Hands on Verification

Verification Tracking Groups Verification Tracking Flag 2016-2017 2017-2018 V1 Standard Verification Group V4 Custom Verification (HS Completion, Identity, SNAP, Child Support Paid) Custom Verification (HS Completion, Identity) V5 Aggregate Verification Group (Standard + HS Completion, Identity) V6 Household Resources (Standard + Untaxed Income) N/A

Both Tax Filers & Non Tax Filers What to verify for V1: Tax Filers Non Tax Filers Adjusted Gross Income Income Earned from Work U.S. Income Tax Paid (must have proof of earnings) Untaxed portions of IRA Distributions Untaxed portions of pensions IRA Deductions and Payments Tax Exempt Interest Income Education Tax Credits Both Tax Filers & Non Tax Filers Number of Household Members Number in College Snap, if indicated on the ISIR (no longer required in 17-18) Child support paid

Reporting Results for groups V4 and V5 You must report the verification results of identity and high school completion status for any student for whom you receive an ISIR with tracking flag V4 or V5—as selected by the CPS, not your school—and request verification documentation. You report this information on the FAA Access to CPS Online website: select the Identity Verification Results option from the main menu, enter your school identifiers, the year, and the student identifiers. You will then enter one of the following numeric codes that most applies: • 1—verification completed in person, no issues found • 2—verification completed using notary, no issues found • 3—verification attempted, issues found with identity • 4—verification attempted, issues found with HS completion • 5—no response from applicant or unable to locate

Amended Taxes Students or parents who file an amended return (IRS Form 1040X) cannot use the IRS DRT, and if they amend the return after using the DRT to fill out the FAFSA, you cannot rely on that data. Instead, you will need to use information from these documents to complete verification: a signed copy of the 1040X form that was filed and an IRS tax return transcript (that will only include information from the original tax return and that does not have to be signed), or any other IRS transcript (such as a return transcript for taxpayer or RTFTP) that includes all the income and tax information required to be verified: AGI, income tax paid, education credits, etc.

4506-T Request for Transcript of Tax Return

Identity Theft Victims of identity theft who cannot get a return transcript or use the DRT submit a Tax Return DataBase View (TRDBV) transcript as well as a statement they have signed and dated indicating that they were victims of tax-related identity theft and that the IRS has been made aware of it. They do this by calling the IRS’s Identity Protection Specialized Unit (IPSU) at 800-908-4490. After the IPSU authenticates the tax filer’s identity, she can ask the IRS to mail her the TRDBV transcript, which is an alternate paper transcript that will look different than a regular transcript but that is official and can be used for verification. Unless you doubt the TRDBV transcript’s authenticity, you don’t need to get an IRS signature or stamp or any other validation. See DCL GEN-14-05 for a sample TRDBV transcript. Those who cannot obtain a TRDBV transcript may instead submit another official IRS transcript or equivalent IRS document if it includes all of the income and tax information required to be verified.

Tax Filing Requirements https://www.irs.gov/pub/irs-pdf/i1040gi.pdf Form IRS 1040 Instructions – Page 8-10

Tax Filing Requirements https://www.irs.gov/pub/irs-pdf/i1040gi.pdf Form IRS 1040 Instructions – Page 8-10

Tax Filing Requirements Cont. https://www.irs.gov/pub/irs-pdf/i1040gi.pdf Form IRS 1040 Instructions – Page 8-10

Sample Tax Transcript

Sample Tax Transcript

16-17 Tax Return Transcript Matrix https://ifap.ed.gov/eannouncements/attachments/050416Revised20162017FAFSAVerifIRSTrans criptMatrix.pdf

Sample Verification Check List

Scenario If a student has not been selected for verification but the family has submitted a copy of their tax return or tax return transcript, do you have to review the information for accuracy?

Answer Yes, if you find conflicting information, you must update the FAFSA with correct information.

Scenario A dependent student completed the FAFSA providing parent information. Parent 1 completed a PLUS Loan form. Your staff checked Parent 1’s default status and realized that Parent 1 had a different last name than Parent 2 and the student. Does your staff need to make sure Parent 1 is a legal parent?

