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502-6 Verification Process

Title: Verification
Owner: Office of Financial Aid
Last Updated/Revised: 05/01/2024

Policy: The following are the institution’s policies regarding verification:

General

  • The verification process requires the school to check the accuracy of a student’s Free Application for Federal Student Aid (FAFSA) when the Department of Education (DOE) or school selects the student’s file for review.
  • The Office of Financial Aid (OFA) routinely reviews the accuracy of an applicant’s information by reviewing the information received on the Institutional Student Information Record (ISIR).
  • In addition to the following guidelines, the OFA must review and be knowledgeable of the DOE’s Federal Student Aid (FSA) Handbook, Application and Verification Guide.
  • The school may not accept verification results determined by other institutions.

Applicant Selection

Student files are selected for verification by one of the following methods:

  • By the Central Processing System (CPS) as indicated on the ISIR
    • If a subsequent ISIR is received that changes the student’s eligibility after verification has been conducted, the school will perform verification on the new ISIR transaction. An exception to this requirement is if a later transaction comes in after the student is no longer enrolled at the school.
  • The OFA may select any student for verification if there is reason to believe that the information on the student’s application may be inaccurate.
    • If the school selects an applicant for verification, OFA may choose to verify only specific data elements and use the applicable tolerance options.
  • All applicants selected by CPS and using financial aid, will be verified.
  • Graduate level students and above are exempt from all verification groups, except V4 – Custom Verification Group and V5 – Aggregate Verification Group.

Verification Exclusions

In the following circumstances, student verification is not required.

  • A student who died during the award year,
  • A student who does not receive Title IV aid for reasons other than failure to complete verification,
  • A student who is eligible to receive only Direct Unsubsidized Loans. However, students selected for V4 or V5 must complete verification,
  • A student selected for verification after ceasing to be enrolled at the school and after all Title IV aid has disbursed, and
  • A Title IV eligible student who is not utilizing financial aid and has provided a signed and dated written statement of their interest to decline Pell.

Notifications

  • The school must notify students of their selection for verification in a timely manner.
    • Verification notification will be communicated to the student via email or phone, upon receipt of an official ISIR selected for verification or at the time the school decides to select the student for verification.
  • Students selected for verification are not eligible for federal aid until the process is complete. Selected applicants must submit required verification documents, no later than the 6th day of the scheduled term start, in order to have their aid applied timely.
    • If the student fails to provide the required documentation within the established timeframe, then the student will be treated as a cash-paying student until the documents are provided.
  • The Office of Financial Aid reserves the right to make exceptions to the above-stated policies due to extenuating circumstances on a case-by-case basis.
  • Students will be given a clear explanation of the documentation needed to satisfy the verification requirements and the process for document submission.
  • The school will inform students, in a timely manner, of the consequences of failing to complete the verification requirements and the actions the school will take if the student does not submit the requested documentation within the time period specified by the school.
  • If the result of verification changes the student’s scheduled award an updated award letter will be sent to the student electronically via email.

Timing of Verification and Disbursements

  • Verification must be completed prior to the deadline set by the DOE as published in the annual Federal Register, or 120 days from the student’s last day of enrollment, whichever is earlier.
  • The school must not disburse any Title IV funds prior to the completion of verification and the resolution of all conflicting information.

After a Student Withdraws

  • A student may submit documentation to complete the verification process, after their withdrawal and completion of a Return to Title IV (R2T4) calculation, to become eligible for a late disbursement of federal aid.
  • For any student who provides verification documents missing at the time of withdrawal, the verification process must be completed by the deadline set by the DOE as published in the annual Federal Register, or 120 days from the student’s last date of attendance (LDA), whichever is earlier.

Referral of Fraud Cases

  • The Financial Aid (FA) representative must contact the Compliance team when there is a suspected fraud case. Any suspected case of fraud will be managed by the Compliance team and reported to the Regional Office of the Inspector General, or, if more appropriate, to a state or local law enforcement agency having jurisdiction to investigate the matter. Referrals to state or local agencies will be reported on an annual basis to the Inspector General.

Correcting FAFSA Information

ISIR corrections must be submitted to CPS for any changes to a non-dollar item or a single dollar item of $25 or more [34 CFR 668.59(a)]. If the school is required to submit a change to any single FAFSA data element because of verification, the school must submit all changes, including dollar amounts that are below $25.

  • All applicants must update dependency status and FAFSA information throughout the award year, except when the update is caused by a change in marital status.
  • All applicants selected for verification by CPS or the school, must update the household size and number in college to be correct as of the date of verification unless the update is due to a change in the student’s marital status.
    • In either of the above two situations, if the school deems it necessary to update a FAFSA application due to the student’s marital status, in order to more accurately reflect the applicant’s ability to pay, the decision must be made on a case-by-case basis.

Purpose: To establish the institution’s verification policy as required by 34 CFR 668.53. The policy will ensure the institution completes a review of information according to regulations regarding student and parental information reported to the U.S. Department of Education (DOE) on the current student/parental Student Aid Report (SAR) or Institutional Student Information Record (ISIR), for accuracy. The DOE or the school may select federal financial aid applications for a process called verification. Institutions receive an ISIR with a comment code 170 (Dependent) or 171 (Independent), which indicates the student has been selected for the verification process. Before being awarded Title IV funding, the school’s Financial Aid Department is responsible for notifying students of their responsibilities to complete the verification process and resolving all conflicting information.

Procedure:

  1. If a student is selected for verification, they will be notified of the selection and placed in the applicable hold group within the student information system until:
    1. Required documents have been completed and submitted by the student to the school; and
    2. Required documents have been reviewed for appropriated signatures, accuracy, and conflicting data has been resolved.

Professional Judgment

If an EFC (expected family contribution) adjustment is being exercised on a CPS selected ISIR, data elements may not be adjusted until all verification has been completed on the original data elements. This means verification will be completed and when the verified ISIR is returned, ISIR updates can the ben submitted for another transaction to complete the EFC adjustment.

Documents Required for the Verification Process

  • Verification Worksheets
  • Tax Return Information
    • Successful IRS Data Retrieval Tool (DRT), or
  • Tax Return Transcript for:
    • Student
    • Parents - for dependent students
    • Spouse - for married students (if not filed as ‘married filing jointly’)
  • Signed copy of the tax return and any applicable schedules
    • For persons who use a tax professional, the tax return does not have to have the filer’s signature, but it must have the name and PTIN of the preparer; or has his or her SSN or EIN and has been signed, stamped, typed or printed with his or her name and address.
  • Letter of Non-Filing
    • If a Student, Spouse, or Parent(s) did not file.
    • All applicants who will not file and are not required to file a U.S. federal tax return may provide income earned from work information on the verification worksheet and must provide copies of W-2’s, 1099’s and any statements of self-employment income.
  • Additional documentation may be requested based on the information provided.

Scope: This policy applies to all students who are selected for verification.

Documents and Forms: The verification worksheets available for completion are:

  • V1 Independent Verification Worksheet
  • V1 Dependent Verification Worksheet
  • V4 Independent Verification Worksheet
  • V4 Dependent Verification Worksheet
  • V5 Independent Verification Worksheet
  • V5 Dependent Verification Worksheet