1. Director of Financial Aid 2005-06 NASFAA National Chair
Federal Verification
David Gelinas
Director of Financial Aid
Davidson College
NASFAA National Chair
Fall Conference November 6 - 8, 2017

2. Fall Conference November 6 - 8, 2017
Who Must Be Verified?
Per the Application and Verification Guide (AVG), “You must verify applications selected by the [Central Processing Service] of students who will receive or have received subsidized student financial assistance[.] Verification is not required for students who are only eligible for unsubsidized student financial assistance[.] Students who are eligible for both subsidized and unsubsidized Title IV aid may not avoid verification by accepting only unsubsidized aid[.]” (AVG-77)
Fall Conference November 6 - 8, 2017

3. Subsidized vs. Unsubsidized
34 CFR defines subsidized and unsubsidized student financial assistance programs
Subsidized programs are “Title IV programs for which eligibility is determined by the EFC”
Unsubsidized programs are “Title IV programs for which eligibility is not based on the EFC”
Fall Conference November 6 - 8, 2017

4. Which Programs Are Which?
Subsidized
Pell Grant
FSEOG
Federal Work Study
Perkins Loan (a moment of silence, please)
Direct Subsidized Loan
Unsubsidized
TEACH Grant
Direct Unsubsidized Loan
Direct PLUS Loan
Iraq and Afghanistan Service Grant
Fall Conference November 6 - 8, 2017

5. Required Policies and Procedures
You must have WRITTEN policies and procedures on:
Deadlines for submitting documentation
And the consequences for missing them
How you’ll notify students if verification changes the award
Required correction procedures
Procedure for referring student to OIG
Fall Conference November 6 - 8, 2017

6. Fall Conference November 6 - 8, 2017
In Addition to Those…
You must give each student selected “in a timely manner...a clear explanation of”:
Required documents
Student responsibilities
Deadlines for completion
Consequences of failing to complete any required action
Fall Conference November 6 - 8, 2017

7. Fall Conference November 6 - 8, 2017
Who Must Be Verified?
Applicant selected by Central Processing System (CPS) or the school
CPS selected:
Verification flag with value of “Y”
Asterisk next to EFC on SAR
Any application the school believes has either incorrect or discrepant information
Any additional application(s) the school selects
You can select all applicants (some schools do)
Fall Conference November 6 - 8, 2017

8. Verification Tracking Groups
V1 – Standard Verification Group
V2 – Reserved for future use by USED
V3 – Reserved for future use by USED
V4 – Custom Verification Group
V5 – Aggregate Verification Group
Must verify all elements of V1 and V4
V6 – Reserved for future use by USED
Fall Conference November 6 - 8, 2017

9. Required Elements of Verification Groups
V1 – Standard Group
Adjusted gross income
U.S. income tax paid
Untaxed portions of IRA distributions
Untaxed portions of pensions
IRA deductions and payments
Tax-exempt interest income
Education credits
Household size
Number in college
Fall Conference November 6 - 8, 2017

10. Required Elements of Verification Groups (cont.)
V4 – Custom Group
“Students must verify high school completion status and identity/statement of educational purpose.”
V5 – Aggregate Group
“Students must verify high school completion status and identity/statement of educational purpose in addition to the items in the Standard Verification [V1] Group.”
There are six reporting results for V4 and V5
You report the correct result on FAA Access to CPS Online
Fall Conference November 6 - 8, 2017

11. Fall Conference November 6 - 8, 2017
Documentation
“The documentation you will need for verification varies according to the item verified…The Department encourages students and parents to use the IRS Data Retrieval tool (DRT) to import data from their tax return and not change it…[You can use] suggested text developed by the Department…to create an institutional verification document if you choose and to verify non-tax items, such as household size and number in college.” (AVG-81)
Fall Conference November 6 - 8, 2017

12. Fall Conference November 6 - 8, 2017
And Then DRT Went Down…
Dear Colleague Letter GEN (dated April 24, 2017) addressed “the impact of the suspension of the…IRS DRT on students and families who have been selected for verification[.]”
The guidance in GEN replaced the guidance in the 10/18/16 Electronic Announcement on documentation for verifying 2015 income and tax information
Signed copies of 2015 IRS tax returns were acceptable documentation
Verification of Nonfiling “no longer required[.]”
Fall Conference November 6 - 8, 2017

