Laws & Guidance HIGHER EDUCATION
Program Integrity Questions and Answers
Verification - Archived Guidance


Archived Guidance
beginning with the 2012-2013 award year

Verification Q&A | Program Integrity Q&A

Questions on this topic are divided into the following categories:

Introductory Verification Questions (IVQ)

IVQ-Q1. What is the effective date of the new regulations on the verification and updating of student aid application information for applicants who receive subsidized student financial assistance?

IVQ-A1. The new regulations on the verification and updating of student aid application information for applicants who receive subsidized student financial assistance are effective July 1, 2012. Any FAFSA/ISIR selected for verification for the 2012-2013 award year and subsequent award years must be verified according to the new verification regulations. [Program Integrity Issues; Final Rule (Page 66832)] [Guidance issued 03/13/2012]

IVQ-Q2. What are the subsidized and unsubsidized student financial assistance programs?

IVQ-A2. The subsidized student financial assistance programs are Title IV programs for which eligibility is determined on the basis of an applicant's EFC and include the Federal Pell Grant, Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Work-Study (FWS), Federal Perkins Loan, and subsidized Direct Loan programs. The unsubsidized student financial aid programs are the Title IV programs for which eligibility is not based on the applicant's EFC and include the TEACH Grant, unsubsidized Direct Loan, and Direct PLUS Loan programs. [Section 668.52] [Guidance issued 03/13/2012]

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General Questions (VER)

VER-Q1. Where can I find guidance on the verification requirements?

VER-A1. The following resources provide guidance on the verification requirements:

2012-2013 Award Year

2013-2014 Award Year

2014-2015 Award Year

2015-2016 Award Year

2016-2017 Award Year

VER-Q3. Are adjustments to an applicant's FAFSA information that are based on professional judgment selected for verification?

VER-A3. Refer to Q&A IVQ - Q3/A3. (Section 668.53) [Guidance issued 01/26/2012; revised 12/16/2014]

VER-Q5. Are Quality Assurance (QA) institutions exempt from the new verification rules beginning with the 2012-2013 award year?

VER-A5. Yes. The changes made to the verification regulations do not alter the way the QA Program operates. In fact, the Department expects that data and results generated from institutions participating in the QA Program will help assess the effectiveness of the new verification regulations. (Section 487A(a)) [Guidance issued 01/26/2012; revised 02/15/2013]

VER-Q12. Can an institution determine which of its staff are authorized to review the identity of an applicant selected for verification groups V4 or V5?

VER-A12. Yes, each institution may determine which of its staff are authorized to review an applicant's identity. The Department does not designate which office or level of staff is responsible for this function. Since the administration of the Title IV programs is an institution-wide responsibility, an institution has much latitude in determining which of its staff are authorized to review an applicant's identity. However, as a best practice, we recommend that staff selected to perform this function be permanent employees of the institution. We also suggest that the institution maintain a written record of who is authorized to carry out this function. [Section 668.53] [Guidance issued 03/13/2013]

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Applicants Selected for Verification by the Department (DS)

DS-Q1. May an institution require an applicant who was selected for verification by the Department to verify other FAFSA information in addition to those items identified by the Department for the award year?

DS-A1. Yes. An institution may require an applicant to verify any FAFSA information that it specifies, and the institution may decide what documentation is acceptable for its institutionally chosen items. For example, an institution may choose to verify (for some or for all of its applicants) "income earned from work," and the institution may determine that copies of IRS W-2 forms will be the required documentation. (Section 668.54(a)) [Guidance issued 01/26/2012]

DS-Q2. When an applicant is not selected for verification by the Department on the applicant's initial transaction, is it possible for that applicant to be selected for verification by the Department on a subsequent transaction?

DS-A2. Yes. Whenever a change to FAFSA information is submitted to the Department, the applicant's FAFSA record is reevaluated under the verification selection model. While the change will not, in itself, result in the applicant being selected, in some instances the review of the entire record could result in the applicant being selected for verification. (Section 668.54) [Guidance issued 01/26/2012]

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Applicants Selected for Verification by the Institution (IS)

IS-Q1. May an institution select applicants for verification other than those selected by the Department?

