Verification

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National Association of Student

Financial Aid Administrators

The following is a presentation prepared for:

MASFAA

Indianapolis, IN

October 6 -9, 2013

Eunice Powell – Senior Training Specialist

Division of Training & Regulatory Assistance

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Verification

IRS DRT

Student FAFSA CPS School

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Verification

Foreign

Tax

Return

Amended

Return

Tax

Transcript

Identity

Theft

Tax

Extension Number in

College

Household

Size

Student

Child

Support

Paid

SNAP

IRS DRT

FAFSA

Name

Change

Statement of

Educational

Purpose

Notary

Public

School

High

School

Completion

Home

School

Completion

GED

Doogie

Howser?

V5

V1

V2

V3

V6 V4

CPS

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Overview of Session

• Review verification tracking groups and changes for

2014 –15

• Address a variety of questions on verification topics

• Discuss your institutions’

– Policies

– Practices

– Challenges

– Success stories

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6

Verification Tracking Groups and Codes

2013 –14

V1

V2

V3

V4

V5

Standard

SNAP

Child Support

Custom

Aggregate

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2014–15 Tracking Groups and Codes

2013 –14

V1

V2

V3

V4

V5

Standard

SNAP FSA Use Only

Child Support

Custom

Aggregate

Household Resources

2014 –15

V1

V2

V3

V4

V5

V6

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V6 Household Resources Tracking Group

Other Untaxed Income

• Payments to tax-deferred pension and savings

• Child support received

• Housing, food, and other living allowances paid to members of the military, clergy, and others

• Veterans noneducation benefits

• Other untaxed income

• Money received or paid on the applicant’s behalf

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Verifying Income

Tax Filers V1 V3 V4 V5 V6

Adjusted

Gross

Income

(AGI)

U.S.

Income

Tax

Paid

Untaxed portions of

IRA distribution/ pensions

IRA deductions and payments

Tax exempt interest income

Education credits

Nontax Filers

Income earned from work

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Verifying Income

• Include income for both of student’s legal parents if parents live together

– See GEN-13-12

• No information yet on verification impact of Supreme

Court decision on Defense of Marriage Act (DOMA)

– GEN-13-12: April 29, 2013

– GEN-13-16: June 13, 2013

– Supreme Court decision: June 26, 2013

V1 V3 V4 V5 V6

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Household Information

• Indicate household members enrolled at least halftime in a Title IV-eligible program during award year, other than parents

• Impact of GEN-13-12 on household size

V1 V3 V4 V5 V6

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Household Information

• Household size not verified if

– Independent student

 Household size is one and applicant is single

 Household size is two and applicant is married

– Dependent student

 Household size is two and parent is single

 Household size is three and parents are married or unmarried and living together

• Number in college not verified if “1” reported

V1 V3 V4 V5 V6

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SNAP/Child Support Paid

• Verify for all tracking groups if SNAP or child support paid is included on ISIR

• Although SNAP tracking group is removed, remains required verification item

• An institution may accept records of electronic payments of child support paid

• If no amount originally reported on FAFSA, update

ISIR with corrected amount

V1 V3 V4 V5 V6

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High School Completion

• May rely on document institution collects for admission or other purposes if the document:

– Demonstrates high school completion (not 7 th semester transcript)

– Is readily available

• Foreign diploma or “Secondary school leaving certificate” for foreign students

• Alternative documentation does not include selfcertified statement of completion

V1 V3 V4 V5 V6

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Equivalent of High School Diploma

Submit documentation for 1 of the 4 following equivalents:

GED

Certificate

GED

Transcript

State Certificate

– Student passed a state authorized exam

– State recognizes as equivalent of a high school diploma

Academic

Transcript

– Student successfully completed two-year program acceptable for full credit toward bachelor’s degree

V1 V3 V4 V5 V6

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Equivalent of High School Diploma

Student who excelled academically in high school, and:

• Did not complete high school

• Is enrolling in an associate or higher level program

Documentation

From High School

- Student excelled academically

Institutional

Documentation

- Student met school’s formal, written policy for admission

V1 V3 V4 V5 V6

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Statement of Educational Purpose/Identity

