STATE UNIVERSITY COLLEGE OF AGRICULTURE AND TECHNOLOGY AT COBLESKILL FINANCIAL AID OFFICE POLICY AND PROCEDURE MANUAL VERIFICATION POLICY and PROCEDURES VERIFICATION POLICY OVERVIEW Verification is the process by which the Financial Aid Office (FAO) compares the information on the financial aid application with source documents provided by the student to verify the accuracy of the application information. The U.S. Department of Education (DoE) requires that a portion of the FAFSA filers at a college campus be verified each award year, ensuring that the information provided is accurate and complete. In addition to those students selected by DoE, FAO reserves the right to select additional students for the process of verification at its discretion. This discretionary selection may be generated randomly, or based on conflicting information or concerns that data may not be accurate or complete. SELECTION OF APPLICANTS 1 Applications are selected for verification by either the Central Processing System (CPS) or by the FAO. For those selected by CPS, the student’s application will be flagged in the system indicating verification is required. FAO will verify 100% of all applications selected by CPS. A selected applicant may be exempt from the verification requirements if unusual circumstances meet the exclusions allowed by the Department set forth in the Application and Verification Guide in the Federal Student Aid Handbook. Students selected for verification will be packaged for all federal and state aid they are eligible for when the FAFSA is official. Verification will hold up memos, authorizations or payments of all federal funds, also students selected for verification will not be able to apply for workstudy positions until verification is complete.2 In addition to the applications selected by CPS, FAO will also select for review those applications it deems to contain discrepancies, requires additional information from the student, or where a Professional Judgment is requested. Furthermore, FAO will verify information under the following circumstances: 1. Student claims to be independent for any reason other than over 24 years of age or married 2. Student claims they are on active duty or veteran of the armed forces (will be evaluated through the C-flag process) 3. Student receives a C-flag from the Federal processor 4. Student or family provides any documentation that may be related to the financial aid process All applications are identified programmatically with the requirements being placed on the requirement screen (RRAAREQ) by using batch processes (RORPOST – Form and RORBPST – Process) 1. 2. (668.54(a)) (668.60) Page 1 of 30 Update 10/29/14 VERIFICATION POLICY and PROCEDURES VERIFICATION EXCLUSIONS 3 The following are circumstances where we may exclude the student from verification. Other than a case where the student has passed away we will follow up on verification if we receive any conflicting information. 1. 2. 3. 4. 5. 6. Death of a student Not an aid recipient The applicant is eligible to receive only unsubsidized student financial assistance Applicant verified at another school Post enrollment Unless you have reason to believe it is inaccurate, you don’t have to verify the reported FAFSA information of the parents of a dependent student if any of the following apply: a. Both of the parents are mentally incapacitated. b. They are residing in a country other than the United States and can’t be contacted by normal means. c. They can’t be located because the student does not have and cannot get their contact information. 7. Unless you have reason to believe it is inaccurate, you don’t have to verify the reported FAFSA information of the spouse of an independent student if any of the following apply: a. The spouse has died. b. He is mentally incapacitated. c. He is residing in a country other than the United States and can’t be contacted by normal means. d. He can’t be located because the student does not have and cannot get his contact information. METHOD OF NOTIFYING STUDENTS 4 FAO submits requirement letters to selected students every 42 days informing them that they were selected for verification (See Attachment 1). This notification includes a listing of what information is being requested in order to complete the verification process, the time frame in which the student has to submit the requested information, the consequences of not submitting the information timely, and the method and timeframe when the student will be notified of any adjustments made to their FAFSA and related Financial Aid package. In addition to the notification letter, regular follow-up emails are sent every 14 days to remind the student of their obligation to submit the requested information (See Attachment 2). After all information is verified, the student will receive a letter indicating the changes made to their Financial Aid package (if any), as well as a summary informing them of the current and revised FAFSA data and Financial Aid package amounts. The Financial Aid office at SUNY Cobleskill, notifies students of any change of award(s) by a form letter (See Attachment 3) on which we give the line number from the FAFSA, their answer, and the correct answer based on the documentation received. On the form letter it states what their present federal aid is and what the revised aid is going to be. If the student receives a C flag from the federal processor, banner will flag what aspect is being questioned and the office will then collect the appropriate information to resolve the C flag. This also automatically creates a requirement within banner which will stop all processing or authorization/disbursement of federal aid until it is resolved. 