Breaking Down the Latest Title IV Flexibilities for 2024-25: What Your Institution Needs to Know
The U.S. Department of Education recently released an important Electronic Announcement addressing ongoing processing issues and extending critical flexibilities for schools navigating the 2024–25 FAFSA cycle. For financial aid administrators, this update includes both good news and essential action items, especially for those working to resolve ISIRs with blank Student Aid Index (SAI) fields.
Here are the key takeaways your institution should know:
1. Disbursement Flexibility Has Been Expanded
The Department has extended Title IV late disbursement flexibilities to include all students (both online and paper filers) affected by FAFSA processing issues that prevented their SAI from being calculated before the end of enrollment. This update builds upon the flexibilities originally provided in GENERAL-24-143 (published in December 2024).
Schools can now disburse aid to eligible students—even if they are no longer enrolled, as long as the FAFSA was submitted before their enrollment ended and the delay is tied to a known processing issue.
✅ Bonus Flexibility: The 180-day clock for late disbursements can start from the later of (1) the withdrawal/ineligibility date or (2) the earliest Transaction Processed Date with an official SAI.
2. Alternative Documentation Allowed for Paper Filers
For paper FAFSA filers, schools may now use an alternative Application Receipt Date if documentation (like a mail delivery receipt) supports it. This can help institutions prove a FAFSA was submitted on time and make students eligible for disbursements they might have otherwise missed.
3. What’s Causing the Blank SAIs?
Despite progress, some ISIRs are still arriving without an SAI or reject code. The main culprits include:
Technical errors involving Federal Tax Information Module (FTIM) data
TransUnion match delays (especially affecting mixed-status families)
Contributor issues preventing form completion or signature
Missing contributor consent/approval or incomplete data
Schools should not attempt to fix these records manually. Instead, document the issue and wait for Department resolution, which will trigger reprocessing. Updates will be shared via the FAFSA Known Issues Guide.
4. Reject Codes That Can Be Resolved
Many FAFSA rejects still stem from missing or inconsistent information and can be fixed using standard correction methods:
Missing signatures or consent (Reject Codes 10–12, 25–27, 36–38, 45–46)
Unusual circumstances or specific aid requests (Reject Codes 1, 14)
Incomplete data (Reject Codes 9, 23, 34, 43)
Your team can use the FAFSA Partner Portal or EDE to submit corrections. The Department has also made on-demand training webinars available through the FSA Training Center to support your staff in making these updates effectively.
5. How JH Strategic Group Can Help
This announcement further complicates an already challenging aid cycle. At JH Strategic Group, we help institutions like yours navigate regulatory changes, resolve complex compliance issues, and maximize Title IV efficiency.
Led by a former Federal Student Aid employee with 10 years of experience at the Dallas regional office, our team provides unmatched insight into federal processes and policy administration. With our Monthly Title IV Retainer Services, your staff can access expert support, when it’s needed most, without the burden of a long-term commitment.
Whether you need:
Late disbursement eligibility analysis
ISIR review and resolution
Staff training or interim leadership
Guidance through audit prep or program reviews
We’re here to be your strategic compliance partner every step of the way.