13. Saved By Prior-Prior Year
“The documentation used to verify any of the following FAFSA items for may be used for verification if that documentation is acceptable…”:
Adjusted gross income
U.S. income tax paid
Untaxed portions of IRA distributions
Untaxed portions of pensions
IRA deductions and payments
Tax-exempt interest income
Education credits
Fall Conference November 6 - 8, 2017

14. Verifying Household Size
“To document the household size, the student needs to provide a statement signed by him and, if dependent, at least one parent that gives the name, age and relationship to the student of each person in the household.”
You do NOT have to verify household size when:
Dependent student
Married HH size is 3; single-parent HH size is 2
Independent student
Married HH size is 2; single HH size is 1
Fall Conference November 6 - 8, 2017

15. Verifying Number In College
“You can document this item with a statement signed by the student (and, if she is dependent, at least one parent) that gives the name and age of each person in the household (excluding the parents of a dependent student) who is enrolled at least half time in a degree or certificate program at an eligible college. The statement must also give the name of each college, and it can be written to document household size as well. Completion of the Department’s verification suggested text can satisfy both items.” (AVG-86)
Fall Conference November 6 - 8, 2017

16. Verifying High School Completion
AVG-87 contains a list of 10 acceptable documents that indicate a student’s high school completion status as of the beginning of the year.
“If your school has already received one of these [ten] documents as part of the admission process, you do not need to ask for another. Also, if you successfully verified a student’s high school completion in a prior year, you do not need to do it again.” (AVG-87)
Fall Conference November 6 - 8, 2017

17. Fall Conference November 6 - 8, 2017
Verifying Identity
“Students should appear in person at your school and present a valid, unexpired, government-issued photo identification (ID) such as a passport or a driver’s license or other state-issued ID. You must maintain an annotated copy of that ID that includes the date it was received and the name of the person your school authorized to receive it. Note that an ID issued by a state university or college is not sufficient for this purpose.” (AVG-88)
Fall Conference November 6 - 8, 2017

18. Statement of Educational Purpose
“Students must also sign a statement of educational purpose [in person or in front of a notary public] that certifies who they are and that the federal student aid they may receive will only be used for educational purposes and for the cost of attending the school for the year…[T]he text for this statement is not suggested—you must use the exact language given [in the AVG.] You must keep [this statement] for at least the required Title IV record retention period.” (AVG-88)
Fall Conference November 6 - 8, 2017

19. Fall Conference November 6 - 8, 2017
Updating
Only certain items on the FAFSA can be updated after the FAFSA was signed:
Applicants whose dependency status changes
“…except when the update is caused by a change in the student’s marital status.”
Applicants selected to verify household size or number in college
These numbers must be correct as of the date of verification
Either may be updated, however, on a case-by-case basis “to address an inequity or to reflect more accurately the applicant’s ability to pay.”
Fall Conference November 6 - 8, 2017

20. Fall Conference November 6 - 8, 2017
Correcting
“[F]or students who are not selected for verification, you or they must correct and submit for processing any errors reported on the original FAFSA that would change the EFC of that determine the students’ eligibility for aid.”
For students who are selected for verification and receiving subsidized student aid, changes that result to any non-dollar item and to any dollar item of $25 or more must be submitted for processing.” (AVG-89)
Fall Conference November 6 - 8, 2017

21. Professional Judgment
“You must complete verification for a selected student before you exercise professional judgment to adjust any values that are used to calculate the EFC. But making a [professional judgment] adjustment does not require you to verify an application that isn’t selected.” (AVG-77)
Fall Conference November 6 - 8, 2017

22. Fall Conference November 6 - 8, 2017
References
34 CFR
Application and Verification Guide
Chapter 4, Verification, Updates and Corrections
Dear Colleague Letter GEN-17-04
Fall Conference November 6 - 8, 2017

23. Please visit them and let them know how much you appreciate it.
NCASFAA would like to thank our Professional Affiliates for their support.
Please visit them and let them know how much you appreciate it.
Fall Conference November 6 - 8, 2017