3 (668.54 (b), 2014 - 2015 FSA Handbook, pp. AVG - 80 to AVG - 81) 4 (668.53(a)(3),(4)) Page 2 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES REQUIRED DOCUMENTATION 5 V1 – Standard Verification Group V2 – Reserved for future use by the Department V3 – Child Support Paid Verification Group V4 – Custom Verification Group V5 – Aggregate Verification Group V6 – Household Resource Group UEH’2’ – Review if student received Pell grant at SUNY Cobleskill in 2010-2011, 2011-2012, 2012-2013 Aid Years UEH’3’ – Review all transfer transcripts REQUIRED DOCUMENTATION V1 – Standard Verification Group A verification worksheet (Attachment 4) would need to be completed along with any financial documentation (IRS Data Retrieval Tool, Tax Transcripts or IRS Form 4868 for late filers and W-2 – See Attachment 12 for acceptable documentation) Per Federal guidelines, the following information must be checked in the verification process for CPS-selected applicants: 1. Household Size 2. Number Enrolled in College 3. Adjusted Gross Income 4. U.S. Income Taxes Paid 5. Receipt of SNAP benefits 6. Child Support Paid 7. Income Earned from Work – Non filers 8. Education Credits 9. Untaxed IRA Distributions 10. Untaxed Pensions 11. IRA Deductions 12. Tax Exempt Interest V2 – Reserved for future use by the Department V3 – Child Support Paid Verification Group Students must verify child support paid by them or their spouse, their parents, or both. The student and the parent of a dependent student will fill out and sign a Child Support Paid worksheet (Attachment 6). Additional documentation showing that child support has been paid may be required if there is any question if student or family actually paid child support or if the amount seems questionable. This is not required for verification 5 (668.53 (a),(b), 668.57, 2014-2015 FSA Handbook, pp. AVG - 81 to AVG - 89) Page 3 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES V4 – Custom Verification Group Students must verify high school completion status and identity/statement of educational purpose in addition to receipt of SNAP benefits and payment of child support. The student and the parent of a dependent student will fill out and sign a Child Support Paid worksheet (Attachment 6), SNAP Worksheet (Attachment 5), an Identity worksheet (Attachment 7) and must provide documentation from the High School Completion worksheet (Attachment 8). V5 – Aggregate Verification Group Students must verify high school completion status and identity/statement of educational purpose in addition to the items in the Standard Verification Group. See above descriptions for documentation needed V6 – Household Resource Group Students must verify the items in the Standard Verification Group as well as certain other untaxed income on the 2014–2015 FAFSA: payments to tax-deferred pension and retirement savings plans (Questions 45a and 94a) child support received (Questions 45c and 94c) housing, food, and other living allowances paid to members of the military, clergy, and others (Questions 45g and 94g) veterans’ non-education benefits (Questions 45h and 94h) other untaxed income (Questions 45i and 94i) money received or paid on the applicant’s behalf (Question 45j) resources or benefits not appearing on the FAFSA, such as in-kind support from a relative or a government agency. UEH’2’ – Review if student received Pell grant at SUNY Cobleskill in 2010-2011, 2011-2012, 2012-2013 Aid Year The institution must review the student’s enrollment and financial aid records to determine if, during the three award year review period (Award Years 2010-2011, 2011-2012, and 2012-2013), the student received a Pell Grant at the institution that is performing the review. If so, no additional action is required unless the institution has reason to believe that the student is one who remains enrolled just long enough to collect student aid funds. In this case, the institution must follow the guidance that is provided below for a UEH Flag of ‘3’. If not, the institution must follow the guidance provided below for a UEH Flag of ‘3.’ UEH’3’ – Review all transfer transcripts The institution must review the student’s academic records to determine if the student received academic credit at the institutions the student attended during the three award year period (Award Years 2010-2011, 20112012, and 2012-2013). Using information from the National Student Loan Data System (NSLDS), the institution must identify the institutions where the student received Pell Grant funding over the past three award years (2010-2011, 2011-2012, and 2012-2013). Based upon academic transcripts it may already possess, or by asking the student to provide academic transcripts or grade reports, the institution must determine, for each of the previously attended institutions, whether academic credit was earned during the award year in which the student received Pell Grant funds. Academic credit is considered to have been earned if the academic records show that the student completed any credit hours or clock hours. Academic Credit Earned: If the institution determines that the student earned any academic credit at each of the previously attended institutions during the relevant award years, no further action is Page 4 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES required unless the institution has other reasons to believe that the student is one who enrolls just to receive the credit balance. In such instances, the institution must require the student to provide additional information as discussed