IS-A1. Yes. An institution may require applicants other than those selected by the Department to verify FAFSA information. (Section 668.54(a)(3)) [Guidance issued 01/26/2012]

IS-Q2. Must an institution require an applicant it selects for verification to verify all of the FAFSA information identified by the Department for the award year? Must the institution comply with the "acceptable documentation" requirements for the FAFSA information it selects for verification?

IS-A2. For the applicants it selects for verification, an institution is not required to verify any or all of the FAFSA information identified by the Secretary for the award year and it may require verification of other FAFSA information. The institution may also determine what documentation to accept for the applicants it selects for verification, for any of the FAFSA information it has determined must be verified. (Section 668.54(a)(3)) [Guidance issued 01/26/2012]

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Verification Items (VI)

VI-Q2. Are institutions required to verify the receipt of - Supplemental Nutrition Assistance Program (SNAP) – Food Stamps - benefits that was reported on a verification worksheet or other documentation at the institution, but not reported on the applicant's FAFSA?

VI-A2. There are special verification considerations for the "means tested benefits programs," including SNAP, that are on the FAFSA. This is because receipt of any of those benefit programs only impacts the applicant's eligibility for Title IV aid if receipt of the benefit makes the applicant eligible for either of the alternate expected family contribution (EFC) calculations: Automatic Zero EFC (Auto Zero EFC) or Simplified Needs Test (SNT). Because not all applicants are eligible to be considered for these alternate EFC calculations (e.g., income to high) and because some applicants are eligible based on other factors (e.g., type of tax return filed), many applicants are not presented with the means tested benefits programs question.

Therefore, some applicants for whom the question was not presented, may have actually received (or someone in their family received) SNAP benefits. Depending on how the institution has chosen to communicate its verification requirement, these applicants might provide the institution with information about the receipt of SNAP on a verification worksheet (or other format) even when the question was not presented to applicants completing FAFSA on the Web.

In instances where the applicant's ISIR does not indicate the receipt of SNAP but the applicant was, nonetheless, determined to be eligible for either of the alternate EFC calculations, the receipt of SNAP benefits was not needed to determine eligibility for Auto Zero EFC or for SNT. When this is the case, there is no need for the institution to change the FAFSA SNAP field using FAA Access. Similarly, if the applicable income precludes the applicant from being considered for either of the alternate EFC calculations, there is no need for the institution to change the FAFSA SNAP field.

However, in instances where it appears that the applicant, who was not determined to be eligible for one of the alternate EFC calculations, would become eligible if the response to the SNAP question was "Yes," the institution must change the FAFSA SNAP field so that the applicant can appropriately benefit from the special EFC calculation. For example, an applicant completing FAFSA on the Web reports an AGI of $52,000. Because the AGI exceeds the income threshold to qualify for either of the alternate EFC calculations, the applicant is not presented with any of the alternative EFC calculation questions. Therefore, the applicant's ISIR will not indicate that the applicant or a household member met any of the eligibility criteria for Auto Zero or SNT. However during verification, the applicant correctly reports to the institution a change in her AGI from $52,000 to $22,000 and indicates receipt of SNAP benefits. In this case, the institution would be required to change the FAFSA SNAP field when correcting the applicant's AGI.

To eliminate burden on institutions with a requirement that they determine whether they must change the FAFSA SNAP field so that a determination can be made as to whether the applicant would or would not be eligible for one of the alternative EFC calculations, it is permissible for an institution to change the FAFSA SNAP field in all instances and let the Department's systems determine eligibility. [Guidance issued 01/26/2012; revised 04/04/2014]

VI-Q3. Must an institution require an applicant selected for verification to verify receipt of SNAP benefits (food stamps) if the applicant or someone in the applicant's household, or if applicable, the applicant's parent's household, also reported receipt of one of the other means-tested federal benefits that would make the applicant eligible for one of the alternate EFC calculations?

