Se ssio n

17

Update on Verification
Requirements

Gregory Martin
Thomas Threlkeld
 Why do I have to Verify?
 Maintain program integrity
– Over $60 billion in grants, loans, and work-study
assistance
– Over $12 billion in Federal Pell
– Over 9 million aid recipients
– Maintaining the integrity of the student aid
programs and minimizing improper
payments is a major objective of all
partners in the financial aid process
 It’s All About Being Right
 To insure
– The right amount of money
– To the right student
– At the right time
– In the right way
 To maintain
– Support of Congress
– Confidence of public
 What is Verification?
 Process by which institutions ensure
that certain information provided on the
FAFSA is reviewed for accuracy and
completeness
 Law and implementing regulations
– Sec. 487 of the HEA 1965, as amended,
20 U.S.C. 1094
– 34 CFR 668.51 – 668.61 (Subpart E)
 Policies and Procedures
 Institution must establish and use
written policies and procedures for
verifying information
 Institution’s procedures must provide for
clear and timely notification of
– Selected applicants’ responsibilities and
– Clear explanation of required
documentation
 Policies and Procedures
 Policies and procedures must include:
– Deadlines for students to provide documentation
– Consequences of failure to provide required
documentation
– Method by which student will be notified of award
changes resulting from verification
– Procedures for correction of applicant data
– Procedures for referring overpayments to the U. S.
Department of Education
 Selection of Applicants
 Central Processing System (CPS)
– Annual process to develop new and improved
selection criteria
• ED/IRS statistical studies comparing AGI and taxes paid
• Edit checks which identify inconsistencies and potential
errors
– Selects 30% of total applicants
 Institution
– School’s criteria
 30% Verification Option
 No institution is required to verify more
than 30% of its total applicants for Title
IV assistance
– School defines total Title IV applicants
– School may include in its 30% only those
applicants selected for verification by the
CPS
• Must verify any applicant’s information that
school has reason to believe is inaccurate
 Required Verification
Items
 Adjusted gross income
 U. S. income tax paid
 Number in household size
 Number of household members
enrolled in eligible postsecondary
school as at least a half-time student
 Untaxed income and benefits
 Untaxed Income and
Benefits
 Social Security Benefits
 Child support
 IRA/Keogh deductions
 Foreign income exclusion
 Earned income credit (EIC)
 Interest on tax-free bonds
 Any other untaxed income sources
reported on the tax return
 Acceptable
Documentation
 AGI and taxes paid
– Base year tax return or IRS form that lists tax
account information
– Statement of non-filer status and sources and
amounts of income
 Household size and number in college
– Signed statement or verification worksheet
– Enrollment verification from institution
 Untaxed income and benefits
– Base year tax return
– Official agency documentation
– Signed statement or verification worksheet
 Acceptable
Documentation
 Tax filers who file extensions
– Copies of W2 forms and
– IRS form 4868 or
– Copy of IRS approved extension
 Tax filers who file fiscal year return
– Return for FY that includes greater number of
months in base year
 Nonresident filers
– Form 1040 NR
 Foreign income
– Foreign tax return or value reported in US dollars
 Acceptable
Documentation
 Joint return to verify individual income
and tax information
– Calculate individual’s AGI using relevant
W2 form(s)
• Add any other income that can be determined
from the joint return
– Calculate individual’s taxes paid using
• Tax table method or
• Proportional method
 Exceptions to Verification
Items
 If institution receives ISIR within 90
days of applicant’s signing FAFSA,
institution is not required to verify
– Household size
– Number in college
 If HHS and/or child support is the same
as that verified in the previous award
year, institution is not required to verify
 Exclusions from
Verification Process
 Student dies during award year prior to
completing verification
 If there is no reason to believe
information reported is incorrect
– Incarcerated students
– Previously verified transfer students
– Recent immigrants
– Non-title IV recipients
 Exclusions from
Verification Process
 Parents’ information for a dependent
applicant whose parental information is
unobtainable
 Spouse’s information for independent
applicant whose spouse’s information is
unobtainable
 Legal residents of Guam, American Samoa,
or Northern Mariana Islands and citizens of
the Marshall Islands, Federated States of
Micronesia, or Republic of Palau
 Interim Disbursements
 If there is no conflicting data or reason
to believe information is inaccurate,
schools may:
– For Federal Pell, FSEOG, and Perkins
• Withhold payment or
• Make one disbursement for student’s first
payment period
 Interim Disbursements
– For FWS
• May withhold payment or
• Employ applicant for first 60 consecutive days
after student’s enrollment in that award year
– For Federal Stafford Loan and Direct
Subsidized Loan funds:
• Refuse to certify or originate loan or
• Certify or originate loan, but may not deliver
loan proceeds to borrower
 Interim Disbursements
 Institution is liable if interim disbursement
causes an overpayment
– May eliminate overpayment by adjusting Title IV
aid in subsequent payment period
– For Pell, Perkins, FSEOG, reimburse program by
earlier of 60 days after LDA or last day of award
year
– For Stafford, withhold and return any amount of a
disbursement received but not yet delivered for
which student is ineligible based on verified
information
 Updating Information
 Applicants selected for verification must
update information as of the date of
verification
– NOTE: applicants not selected for
verification cannot update for changes
occurring after original application
 Updating Information
 Must always update dependency status
if it changes during an award year
– Unless the reason is a change in the
student’s marital status
 Must always update household size and
number in college when student is
selected for verification
– Unless the reason is a change in the
student’s marital status
 Updating Information
 Institution must complete verification
before it exercises professional
judgment to change the EFC of a
student selected for verification
 Recalculating Changes
 If as a result of verification, the EFC
changes
– For Pell
• Applicant must submit correction to the CPS
• The Pell award must be based on the corrected
ISIR
– For Campus-Based and Stafford
• Applicant is not required to submit correction
• Institution is liable if pays based on an incorrect
EFC
 Verification Tolerance
Option
 No recalculation of EFC is required if as
a result of verification, there are
– No errors in nondollar items and
– No net difference greater than $400 in
dollar items
• Compare original AGI plus untaxed income and
benefits minus original U.S. taxes paid and
• Corrected AGI plus untaxed income and
benefits minus corrected U.S. taxes paid
 Verification Tracking
Number
 Identifies priority for selection and
likelihood of error
– Does not mean applicant was selected for
verification
 Higher number indicates higher risk
– Range is 00 to 99 for 2003-2004
– Range is 0001 to 9999 for 2004-2005
 Verification Tracking Flag