below under “Academic Credit Not Earned.” If it is determined that academic credit was not earned at one or more of the previously attended institutions, the institution must follow the “Academic Credit Not Earned” guidance below. Academic Credit Not Earned: If the student did not earn academic credit at a previously attended institution and, if applicable, at the institution performing the review, the institution must obtain documentation from the student explaining why the student failed to earn academic credit. The institution must determine whether the documentation supports (1) the reasons given by the student for the student’s failure to earn academic credit; and (2) that the student did not enroll only to receive credit balance funds. In some cases, the student may present personal reasons to explain the failure to earn academic credit. These reasons could include illness, a family emergency, a change in where the student is living, and military obligations. The institution should, to the extent possible, obtain third party documentation to support the student’s claim. In other instances, the student may present academic reasons to explain the failure to earn academic credit. For example, the student might explain that the first enrollment was at an institution that presented unexpected academic challenges, or that the student determined, before completing any academic credit, that the academic program did not meet the student’s needs. Again, the institution should, to the extent possible, obtain third party documentation to support the student’s claim. Much like the exercise of professional judgment, as provided by section 479A of the Higher Education Act (HEA), the financial aid administrator determines whether the circumstances of the failure of the student to receive academic credit, as evidenced by the student’s academic records and other documentation, support the continuation of title IV, HEA program assistance eligibility. Also, like professional judgment, these institutional determinations are final and not appealable to the Department, and the reasons for the decision must be documented and maintained for possible review. C-FLAGs – Review of Discrepant Information From the Federal Processor Social Security Administration (SSA) – If an error comes from the SSA the FAO will require the student or parent to fix the FAFSA by checking to make sure that SSN, Last Name and Date of Birth all match the SSA. We will not Package, Authorize, Memo or Pay any federal funds until this has been fixed. Department Of Homeland Security (DHS) – There are 2 situations where we will need to collect documentation to show eligibility to receive federal aid. 1) If the student is an Eligible Non-Citizen then the FAO will either have the student put in their Alien Registration Number (ARN), or we will collect the Green Card and put the ARN, on the FAFSA once a corrected FAFSA has been retrieved it should show that the student is eligible to receive aid. If not we would then have to send a copy of the ARN to DHS using form G-845, Document Verification Request. We will not package aid until this C-Flag has been verified one way or the other. 2) For all other citizenship issues we will need to see the original document that shows U.S. citizenship. We will accept a faxed copy to start packaging aid but will not Authorize, Memo or Pay any federal funds until we have observed and copied the original document. For examples of what is valid documentation see FSA Handbook Volume 1 – Student Eligibility pages 1-21 to 1-45 Page 5 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Selective Service System – No federal financial aid will be Packaged, Authorized, Memoed, or Paid until the student has registered for the Selective Service. This can be done online at www.sss.gov or at the local post office. The online registration is immediate and we can confirm registration immediately. The FAO will go online to www.sss.gov to verify if the student has registered. If they have we will print copy of proof of registration and will remove the C-Flag. If the student is not a male student age 18-25 and cannot register for the Selective Service we will evaluate that student based on the information in the FSA Handbook Volume 1 – Student Eligibility pages 1-67 to 1-71 National Student Loan Data System (NSLDS) - There are 4 main issues we that we deal with where a student gets a C-Flag from the NSLDS. 1) Defaulted Loans – If a student has received a c-flag because of defaulted loans a copy of the NSLDS screen will be printed and the Status codes will be evaluated and it will be determined if the student can continue to receive aid based on the code. The codes and their descriptions can be found in the see FSA Handbook Volume 1 – Student Eligibility pages 1-59 to 1-60. No aid will be Packaged, Authorized, Memoed, or Paid until it has been determined if the student is eligible. 2) Over Payment – If a student has received a c-flag because of over payment of loans or grants a copy of the NSLDS screen will be printed. If it is determined that there was an overpayment of federal aid we will return the amount of aid that has been over paid and remove the C-Flag. If the overpayment did not come from our school we will not Package, Authorize, Memo, or Pay until any federal funds until the aver payment has been corrected. 