VI-A3. Yes. If the receipt of SNAP benefits was included on the applicant's ISIR, the institution must require an applicant selected for verification to verify the receipt of SNAP benefits.

The institution may document the receipt of SNAP benefits by obtaining a statement signed by the applicant or parent, as appropriate, affirming that SNAP benefits were received by someone in the household during the appropriate calendar year for the award year. The Department's suggested verification text provides such a statement. Alternatively, the institution may require documentation from the agency that issued the SNAP benefits. (Sections 668.56 and 668.57(d)) [Guidance issued 03/13/2012; revised 04/04/2014]

VI-Q5. Must an institution complete verification of all FAFSA information identified by the Secretary in the July 13, 2011, Federal Register notice for selected applicants who are eligible for either of the alternate expected family contribution (EFC) calculations: Automatic Zero EFC (Auto Zero EFC) or Simplified Needs Test (SNT)?

VI-A5. Generally, yes for SNT eligible applicants and no for Auto Zero applicants.

The only difference in the EFC calculation for SNT eligible applicants is the elimination of assets and assets are not items that are required to be verified. Therefore, SNT eligible applicants are required to verify all FAFSA information listed in Federal Register notice published July 13, 2011.

For Auto Zero EFC eligible applicants, the information that must be verified varies slightly between those applicants who are dependent and those who are independent.

Auto Zero EFC for a Dependent Applicant Selected for Verification—If the "Automatic Zero EFC Indicator" field on the ISIR is set to "Yes," only the following FAFSA/ISIR information must be verified:

  • The parent’s AGI if the parent(s) was a tax filer;
  • The parent’s income earned from work if the parent(s) was not a tax filer; and
  • The receipt of SNAP benefits (food stamps) by any household member if used to qualify for Auto Zero EFC.

Auto Zero EFC for an Independent Applicant Selected for Verification—If the "Automatic Zero EFC Indicator" field on the ISIR is set to "Yes," only the following FAFSA/ISIR information must be verified:

  • The applicant's (and spouse's, if applicable) AGI if a tax filer;
  • The applicant's (and spouse's, if applicable) income earned from work if not a tax filer;
  • The number of household members to determine if the independent applicant has one or more dependents other than a spouse; and
  • The receipt of SNAP benefits (food stamps) by any household member if used to qualify for Auto Zero EFC. [Section 668.56] [Guidance issued 05/04/2012 and applies only to the 2012-2013 award year]

VI-Q6. Are institutions required to verify the payment of Child Support that was reported on a verification worksheet or other documentation at the institution, but not reported on the applicant's FAFSA?

VI-A6. An institution must resolve conflicts between an applicant's FAFSA information and other information at the institution, including information that was reported on a verification worksheet. For this question, the conflict is that when completing the FAFSA the applicant did not indicate payment of child support by the applicant, the applicant's spouse, and/or the applicant's parent. Yet, on a verification worksheet, or other documentation received by the institution, payment of child support was reported. Resolving this conflict is important because if it is determined that child support was paid, the applicant's EFC will likely be reduced. Note, however, that if the applicant was eligible for Automatic Zero EFC (Auto Zero EFC), the Child Support Paid question would not have been presented. In this case, so long as the applicant is still Auto Zero EFC eligible, there would be no need to correct the Child Support Paid field. (Section 668.16(f)) [Guidance issued 10/10/2012]

VI-Q7. Must an institution complete verification of all FAFSA information identified in Verification Tracking Groups V1 or V5 even if the selected applicant is eligible for either of the alternate expected family contribution (EFC) calculations: Automatic Zero EFC (Auto Zero EFC) or Simplified Needs Test (SNT)?

VI-A7. Generally, yes for SNT-eligible applicants and no for Auto Zero EFC-eligible applicants.

The only difference in the EFC calculation for SNT-eligible applicants is the elimination of assets, and assets are not required to be verified. Therefore, SNT-eligible applicants who are assigned to Verification Tracking Groups V1 or V5 are required to verify all FAFSA information listed for the Verification Tracking Group they are placed in.

For Auto Zero EFC-eligible applicants placed in Verification Tracking Groups V1 or V5, the information that must be verified varies slightly between those applicants who are dependent and those who are independent.