Answer Yes, you need to make sure that the parent on the FAFSA is a “legal” parent (biological, adoptive, or determined by the state). You will need to correct the FAFSA with appropriate information to resolve conflicting information and confirm that the parent who completed the PLUS Loan is considered a legal parent.

Scenario Can both parents on a FAFSA file as “Head of Household”?

Answer If parents were legally separated according to their state law If parents are married but lived apart for the last 6 months of 2015 Each home was the main home of a child for more than half the year, parent paid more than half support; and The tax filer is able to claim an exemption for the child

Scenario If a student and/or parent completes the verification documentation and provides income that doesn’t match lines 7, 12, & 18, is this considered conflicting information?

Answer Yes, you need to request additional documentation to verify lines 7, 12, & 18 which may include: All W-2s Schedule C (Business Income) Schedule F (Farm Income) Signed statement of earnings

Scenario A student indicates on a verification worksheet that he did not file a tax return and earned $4,000. He also submits a 1099 as proof of income in the amount of $4,000. Is this student required to file a tax return?

Answer Yes, anyone who had net earnings from self-employment of at least $400 is required to file a tax return.

Scenario A dependent student claimed their 26 year old brother on the verification worksheet. Does you have to correct the dependent student’s FAFSA and remove the 26 year old brother from the FAFSA since the 26 year old brother can file their own FAFSA as an independent student?

Answer No, if the parent claims that they still provide more than half of the siblings support, you should not update the FAFSA. *Don’t forget to confirm # in college if independent brother is enrolled as an at least half time student.

Scenario Through the verification process, you determine that Parent 2’s income was underreported by $20. Do you need to submit a correction on the student’s FAFSA?

Answer No. For students who are selected for verification and receiving subsidized student aid, changes that result to any non-dollar item and any only dollar item of $25 or more must be submitted for processing.

Scenario A family submits verification documentation. One parent filed as Married filing separately and one filed as Head of Household. You contact the parent who filed as Head of Household and realize that they have to amend their tax return as they don’t qualify for the Head of Household filing status. You receive an amended tax return and notice that the Adjusted Gross Income has also been adjusted. Is this considered conflicting information?

Answer Yes, changing filing status impacts tax liability not their adjusted gross income. You need to collect additional documentation to correct the conflicting information.

Scenario A family submits verification documentation and includes their foster child as a member of their household. Is this allowed?

Answer Maybe? Typically foster children do not count in the household size as their costs are covered by foster care payments. However, children in “kinship foster care” for whom no benefits are provided can count the student in the household size if they meet the tests for other persons, i.e., if they live with & receive more than half of their support from their foster parents for the award year.

Scenario Two of your typical college age students live together and have a child together. Can both students be considered independent?

Answer No. Only one parent can indicate that they provide more than half of the child’s support. The other student would have to provide parental information on their FAFSA.

Scenario Two of your typical college age students have a child together but live separately. Can both students be considered independent?

Answer Yes, under very limited scenarios: Need to determine if support from either student amounts to more than half support. Mother can claim she is providing more than half support based on child support received. Father can claim he is providing more than half support based on child support paid.

Audience Scenarios

Resources Dear Colleague Letter GEN-15-11: https://ifap.ed.gov/dpcletters/GEN1511.html Dear Colleague Letter GEN-16-07: https://ifap.ed.gov/dpcletters/GEN1607.html Federal Register published June 26, 2015: https://ifap.ed.gov/fregisters/attachments/FR062615FAFSA20162017BeVerified.pdf3 Federal Register published April 1, 2016: https://ifap.ed.gov/fregisters/attachments/FR040116FAFSA20172018BeVerified.pdf Application and Verification Guide 2016-2017: https://ifap.ed.gov/fsahandbook/attachments/1617AVG.pdf NASFAA Verification Webinar June 8, 2016

Questions ?

Thank you! My contact information: Karen Gagnon Director of Student Financial Planning Morningside College 1501 Morningside Avenue Sioux City, IA 51106 800-831-0806 ext. 5272 712-274-5272 gagnon@morningside.edu