3) Exceeds Maximum Eligibility - If a student has received a c-flag because loans exceed maximum eligibility, a copy of the NSLDS screen will be printed. a. We will evaluate whether a PLUS loan denial was in place and a student received additional unsubsidized loan money. If this is the case we will override the NSLDS C-Flag and give the student whatever loans they are eligible for. b. A student receives more than the $23,000 in subsidized loan. We will reduce the subsidized loan and put any loan the student is eligible for on the unsubsidized. 4) PELL LEU is close to or over the 600% eligibility. A copy of the NSLDS screen will be printed and the grant section will be evaluated to determine student eligibility. Once that has been reviewed the CFlag will be removed and Banner will make the necessary calculations to ensure the proper amount of PELL is created and disbursed. 5) Any other NSLDS C-Flags they may come up can be reviewed in the FSA Handbook Volume 1 – Student Eligibility pages 1-51 to 1-60 All Other C-Flags – All other C-Flags will be evaluated as they come in. We will utilize all FSA Handbook Volumes to determine student eligibility. Furthermore, FAO also has the authority to request any other documentation it deems reasonably necessary to verify other application items. FAO makes the determination as to what constitutes acceptable documentation for this process. Any documentation received by the student throughout the verification process, as well as any verification checklists or worksheets, will be retained in the student’s file. Page 6 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES SPECIAL TAX SITUATIONS The Financial Aid office can only accept the Federal Tax Return Transcript or the IRS Data Retrieval as documentation for tax return information. For the 2014-2015 aid year there is no substitutions for late filers of the 2013 tax return. If a person has filed for an extension the FAO will accept the IRS Form 4868, a copy of all their W-2 forms or, if they are self-employed, a signed statement with the amount of their AGI and their U.S. income taxes paid. We will not require them to send a copy of their IRS Tax Return Transcript once it is completed. For victims of identity theft who cannot get a return transcript or use the DRT must call the IRS’s Identity Protection Specialized Unit (IPSU) toll-free number at 800-908-4490. After the IPSU authenticates the tax filer’s identity, she can ask the IRS to mail her an alternate paper tax return transcript known as the TRDBV (Transcript DataBase View) that will look different than a regular transcript but that is official and can be used for verification. Other examples of special situations can be found in the Application and Verification Guide on pages AVG-83 to AVG-84. REPORTING RESULTS FOR VERIFICATION TRACKING GROUPS V4 AND V5 Beginning with 2014–2015, you must report your results for any student for whom you receive an ISIR with tracking flag V4 or V5—as selected by the CPS, not your school—and request verification documentation. You report this information on the FAA Access to CPS Online website: select the Identity Verification Results option from the main menu, enter your school identifiers, the year, and the student identifiers. You will then enter one of the following numeric codes that most applies to the student: 1 2 3 4 5 verification completed in person, no issues found verification completed using notary, no issues found verification attempted, issues found with identity verification attempted, issues found with HS completion no response from applicant or unable to locate If issues were found with both identity and high school completion status, use code 3. See the 11/13/13 electronic announcement for more information. Because the FAA Access website does not store a list of these verification results for you to retrieve, we recommend you print and keep the confirmation page for your records. If there is a change in a result you have already submitted, you can submit the new code using the above process. Instead of using this individual method, you can submit verification results by uploading a flat file with the data for up to 2,000 students. This option became available in April, 2014; see the electronic announcement from 4/4/14. DEADLINES FOR SUBMISSION 6 Students are required to submit all requested information to FAO no later than 90 days after the last day of enrollment, regardless of their basis of selection (CPS or FAO). If the student fails to submit all required documentation by this deadline, the Campus will not disburse any Federal funds to the student’s account (this includes Pell, FSEOG, Perkins Loans, and Federal Direct Student Loans), and a Federal Direct student loan application cannot be originated. Additionally, students participating in a Federal Work Study (FWS) program will no longer be allowed to continue with the FWS job. If the student has already received Pell, ACG, National SMART, FSEOG or Perkins funds prior to being selected for verification, these monies must be returned is the result of the verification reduces their eligibility. Furthermore, if these funds were part of an interim disbursement, the Campus must return these monies to the programs. 