For dependent applicants, only the following FAFSA/ISIR information must be verified:

  • The parents' AGI if they were tax filers;
  • The parents' income earned from work if they were nontax filers; and
  • The receipt of SNAP benefits (food stamps) by any household member if the receipt of these benefits qualified the applicant for Auto Zero EFC.

For independent applicants, only the following FAFSA/ISIR information must be verified:

  • The applicant's and spouse's AGI if tax filers;
  • The applicant's and spouse's income earned from work if they were nontax filers;
  • The number of household members to determine if the independent applicant has one or more dependents other than a spouse; and
  • The receipt of SNAP benefits (food stamps) by any household member if the receipt of these benefits qualified the applicant for Auto Zero EFC.

In addition to the FAFSA/ISIR information listed above, dependent and independent applicants placed in Verification Tracking Group V5 must also verify their high school completion status and identity/statement of educational purpose. [Section 668.56] [Guidance issued 03/13/2013; revised 7/11/2013 and applies only to the 2013-2014 award year

VI-Q8. What is the language in the "Statement of Educational Purpose" that institutions must use for students placed in Verification Tracking Groups V4 or V5?

VI-A8. The following Statement of Educational Purpose must be used by an institution for students placed in Verification Tracking Groups V4 or V5, except that the student’s identification number is optional if collected elsewhere on the same page as the statement.

Statement of Educational Purpose

I certify that I [Print Student's Name] am the individual signing this Statement of Educational Purpose and that the federal student financial assistance I may receive will only be used for educational purposes and to pay the cost of attending [Name of Postsecondary Educational Institution] for 2013-2014.

[Student's Signature] [Date]

[Student's ID Number]

For Spanish Speakers:

Declaración de Propósito Educativo

Certifico que yo, [Imprimir Nombre del Estudiante], soy el individuo que firma esta Declaración de Finalidad Educativa y que la ayuda financiera federal estudiantil que yo pueda recibir, sólo será utilizada para fines educativos y para pagar el costo de asistir a [Imprimir Nombre de Institución Educativa Postsecundaria] para 2013-2014.

[Firma del Estudiante] [la Fecha]

[Número de Identificación del Estudiante]

The institution may insert the name of the institution and the student, where indicated, prior to providing the statement to the student. (Section 668.57) [Guidance issued 03/13/2013; revised 07/11/2013 and applies only to the 2013-2014 award year]

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Updating Applicant’s FAFSA Information (UPD)

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Acceptable Documentation for FAFSA Information Selected for Verification (DOC)

DOC-Q1. How can the IRS Data Retrieval Process be used to satisfy the verification requirement if the tax filer has not filed an income tax return at the time of completing the FAFSA?

DOC-A1. If the tax filer has not filed an income tax return at the time the FAFSA was initially completed, estimated income tax information may be used. Once the tax filer has filed the income tax return, the IRS data may be retrieved and transferred using the IRS Data Retrieval Process available through the corrections process of FAFSA on the Web. (Section 668.57(a)) [Guidance issued 01/26/2012]

DOC-Q3. May an applicant have an IRS Tax Return Transcript sent directly to a college or university?

DOC-A3. It is the Department's understanding that IRS Tax Return Transcripts requested online or by telephone will only be sent by the IRS to the address of the tax filer and cannot be sent directly to a third-party by the IRS. However, on line 5 of the paper IRS Form 4506T-EZ tax filers may request that the IRS mail their IRS Tax Return Transcript directly to a third-party. Institutions are responsible for notifying aid applicants to list the institution as the third-party to receive the transcript. (Section 668.57(a)) [Guidance issued 01/26/2012; revised 04/04/2014]

DOC-Q4. May an institution decide what documentation is acceptable for its institutionally selected applicants?

