NSLDS Issue Resulting in Post-Screening ISIRs

By Rick Cox

The Department of Education has posted an electronic announcement (General-24-48) regarding an issue with NSLDS calculating aggregate loan totals incorrectly. This issue was resolved and all impacted aggregate loan totals were corrected on April 7, 2024. Through the normal NSLDS post-screening process, colleges began receiving revised 2023-2024 ISIRs during the week of April 15, 2024. The new ISIRs reflect the correct aggregate loan totals. In many cases, these new ISIRs reflect students exceeding their aggregate loan limits. The only ISIRs that have been reprocessed as of April 29, 2024, are for the 2023-2024 award year. For 2024-2025, approximately 8,200 ISIRs are impacted by this issue but will not be reprocessed until later this year.

Colleges will need to evaluate these students to determine the correct process for resolving this issue. Please note: The college is not obligated to return loan funds that were disbursed prior to receipt of this new information. However, there are actions the college will need to take for the student to remain eligible for Title IV aid, including cancelling or adjusting any pending disbursements. As a reminder, a student who exceeds the aggregate loan limits loses eligibility for all Title IV aid until the overborrowing has been resolved by returning the excess amounts (returned by the student or by the college), OR the student completes a reaffirmation agreement with their loan servicer. We are providing guidance below for addressing this issue:

1.      If all loan disbursements for the current academic year have already been made prior to receipt of the new 2023-2024 ISIR, the school is not required to take any action. However, the student will not be eligible for any future Title IV aid unless the amount exceeding the aggregate loan limits has been returned by the school or the student OR the student signs a reaffirmation agreement with their loan servicer. As indicated above, the school is not required to return the funds but might elect to do so in order for the student to remain eligible for Title IV aid. Rather than returning the funds, we would encourage colleges to work with the student in completing a reaffirmation agreement with the student’s loan servicer.

2.      If all loan disbursements for the current academic year have not yet been made, the college will need to adjust or cancel the pending disbursements to prevent the student from exceeding the aggregate loan limits. If the adjustments or cancellations prevent the student from exceeding the aggregate loan limits, no further action is necessary. If the disbursements made before receipt of the new ISIR cause the student to exceed the aggregate totals, the student is not eligible for any future Title IV aid of any kind unless the amount exceeding the aggregate loan limits is returned by the school or the student, OR the student signs a reaffirmation agreement with their loan servicer. The school is not required to return the funds that were disbursed prior to receipt of the new 2023-2024 ISIR but might elect to return these funds in order for the student to continue being eligible for Title IV aid. Rather than returning the funds, we would encourage schools to work with the student in completing a reaffirmation agreement with the student’s loan servicer.

3.      As indicated above, approximately 8,200 ISIRs for the 2024-2025 award year are impacted by this issue and will not be reprocessed until later in the year. The impacted applications were processed before April 7, 2024. For the 2024-2025 ISIRs processed before April 7, 2024, colleges should review the NSLDS history for students that have a “C” (close to or equal to limit) OR “E” (exceeded limit) flags on the NSLDS aggregate limit fields. For these students, the college can either send Financial Aid History requests to NSLDS and the response will reflect the correct aggregate totals OR the school can manually view the students’ aggregate loan totals on NSLDS. Please note that for the 2024-2025 award year, all awards being made are after the notice of this issue and therefore all awards must be in compliance with the loan limits. Awards made in excess of the loan aggregate limits must be adjusted or returned by the school.

To access this announcement, please click here.

Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance