Verification
Where We are and What’s Ahead
Agenda
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General Purpose and Policies
2013-2014: Where we are
2014-2015: What’s ahead
Impact of GEN-13-12
Resources
Purpose
• To ensure funding is allocated to
applicants with the greatest need by
checking data elements for accuracy and
completeness
• Federal criteria targets error prone data items specific
to an applicant
• Non-selected applicants are again subject to risk
model when submitting corrections
General Policies
• Required of all applicants selected by the
Department of Education who are eligible
or receiving subsidized Title IV aid:
o
o
o
o
o
Pell Grants
Subsidized Loans
FSEOG
FWS
Perkins
General Policies, cont.
• Not required if applicant only receiving:
o Unsubsidized loans
o PLUS loans
o TEACH Grant
• School may select applicants for verification
who were not originally selected by the
Department
o School may use institutional criteria for choosing who to
select
o School may select which data elements to verify and is not
required to verify federal data elements if not selected by
the Department
General Policies, cont.
• For subsidized programs, submit all
verification changes (not just those that
affect Pell) to CPS if change is:
• To any non-dollar item that affects the EFC or
• A single dollar item of $25 or more
• $400 tolerance ended in 2011-12
• If required to submit one change, must
submit all changes
General Policies, cont.
• Updating Marital Status:
- MAY require student to update FAFSA if
change in applicant’s marital status
necessary to address an inequity or reflect
more accurately ability to pay
• FAFSA needs to reflect accurate household
size, # in college, dependency status and
family financial information
General Policies, cont.
Marital Example 1
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20 Year Old Dependent Female student
Parental info required
Filed 2013-14 FAFSA on 2/15/2013
Gets married on 7/4/2013
If selected for verification, school may:
1) Make no change
2) Update information to more accurately reflect the ability
to pay, but if so, must update other items to reflect
current situation
Note: If not selected (by ED or the school), you cannot update
General Policies, cont.
Marital Example 2
• The parent of a dependent student remarries
between application and verification
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(2013-14 FAFSA filed 1/10/2013; married 1/12/2013; selected for
verification 4/20/2013)
• Must update HH size to include the new stepparent.
• However, would not automatically add in the new
stepparent’s income and assets. The school may use PJ
to include the stepparent’s income or to otherwise account
for the change.
• HEA Sec. 475(f)(3)
• 34 CFR 668.55(b)
General Policies, cont.
• If a student is selected (by either the Dept.
or the school), a school MUST NOT
complete any professional judgment until
the ISIR has been verified
General Policies, cont.
• If not selected, may complete professional
judgment without formal verification
• ISIR should be marked as PJ when this is
done; if coded, ISIR will not be
subsequently selected by the Department
Verification 2013-14
Where We Are
2013-2014 Verification
• Introduction of verification groups
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V1, V2, V3, V4, V5
• Introduction of identity and high school
completion elements
Tracking Groups and
Data Elements
V1: Data and
Documentation
• Data elements:
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Household size
Number in college
Income and tax information
Child support paid
SNAP
• Documentation
o Signed worksheets, DRT, tax transcript, etc.
o Largely unchanged from prior year
V2: Data and
Documentation
• Data element:
o SNAP Benefits
• Documentation
o Signed statement of receipt or
o Document from issuing agency if it is:
• For all students as part of the school’s verification policy
• For selected students when there is a reason to question the information or
documentation provided
• ONLY applies if reported on FAFSA
V3: Data and
Documentation
• Data element:
o Child support paid
• Documentation
o Verification worksheet (or signed certification of
payment), indicating—
• Amount of child support paid
• Name of the person to whom it was paid, and
• Name of the children for whom it was paid
V4: Data and
Documentation
• Data element:
o High School Completion and Statement of
Identity/Purpose
o May also include Child Support Paid and SNAP (if
indicated on the FAFSA)
• Documentation
o Verification worksheet (or appropriate SNAP/Child support
paid documentation)
o Proof of high school completion or alternative
documentation
o Proof of identity and statement of educational purpose
V4: Data and
Documentation, cont.
