we are not able to adjust future disbursements of aid downward, the student will be considered to have a Title IV overpayment. If this happens the following the student will be required to repay the portion of federal need based grant dollars (Pell Grant and/or SEOG). Students will be flagged in the federal system as having a Title IV overpayment. This will impact their ability to receive financial aid from either CPCC or at another school.

The student’s financial aid package will be suspended or cancelled. This could result in an owing balance to the College as the student becomes responsible for all education related charges.

While the Office of Financial Aid never likes to suspend or cancel aid, if conflicting information is not resolved, we are required to take the applicable actions as outline above. Therefore, we highly recommend that students use the IRS Data Retrieval Tool (IRS DRT) to transfer IRS data to their FAFSA applications when they meet the eligibility requirements to do so. This is the most effective way to prevent conflicting information. Questions regarding Code 399 should be addressed to the Office of Student Financial Aid at (704) 330-6240.