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
2
IRS DRT
Student FAFSA CPS School
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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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• 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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V1
V2
V3
V4
V5
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2013 –14
V1
V2
V3
V4
V5
V1
V2
V3
V4
V5
V6
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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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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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• 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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• 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 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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• 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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• 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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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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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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• 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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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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• 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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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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• 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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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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• 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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