topSkip to main content

Menu, Secondary

Menu Trigger


AAU Joins Letter Expressing Concerns with ISIR Processing for Federal Financial Aid

AAU, along with 14 other higher education organizations, joined a letter led by ACE to the US Department of Education expressing ongoing concerns with the rollout of the new FAFSA application, now with the processing of Institutional Student Information Records (ISIRs) and the timely computation of financial aid packages for students. The letter asks that the Department of Education “fully communicate all information regarding the FAFSA process to institutions in a timely manner and provide the necessary support to ensure that they can make this process as smooth as possible for both current and incoming students.”

Dear Secretary Cardona,

On behalf of the undersigned higher education associations, I write to share the concerns institutions of higher education have regarding the challenges they face with processing the Institutional Student Information Records (ISIRs) and their confidence in their ability to package financial aid within weeks of the receiving the ISIRs. We ask that you fully communicate all information regarding the FAFSA process to institutions in a timely manner and provide the necessary support to ensure that they can make this process as smooth as possible for both current and incoming students.

Due to the passage of the Fostering Undergraduate Talent by Unlocking Resources for Education (FUTURE) Act1 and the Free Application for Federal Student Aid (FAFSA) Simplification Act2 by Congress, the Department of Education (Department) embarked on the implementation of both pieces of legislation. In efforts to implement both laws, certain systems needed upgrading, leading to the Department creating a new FAFSA processing system, the new Federal Tax Information (FTI) Module, and a new FTI Student Aid Internet Gateway (SAIG) mailbox.3 Institutions of higher education were informed that they would need to update their SAIG mailboxes in order to receive ISIRs for the 2024-2025 academic year (AY), and the SAIG enrollment agreement was made available on Oct. 23, 2023.4

In preparation for AY 2024-2025, the Department also had to modify the current FAFSA to comply with the FAFSA Simplification Act. The Higher Education Act sets a Jan. 1 statutory deadline for FAFSA submissions,5 and there is a current FAFSA processing cycle that consists of 21 months, allowing students to begin to submit a FAFSA on Oct. 1 prior to the start of the academic year in which they would enroll. The FAFSA was not available for students to complete on Oct. 1, 2023, and the Department issued an official notice last November indicating that the FAFSA would be delayed until Dec. 31, 2023.6 The delay in the FAFSA has resulted in other delays regarding the timeliness of ISIRs being delivered to institutions and now an even further delay due to miscalculations of the Student Aid Index for dependent students who reported assets.7 In addition, the Department announced that students would not be able to make corrections to their FAFSA until the first half of April.8 Also, because there has not been an official update to the Federal Need Analysis Methodology as required in statute,9 there will be delay in when institutions can accurately package their aid to students.

The American Council on Education, EDUCAUSE, and the National Association of College and University Business Officers (NACUBO) conducted a survey to assess the needs of our member institutions and gather feedback regarding their thoughts around the FAFSA delays, their efforts to update their SAIG mailboxes, and the processing of ISIRs. This survey was sent to college and university presidents, information technology administrators, enrollment officers, financial aid officers, and business officers. The survey yielded 358 respondents, and the majority of responses came from financial aid officers (251 responses). Also, 49 percent of all respondents (172 responses) were from four-year, private, nonprofit institutions.

The survey found that 80 percent of the respondents had already updated their SAIG mailboxes while 10 percent shared that they have not completed the update and another 10 percent were unsure. Given the recent news from the Department that only roughly 100 institutions remain in need of updating their SAIG mailboxes, the feedback we received seems to match the current landscape.