• High School Completion:
• High School Diploma
• Copy of Final HS Transcript Showing Graduation Date
• Alternative Documentation
o GED, State Exam, Transcript of 2-year Program with
Credit toward Bachelor’s Degree, OR…
“For a person who is seeking enrollment in an
educational program that leads to at least an
associate degree or its equivalent and has not
completed high school but has excelled
academically in high school, documentation
from the high school that the student excelled
academically when in high school and
documentation from the postsecondary
institution that the student has met the
formalized, written policies of the
postsecondary institution for admitting such
students”
V4: Home Schooled
Students
• Transcript or the equivalent, signed by the
parent or guardian, that lists the secondary
school courses completed by the applicant
and documents the successful completion
of a secondary school education; or
• A secondary school completion credential
for home school (other than a high school
diploma or its recognized equivalent)
provided for under State law
V4: Identity/Purpose
• Appear in person and present to an institutionally
authorized individual-• A valid government-issued photo identification
(driver’s license, non-driver’s license, military
identification, or passport); and
• A signed statement of educational purpose (using
language provided from Dept. of Ed)
V4: Identity/Purpose,
cont.
Must maintain an annotated copy of the
identification submitted by the applicant that
includes—
• The date documentation was received; and
• The name of the institutionally-authorized individual
that obtained the documentation
What if you can’t appear
in person?
If unable to appear in person, a student must provide the
institution—
• A copy of a valid government-issued photo
identification (driver’s license, non-driver’s license,
military identification, or passport); and
• An original notarized statement of educational
purpose signed by the applicant
V5: Documentation and
Data
• Data elements that must be answered:
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o
o
o
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Income and Tax
SNAP (if reported on FAFSA)
Child Support Paid (if reported on FAFSA)
HS Completion
Identity and Statement of Educational Purpose
# in Household
# in College
Favorite color
Airspeed velocity of an unladen swallow
Verification 2014-15
What’s Ahead
2014-2015 Verification
• Federal Register published June 13, 2013
• Dear Colleague Letter, GEN-13-16,
published June 13, 2013
What’s Changing?
• V2 Tracking Group
(SNAP only
verification)
o SNAP will still be verified in other
groups: V1, V4, V5 and…
What’s New?
• V6: Household
resources (untaxed
income)
What’s New? cont.
• Modifications to documentation
requirements
• Updated process for verification of identity
for V4 and V5 tracking groups
Verification
Tracking Groups
V6: Household Resources
• Applies to tax filers and non-filers
• Requires all elements from groups V1 as
well as other untaxed income
2014-2015 Verification –
Other Untaxed Income
• Payments to tax-deferred pension and savings
plans
• Child support received
• Housing, food and other living allowances paid
to members of the military, clergy and others
• Veterans noneducation benefits
• Other untaxed income (workers’ compensation,
untaxed portion of health savings accounts,
etc.)
• Money received or paid on the student’s behalf
2014-2015 Verification –
Other Untaxed Income
• Acceptable documentation includes:
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Signed statement by the student and parent, if
applicable, that lists the untaxed income amounts
Copies of the 2013 W-2s from all sources of
income
2014-2015 Verification –
Other Untaxed Income
If the FAA determines the income verified
does not appear to provide sufficient
financial support, the student or parent
must explain how the family was financially
supported during calendar year 2013.
• Income sources: AGI, income earned from
work, all untaxed income, and other
untaxed income not included on the
FAFSA.
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2014-2015 Verification –
Other Untaxed Income
• Common question?
You’re able to pay your bills and you have
negative income? Amazing!
Sources can include untaxed income not listed
on the FAFSA such as:
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Welfare benefits
Additional child tax credit
Earned income credit
Untaxed social security benefits
Supplemental security income (SSI)
2014-2015 Verification –
Other Untaxed Income
• Household Resources
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ED will not be specifying an income threshold
Leaving that to the institution to define
• How will you determine your “magic”
number?
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Use poverty guidelines?
What seems appropriate/necessary for a
certain family’s size and geographic location?