DOC-A4. Yes. The institution may decide what documentation is acceptable for its institutionally-selected applicants both for institutionally-selected information and for FAFSA information that has been identified for verification by the Department for the award year. Keep in mind that while the institution may identify acceptable documentation for institutionally-selected applicants, the institution must use the documentation identified in the Federal Register notice for applicants selected by the Department. (Sections 668.53(b)(1) and 668.54(a)) [Guidance issued 01/26/2012]

DOC-Q6. What documentation must be collected from an applicant who was selected for verification and whose Institutional Student Information Record (ISIR) shows receipt of Food Stamps – Supplemental Nutrition Assistance Program (SNAP)?

DOC-A6. An institution may accept as documentation, to verify the FAFSA reported receipt of SNAP benefits included on the ISIR, a signed statement by one of the parents of a dependent applicant or by an independent applicant that certifies that either they or another person who was included in the FAFSA household size received SNAP benefits during the appropriate calendar year for the award year. The Department's suggested verification text provides such a statement. Alternatively, the institution may require documentation from the agency that issued the SNAP benefits. (Section 668.57(d)) [Guidance issued 01/26/2012; revised 04/04/2014]

DOC-Q7. For verification of nontax filer wages, are institutions required to collect both the W-2(s) from all employers and the signed statement certifying that the individual has not filed and is not required to file an income tax return, listing all income and sources?

DOC-A7. Yes. For nontax filers, an institution is required to collect a signed statement certifying that the person is not required to file an income tax return and including the sources and amounts of any income earned from work. In addition, copies of an IRS W-2 form for each source of income earned from work must also be collected.

The Department's suggested verification text will assist an institution in accomplishing this. Institutions that do not use the Department's suggested verification text must collect the documentation necessary to account for all sources of income.

Beginning with the 2017–2018 award year, nontax filers must also provide confirmation of nonfiling as specified in the applicable annual Federal Register notice. If appropriate, a similar confirmation from another tax authority (e.g., a U.S. territory or a foreign government) is also acceptable. For information on obtaining confirmation of nonfiling from the IRS or foreign tax authorities, refer to Electronic Announcement dated 2/23/2017 and Q&A DOC-Q30/A30 respectively. [Section 668.57(a)(4)(i)] [Guidance issued 03/13/2012; revised 3/21/2017]

DOC-Q8. For verifying child support paid, please clarify whether the institution is required to obtain the signature of the person who paid the child support?

DOC-A8. To minimize burden on families and institutions that would result by requiring the signature of the person who paid the child support, the signature of the applicant and, for a dependent student, one of the applicant's parents, on the Department's sample verification worksheets (or on a similar form developed by the institution) will meet the verification requirement for child support paid. This is because by providing those signatures the applicant, or parent, is certifying that the information provided is complete and accurate. This policy is consistent with our position to only require the applicant's signature and not the applicant's spouse and only one parent's signature for a dependent student when completing the Free Application for Federal Student Aid (FAFSA). [Section 668.57(d)] [Guidance issued 03/13/2012]

DOC-Q9. May an institution accept or make a copy of an IRS transcript that was originally obtained from the IRS?

DOC-A9. Yes, an institution may accept or make a copy of an IRS transcript that was originally obtained from the IRS. [Section 668.57(a)(1)(i)] [Guidance issued 03/13/2012]

DOC-Q11. In some cases, tax filers who have visited an IRS field office have been provided with a copy of their IRS tax return stamped "official" in lieu of an IRS Tax Return Transcript. May an institution use an IRS tax return that has been stamped "official" by the IRS as a substitute for an IRS Tax Return Transcript to meet the verification requirements?

DOC-A11. An IRS tax return that has an "official" stamp by the IRS is not a substitute for an IRS Tax Return Transcript. However, as provided in the April 16, 2012 Dear Colleague Letter (GEN-12-07), institutions may, until July 15, 2012, accept a signed copy of the relevant (i.e., applicant, spouse, or parent) 2011 IRS Tax Return as acceptable verification documentation for the 2012-2013 award year. After July 15, 2012, or if an institution chooses not to accept the tax return prior to that date, the applicant, spouse or parent must obtain an IRS Tax Return Transcript, if unable to use the IRS Data Retrieval Tool. [Section 668.57(a)] [Guidance issued 06/21/2012 and applies only to the 2012-2013 award year]

DOC-Q13. Is there an instance when an IRS Request Flag code of "02" would not carry forward to a subsequent transaction?