• Present in person both:

– Valid, government-issued photo identification

– Signed statement

• Notarized if unable to appear in person

• Statement must use exact language issued by ED

V1 V3 V4 V5 V6

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Homeschooled

Submit either:

Transcript

(or equivalent)

– Lists secondary school courses completed

– Documents successful completion of a secondary school education

– Signed by parent or guardian

V1 V3 V4 V5 V6

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Secondary School

Completion Credential

– Issued for home school

– Recognized under state law

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Statement of Educational Purpose/Identity

• Institution must authorize individuals who review identity documents

• Include authorized individuals in policies and procedures

• Maintain annotated copy of ID document

– Date identification received

– Name of individual who received ID

V1 V3 V4 V5 V6

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Statement of Educational Purpose/Identity

Report “Identity Verification Results” for all applicants contacted to verify identity and high school completion

• Verification completed in person, no issues found

• Verification completed remotely, no issues found

• Verification attempted, issues found with identity

• Verification attempted, issues found with high school completion

• No response from applicant

V1 V3 V4 V5 V6

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Untaxed Income

• V6 Household Resources Verification Tracking

Group

• Untaxed income items not on IRS tax return

• V6 must also verify:

– Income

– Household size / number in college

– SNAP, if reported on FAFSA

– Child support paid, if reported on FAFSA

V1 V3 V4 V5 V6

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Untaxed Income

If combined income sources appear too low to financially support family:

• Contact student or parent to request sources and amounts of financial support received during 2013 calendar year

• ED will provide suggested text

• Correct for additional income, if any, identified during process

V1 V3 V4 V5 V6

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Must we complete verification for a student receiving only a Direct Unsubsidized Loan?

• No, unless the student is eligible for need-based aid but has declined it, or later becomes eligible for need-based aid

• Strongly encouraged to verify high school completion status and identity/statement of educational purpose for V4, V5 applicants

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For institutionally selected students, must we request the same documents specified by ED?

• Institution can determine what elements to verify and what documentation to accept for applicants it selects

– If CPS selects applicant on a subsequent ISIR, institution must collect required documentation

• Quality Assurance (QA) institutions are exempt from verification rules

• Corrections must be sent to CPS

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What are we supposed to verify for Automatic

Zero EFC students?

• Minimal requirements for V1 and V5

• Dependent students

– Parents’ AGI if tax filer

– Parents’ income earned from work if nontax filer

– Receipt of SNAP if auto zero based on SNAP

• Independent students

– AGI if tax filer

– Income earned from work if nontax filer

– Number of household members

– Receipt of SNAP if auto zero based on SNAP

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What are we supposed to verify for Automatic

Zero EFC students?

• Must verify high school completion status and identity/statement of educational purpose for V4, V5

• Must also verify SNAP and child support paid, if reported on ISIR

• Untaxed income verification for V6 pending ED guidance

• (This guidance applies to 2013–14, ED has not yet released official 2014 –15 guidance)

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How do we identify and handle IRS rollovers of

IRA’s, pensions, or annuities?

• Untaxed portion of IRS distribution on ISIR may indicate rollover, or actual distribution

• Additional documentation needed from tax filer to identify IRS rollover

– Signed statement, or

– Signed, dated IRS Tax Return Transcript with

“Rollover” noted beside applicable item(s)

• Considered a correction, not PJ

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Are we supposed to use text provided by ED for verification requests?

• Suggested text provided in lieu of verification worksheets

• Must use exact wording for Statement of

Educational Purpose

• All other examples are suggestions

• ED will provide suggested text for new V6 verification tracking group (untaxed income)

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Can we update a student’s marital status change only during verification?

An institution may require an applicant to update dependency status at any time during the award year due to a marital status change

• To address an inequity or to reflect more accurately the applicant’s ability to pay

• The applicant need not have been selected for verification

• Other items must also be updated to reflect the marital status change (household size, number in college, spouse’s income, etc.), which may require verification

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Please send your questions to: powelle@nasfaa.org

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