 “For Financial Aid Office Use Only”

– Y indicates student is selected for
verification
– N indicates student is not selected
– * indicates student is selected on a
subsequent transaction
 Verification Codes
 For 2003-2004 and 2004-2005
–V verified
–W without documentation
–S selected but not verified
– Blank not selected or verified
 Changes After
Verification
 School must review all subsequent
ISIRs received even if verification has
been completed
– NSLDS postscreening
– INS/BCIS secondary confirmation
– Student or parent may make change
– Another school may make change
 Changes After
Verification
 School must review
– Multiple reporting records (MRRs)
• Concurrent enrollment
• Potential overaward
– NSLDS transfer monitoring alerts
 Verification Deadlines
 For Pell Grants
– Earlier of 120 days after last day of enrollment or
August 31, 2004
• Student may never increase Pell award during
verification extension
 For Campus-Based, subsidized FFEL and
Direct Loans
– Earlier of institution’s verification deadline or the
dates established by the Secretary (see above)
 Conflicting Information
 Conflicting information
– Must be resolved for all Title IV recipients
– Includes any information affecting Title IV
recipient’s eligibility
 Verification
– Must be completed for “selected” Title IV
recipients
– Includes specific ISIR data elements
 Verification Assistance
 Student Financial Aid Handbook
 COACH
 FSA Assessments
– FSA verification module
• Requirements
• Activities/tests
• Community Q&As
– ISIR Analysis Tool
 Additional References
 Federal Register (Dec. 12, 2003 )
– Provides waivers and modifications of
some statutory and regulatory provisions
for certain individuals pursuant to the
HEROES Act
 DCL GEN-04-03 (Feb. 2004)
– Addresses issues relating to verification
and the calculation of R2T4
 Related Conference
Sessions
 Session 31 – FSA Assessments:
Evaluation Tools to Keep You on Track
 Session 7 – The New FSA Handbook:
Who Moved the Gruyere?
 Session 11 – Managing the “Conflicting
Information” Requirements of the
Regulations
QUESTIONS?

Greg Martin
[email protected]
(215) 656-6452

Tom Threlkeld
[email protected]
(617) 223-9558