DOC-A13. Yes, when the student, parent, or FAA corrects a transaction on which the IRS Request Flag is not set to '02' or a change is made to any of the associated IRS information. An example would be where the student when completing the FAFSA used the IRS Data Retrieval Tool to transfer IRS information to the FAFSA but the parent did not. The resultant ISIR transaction '01' would have an IRS Request Flag code of '02' for the student and '05' for the parent. If the family then used the '01' transaction to transfer the parent's IRS information using the IRS Data Retrieval Tool, the resultant ISIR transaction '02' would have an IRS Request Flag code of '02' for both the student and the parent. If the family or FAA used the '01' transaction instead of the '02' transaction when submitting a correction that did not change any of the IRS information, the resultant ISIR transaction '03' would again have an IRS Request Flag code of '02' for the student and '05' for the parent because those were the values in the '01' transaction that was used to make the last correction. Likewise, if the FAA used the '02' transaction to submit a correction to the parent's IRS information, the resultant transaction would have an IRS Request Flag code of '02' for the student but not for the parent because of the change to the parent's IRS information. The IRS Request Flag codes can be found in the ISIR Guide. [Guidance issued 06/21/2012; revised 04/04/2014]

DOC-Q14. What tax information should an institution use when both the IRS Data Retrieval Tool is used and an IRS Tax Return Transcript is obtained?

DOC-A14. We have informed institutions that tax information obtained through the IRS Data Retrieval Tool (DRT) may be considered verified if that information was not subsequently changed after it was transferred from the IRS to the FAFSA. However, an IRS Tax Return Transcript may provide a "per computer" amount for certain tax information that is different than the amount the tax filer originally reported to the IRS. The "per computer" is an amount that has been modified by the IRS to correct mathematical errors and therefore is more accurate than the amount for the same tax information that was transferred through the IRS DRT. The IRS Tax Return Transcript may also include other tax information that may be different from what was initially reported on the FAFSA but was not part of the tax information transferred through the IRS DRT. Institutions are not required to obtain an IRS Tax Return Transcript to complete verification for individuals who successfully utilized the IRS DRT. If an institution obtains a copy of a tax filer's IRS Tax Return Transcript, any amount(s), including the "per computer" amount(s), on the transcript that is different from the amount reported on the FAFSA by $25 or more must be corrected on the FAFSA through CPS. However if an institution is required to submit any change through CPS as a result of verification it must submit all changes, including amounts that are below the $25 tolerance. (Sections 668.16(f), 668.57(a), and 668.59(a)(2)) [Guidance issued 09/13/2012]

DOC-Q15. What documentation is required for an applicant, parent or spouse who is the victim of identity theft and, as a result, is unable to use the IRS Data Retrieval Tool or obtain an IRS Tax Return Transcript until the matter has been resolved by the IRS?

DOC-A15. When the IRS determines that a tax filer has been, or likely was, a victim of identity theft, it will not allow that tax filer to obtain tax information through the use of the IRS DRT or to receive an IRS Tax Return Transcript until the matter has been resolved by the IRS. Resolution could take up to a year, depending on the complexity of the case. Therefore, in instances when the tax filer has been the victim of identity theft, the institution may accept for verification purposes a signed copy of the paper IRS income tax return that was filed with the IRS along with additional documentation as follows.