The following key concerns were identified:

  • Some institutions still face challenges updating their SAIG mailboxes – For those institutions that have not updated their SAIG mailboxes, the majority expressed issues with technological limitations, the inability to get the proper help needed from the Department, and staffing issues. As examples, respondents expressed that:
    • Many institutions have been having issues with EDconnect 6.0 and are afraid that updating it will hinder their ability to process 2023-2024 aid;
    • Upgrades are being delayed because ISIR delivery is delayed, and it is important for the Department to work out all of the technological issues before institutions are able to successfully update their SAIG mailboxes;
    • Many institutions need more guidance on how to properly update their SAIG mailboxes and properly update EDconnect;
    • Some institutions have attempted to update the mailbox but have been experiencing issues with switching to the new version of TDClient; and
    • There was no resolution when calling the Department for support; institutions reported spending hours on the phone with no positive results.
  • Institutions remain uncertain about their ability to process ISIRs in a timely fashion – a total of 67 percent of respondents shared that they do not believe they will be able to successfully process ISIRs within a few weeks. As examples, respondents shared that:
    • Institutions that had not yet received the test ISIRs were having issues with the test records made available on GitHub since they did not come through the SAIG mailbox, which impacted the ability of institutions to truly know if they would be able to process the test ISIRs effectively;
    • Software developers are having to create new dictionary items to match all of the new fields on the FAFSA, and not having the final version of the ISIRs makes it challenging for both developers and institutions to know if the system changes already implemented or in process will actually work;
    • Processing ISIRs within a few weeks is unrealistic—it will take at least four to six weeks;
    • Institutions will need additional time to complete new year system setup, which includes updating rules and appropriate testing; and
    • Although software providers have been following the rollout carefully and making the required programming changes to accept the new ISIR fields, both providers and institutions are concerned that the sheer volume of ISIRs received in the initial download will pose problems for financial aid management systems.

The attached document highlights the themes identified above and provides more information on how participants responded to each question that was asked. To address issues with the delay in the FAFSA, 47 percent of respondents shared that they would be adjusting their May 1 deadline dates and 13 percent indicated that they have already adjusted their dates. In an effort to keep track of institutions that are adjusting their deadline dates, ACE has a database that shares those institutions that are extending their deadlines to best serve students.10

We thank you for your attention to this letter. It is our hope that you will take these institutional responses into consideration and continue to be as transparent as possible with the higher education community to allow us to make this process as smooth as possible for both current and incoming students.

On behalf of:

American Association of Collegiate Registrars and Admissions Officers

American Association of State Colleges and Universities

American Council on Education

Association of American Universities

Association of Catholic Colleges and Universities

Association of Governing Boards of Universities and Colleges

Association of Jesuit Colleges and Universities

Association of Public and Land-grant Universities

Council for Christian Colleges & Universities

College and University Professional Association for Human Resources

Council of Graduate Schools


Hispanic Association of Colleges and Universities

National Association of College and University Business Officers

National Association of Independent Colleges and Universities

National Association of Student Financial Aid Administrators

1 Fostering Undergraduate Talent by Unlocking Resources for Education Act, 20 U.S.C. § 1067q et. seq & 26 U.S.C. § 6103 (2019).

2 FAFSA Simplification Act, 20 U.S. C § 1001 et seq. (2020).

3 Federal Student Aid. (2023, May). Access and use of federal tax information (FTI) for federal student aid programs beginning with the 2024-25 FAFSA processing cycle. U.S. Department of Education.

4 Federal Student Aid. (2023, September). Updated SAIG enrollment agreement available Oct. 23, 2023 – Required steps to receive 2024–25 ISIRs. U.S. Department of Education.

5 Higher Education Act, 20 U.S.C. § 1090(a)(8) (1965 as amended through P.L. 118-40).

6 Federal Student Aid. (2023, November). Update on the simplified, streamlined, redesigned 2024-25 FAFSA. U.S. Department of Education.

7 Federal Student Aid. (2024, March). Update on 2024-25 FAFSA institutional student information record (ISIR) delivery

8 Federal Student Aid. (2024, March). Update on 2024-25 FAFSA processing

9 Higher Education Act, 20 U.S.C. § 1087rr (1965 as amended through P.L. 118-40).

10 American Council on Education. (n.d.). Extending enrollment and financial aid deadlines.

Download the PDF