Modifications to Acceptable
Documentation for Other
Tracking Groups
• Nontax filers – if an institution questions the
claim of not filing, the institution may/must
require the student to submit a “Verification of
Nonfiling” from the IRS.
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The IRS will not be issuing until after June 15,
2014.
• FAA should know income thresholds for filing
Income Filing Thresholds
for 2012
Filing Status
Age at end of 2012
Must file if gross
income at least…
Single
Under 65
$9,750
65 or older
$11,200
Under 65
$12,500
65 or older
$13,950
Under 65 (both spouses)
$19,500
65 or older (one spouse)
$20,650
Head of Household
Married Filing Jointly
65 or older (both spouses) $21,800
Married Filing Separately
Any age
Qualifying Widow(er) with Under 65
Dependent Child
65 or older
$3,800
$15,700
$16,850
Modifications to Acceptable
Documentation
• High School Completion Status
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Previously collected HS Completion
documentation may be used as long as it
meets the criteria outlined in the Federal
Register.
High School Completion Abroad – may obtain
a copy of a “secondary school leaving
certificate” through the appropriate
government agency
Homeschool – secondary school completion
credential vs. transcript signed by student’s
parents
Modifications to Acceptable
Documentation
• Identity/Statement of Educational Purpose
Specific text for 2014-2015 provided in the
Federal Register
Documentation may be converted into an
electronic record (ie. your imaging system)
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• Household Size
Includes parents who are married or unmarried
and living together, irrespective of gender
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GEN-13-12
Impact of GEN-13-12
• Beginning with 2014-2015, dependent
students will be required to provide income
information from the student’s legal parents
(biological or adoptive) regardless of
marital status or gender, if those parents
live together.
• In the past, income has been excluded
when the parents were unmarried, even if
the parents were living together.
Impact of GEN-13-12
• Philosophy – the family should help pay the
educational expenses of their child.
• Help to ensure limited taxpayer resources
are directed to students with the most
need, regardless of the parents’ marital
status or gender, when those parents are
living together.
Impact of GEN-13-12
• New response to FAFSA question, “As of
today, what is the marital status of your
legal parents?”, will include “Unmarried and
both parents living together.”
• FAFSA on the Web will no longer have
mother/father reference, but will reference
Parent1/Parent2.
Additional Requirements
• Required to enter Identity Verification
Results into FAA Access (V4 and V5)
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Manually enter information into CPS one
student at a time until…
FAA Access to CPS online will accept a batch
file after April 2014.
Additional Requirements
• Schools must report a code in the Identity
Verification Results field on CPS, even if
the student never enrolls in your school.
• Response options on CPS will include:
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1) Verification completed in person, no issues found;
2) Verification completed remotely, no issues found;
3) Verification attempted, issues found with identity;
4) Verification attempted, issues found with high
school completion; or
o 5) No response from applicant or unable to locate.
Impacts to Consider
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Impact to your verification forms
Impact to your student systems
Impact to your website
Impact to your Policy and Procedure
Manual
Resources
• Federal Register, published June 13, 2013
• http://ifap.ed.gov/fregisters/attachments/FR
061313FAFSAInformationToBeVerifiedforthe2
0142015AwardYear
• Dear Colleague Letter (GEN-13-16),
published 6/13/13
• http://ifap.ed.gov/dpcletters/GEN1316.html
Resources
• 2013 NASFAA Conference, Department of
Education Verification session handout/audio
• www.nasfaa.org/conference/videos/edsessions.aspx
• NASFAA’s News July 30, 2013 – FAA Access
Reporting for Verification of Identity and HS
Diploma Required in 2014-15
• www.nasfaa.org/Main/orig/2013/FAA_Access_R
eporting_For_Verification_Of_Identity_And_High
_School_Diploma_Required_In_2014%e2%80%93
15.aspx
Resources
• 2013 Kansas State University presentation,
Oct. 3rd, 2013
https://www.kasfaa.org/docs/training/2013Fall/p
resentations/Verification.pptx
• Dept. of Ed presentation, PASFAA,
https://www.pasfaa.org/docs/training/2013/sprin
g/Verification.ppt