If the tax filer had submitted to the IRS an IRS Form 14039 "Identity Theft Affidavit," a copy of that signed form must be submitted to the institution with the signed copy of the paper tax return. In some instances, the IRS does not require the tax filer to submit an IRS Form 14039, or the tax filer may not have saved a copy of the IRS Form 14039 that was submitted to the IRS. In these instances, the tax filer must submit, in addition to the signed copy of the tax return, either:

  • a statement signed and dated by the tax filer indicating that he or she was a victim of IRS identity theft and that the IRS is investigating the matter. The statement must also indicate that the tax filer submitted a Form 14039 to the IRS, but did not keep a copy of it or that he or she was not required to file the form; or
  • a copy of a police report that may have been filed by the tax filer related to the IRS identify theft. [Section 668.57(d)] [Guidance issued in an Electronic Announcement dated August 21, 2012; revised guidance issued on page 3 in APPENDIX A of the Electronic Announcement dated January 18, 2013 and applies to 2013-2014 and previous award years. Guidance for 2014-2015 is provided in Dear Colleague Letter GEN-14-05]

DOC-Q17. Can an institution rely on documentation of a student's high school completion status or documentation that a student has the equivalency of a high school diploma that it collected for purposes other than completing verification to verify a student's high school completion status?

DOC-A17. Yes, if the documentation the institution collected (e.g., a copy of the high school diploma, GED, homeschool credential, or documentation that indicates the student successfully completed a program of at least two years that is acceptable for full credit toward a bachelor's degree) complies with the Title IV verification requirements as provided in the annual Federal Register notice.

Some institutions collect 7th semester high school transcripts prior to the student having been awarded the actual diploma. Also, some institutions collect high school transcripts for some but not all of their students because they may have special programs that admit students who do not have a high school diploma. In both of these instances, the institution must collect separate documentation that show the date when the diploma was awarded. [Section 668.57] [Guidance issued 04/25/2013; revised 12/08/2017]

DOC-Q19. Are high school diplomas from other countries acceptable documentation to verify a student's high school completion status?

DOC-A19. A high school diploma from a country other than the United States is acceptable as documentation to verify a student's high school completion status if the diploma is equivalent to a U.S. high school diploma. An institution with the expertise may determine whether a foreign secondary school diploma or certificate is equivalent to a U.S. high school diploma, or it may use a diploma evaluation service. [Section 668.57 and Volume 1 of the Federal Student Aid Handbook] [Guidance issued 04/25/2013]

DOC-Q20. What must institutions collect when a student established Title IV eligibility under one of the ability-to-benefit (ATB) alternatives but is selected under verification groups V4 or V5 to verify the student's high school completion status?

DOC-A20. In such cases, the institution should have already obtained or be in the process of obtaining documentation necessary to support the student's eligibility under one of the ATB alternatives (passed appropriate ATB test or successfully completed the requisite number of hours). Therefore, no further high school completion documentation should be needed from the student. [Section 668.57, Dear Colleague Letters GEN-12-09 and GEN-15-09] [Guidance issued 04/25/2013; revised 7/7/2015]

DOC-Q21. After a tax filer uses the IRS Data Retrieval Tool (IRS DRT) and the ISIR shows an IRS Request Flag code of '02' (IRS data were imported to the FAFSA and not changed), he or she makes a correction to one or more of the items that were imported (e.g., the amount for Untaxed IRA Distributions). The resulting CPS transaction would no longer have an IRS Request Flag code of '02'. Does the institution need to require the student to submit an IRS Tax Return Transcript to verify all of the IRS-related verification items, or can it use the original unchanged values and only verify the changed value?

DOC-A21. The institution may consider as verified the values of the unchanged IRS data items that were included on the CPS transaction that had an IRS Request Flag code of '02'. The institution need only verify items that were changed on the subsequent transaction. Note that if the reason for the changed item was that the institution determined, based on proper documentation, that the original IRS DRT value was incorrect, that documentation satisfies verification of that item. Generally, this would only happen when the Untaxed IRA Distributions is changed because of a rollover and the institution submitted the change to the CPS or directed the student to do so. However, if the proper documentation used is an IRS Tax Return Transcript, the institution must ensure that there is no discrepancy between the amount(s) on the transcript and what was reported on the FAFSA and shown on the ISIR. Also when both the IRS DRT is used and an IRS Tax Return Transcript is obtained, institutions must follow the guidance in Q&A DOC-Q14/A14. [Guidance issued 05/02/2014; and applies until the end of the 2017-2018 FAFSA processing year]

DOC-Q24. If, prior to the March 25, 2014, release of the 2014-2015 identity theft guidance provided in Dear Colleague Letter GEN-14-05, an institution completed verification for 2014-2015 using the identity theft guidance provided in Dear Colleague Letter GEN-13-16, must the institution re-verify the student for 2014-2015 following the guidance in Dear Colleague Letter GEN-14-05?

DOC-A24. No, if prior to the release of Dear Colleague Letter GEN-14-05 on March 25, 2014, the institution completed verification for a tax filer who was the victim of Tax Administration Identity Theft, as discussed in DOC-Q23, using guidance from Dear Colleague Letter GEN-13-16, the institution is not required to re-verify that tax filer’s information. In these cases, the institution must document that verification was completed before the release of Dear Colleague Letter GEN-14-05 on March 25, 2014. [Guidance issued 09/03/2014]

DOC-Q25. If a student who reported an item on the FAFSA, such as SNAP or child support, then later informs the institution that he or she did not receive the item, must an institution obtain documentation from the student confirming non-receipt of that item?

DOC-A25. If, based on the student’s statement that the item in question was not received, the institution wishes to make the required FAFSA change, the institution would need signed documentation from the student (and parent, if applicable) confirming the change, just as in any case where an institution makes a change to a student’s FAFSA information. If, however, the student made or makes the correction to the FAFSA, the resultant ISIR would have a different EFC that would require the institution to resolve the “conflicting information” that caused the difference. That resolution would include collecting written documentation from the student as to the circumstances for the misreported item, or the institution may include a note in the student’s file to document why there were changes between ISIRs. [Guidance issued 09/03/2014]

DOC-Q26. Is a government-issued photo identification that is not compliant with the REAL ID Act of 2005, e.g., one marked “not for federal identification,” acceptable documentation for an applicant selected to verify identity/statement of educational purpose?

DOC-A26. Yes. The REAL ID Act of 2005 currently affects individuals seeking access to restricted areas where identification is required e.g. Federal facilities or boarding Federally regulated commercial airplanes. Because there are currently no restrictions under the REAL ID Act on Federal agencies from accepting non-compliant identification for other purposes, such identification is acceptable to complete verification for an applicant required to verify identity/statement of educational purpose if that identification has not expired and includes the applicant’s photo and name. [Guidance issued 10/29/2014; revised 11/6/2014]

DOC-Q27. What documentation is required for an applicant, parent or spouse who is the victim of IRS tax-related identity theft?

DOC-A27. Individuals who are victims of IRS tax-related identity theft must submit to the institution–

  • A Tax Return DataBase View (TRDBV) transcript obtained from the IRS; and
  • A statement signed and dated by the tax filers indicating that they were victims of IRS tax-related identity theft and that the IRS has been made aware of the tax-related identity theft.

Tax filers may obtain a TRDBV transcript and inform the IRS of the tax-related identity theft by calling the IRS’s Identity Protection Specialized Unit (IPSU) at 1-800-908-4490. The IPSU will first authenticate the identity of the tax filer, who can then ask the IRS to mail them a TRDBV transcript. The TRDBV transcript will look different than a regular IRS tax return transcript, but it is official and can be used for verification. Tax filers who cannot obtain a TRDBV transcript may instead submit another official IRS transcript or equivalent document provided by the IRS if it includes all of the income and tax information required to be verified. Unless the institution has reason to suspect the authenticity of the TRDBV transcript or the equivalent document provided by the IRS, a signature or stamp or any other validation from the IRS is not needed. [Section 668.57(d)] [Guidance issued 7/7/2015; and applies beginning with the 2015-2016 award year]

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Changing Applicant's FAFSA Information (CHD)

CHD-Q2. Since IRA rollovers are not reflected on the IRS Tax Return Transcript or transferred into an online FAFSA using the IRS Data Retrieval Process, is changing the FAFSA to reflect the rollover exclusion a "correction," an "update" or "professional judgment?"

CHD-A2. Such a change is a correction and not updating or a use of professional judgment. [Guidance issued 10/10/2012]

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Verification Q&A | Program Integrity Q&A



   
Last Modified: 06/26/2018