6 (668.53(a)(1), (b)(2)) Page 7 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES COMPLETING THE PROCESS Once FAO receives all required documentation from the student it can complete the verification process. If the information is correct and no outstanding issues of conflicting information exists, the Campus will award and disburse the Federal Aid for which the student is eligible. If any errors or inconsistencies are discovered, the student is instructed on how to make the necessary corrections to their information or how the FAO corrected the information. CORRECTION PROCEDURES Often the verification process results in incorrect data and the student must submit corrections in order to complete the verification process and receive Federal Student Aid. However, even if the change does not result in a corrected EFC or award amount (typically non-dollar items), students still must submit corrections relating to household size, dependency status, number in college, social security number, or other application questions. The student can submit the corrected information using FAFSA on the Web, through FAA Access to CPS Online, or the Student Aid Report (SAR). FAO will assist any student needing to make corrections to their application information, as necessary. REFERRING OVERPAYMENTS When the verification process results in a change in Financial Aid package, an overpayment may occur. If an overpayment occurs the school will send any funds back to the federal or state governments. In doing this the student’s account may show a balance and the student is responsible for covering the balance at the school. The school chooses to send all monies back and bill the student, it does not refer students in over payment. Should fraud or abuse be detected or suspected, the Director of Financial Aid will consult with legal counsel prior to referring it for investigation to the Office of the Inspector General of the Department of Education. All credible information indicating that an applicant for Title IV may have engaged in fraud or other criminal conduct will be provided. In addition, we will refer any third-party servicer who may have engaged in fraud, break of fiduciary responsibility or other illegal conduct involving the FSA programs. OIG Address and Phone Numbers Office of Inspector General US Department of Education 400 Maryland Avenue, SW Washington, DC 20202-1510 1-800-MIS-USED Page 8 of 30 Updated 10/29/2014 STATE UNIVERSITY COLLEGE OF AGRICULTURE AND TECHNOLOGY AT COBLESKILL FINANCIAL AID OFFICE POLICY AND PROCEDURE MANUAL VERIFICATION POLICY and PROCEDURES VERIFICATION PROCEDURE How the Student is Initially Selected Student Financial Aid information is verified if any of the following incidents happens: a. Student is selected by the Federal government during the filing of the FAFSA b. Student has claimed to be independent for any reason other than over 24 years of age or married. Also, Student claims they are on active duty or are a veteran of the armed forces will be evaluated through the c-flag process. c. Student has received a c-flag from the Federal processor. d. If in the course of reviewing the financial aid information any discrepancy is determined – Conflicting information would be any information that is not consistent between the verification worksheet, w-2s, FAFSA, college application and any other documentation requested by the school or provided by the student/family. 7 e. Student or family provides any documentation that may be related to the financial aid process Procedures for Each Scenario 8, 9 1) When a student is selected for verification by the Federal government the following steps will be followed: a. The verification process begins once the FAFSA has been downloaded into Banner and the student is accepted to the college. b. Requirements are created on the requirement screen (RRAAREQ) based on the Tracking Group the student is assigned. i. DEPVER – Dependent Student Selected for Verification ii. DEPNVR – Dependent Student Not Selected for Verification iii. INDVER – Independent Student Selected for Verification iv. INDNVR – Independent Student Not Selected for Verification c. Once the Student has been assigned a Tracking Group the requirements are then updated on their account with an Outstanding Status (E) until satisfied. The types of requirements will be posted programmatically using the RORPOST Form and t he RORBPST Process in Banner. The requirements to be posted will vary based on the verification group created by the Federal Processor: i. DEPVER 1. AFSAxx – Is there and Official FAFSA for the Aid Year a. Satisfied programmatically based on Official STATUS from RNARSxx 2. V1 – Standard Verification Group a. xxPINC – Parent tax return for the previous year 7 (668.54(a)(2), 668.16(f), 2014-2015 FSA Handbook, pp. AVG-125 to AVG-126) 8 (668.57) – Acceptable Documentation 9 (668.56), (668.54(a)(3)) – Data Elements to be verified Page 9 of 30 Update 10/29/14 VERIFICATION POLICY and PROCEDURES 3. 4. 5. 6. 7. b. xxPW-2 – Parent W-2 for the previous year c. xxSINC – Student tax return for the previous year d. xxSW-2 – Requested if student has wages but does not have to file tax return e. VERIFY – A verification worksheet filled out and signed by student and parent f. CHLDPA – Child Support Paid g. CHLDRE – Child Support Received h. SNAP – Receipt of SNAP benefits V2 – Reserved for future use by the Department V3 – Child Support Paid Verification Group a. CHLDPA – Child Support Paid V4 – Custom Verification Group a. STAPUR – Statement of Purpose b. HIGHSC – Verification of Completion of High School c. SNAP – Receipt of SNAP benefits d. CHLDPA – Child Support Paid V5 – Aggregate Verification Group a. xxPINC – Parent tax return for the previous year b. xxPW-2 – Parent W-2 for the previous year c. xxSINC – Student tax return for the previous year d. xxSW-2 – Requested if student has wages but does not have to file tax return e. VERIFY – A verification worksheet filled out and signed by student and parent f. CHLDPA – Child Support Paid g. CHLDRE – Child Support Received h. SNAP – Receipt of SNAP benefits i. STAPUR – Statement of Purpose j. HIGHSC – Verification of Completion of High School V6 – Household Resource Group a. xxPINC – Parent tax return for the previous year b. xxPW-2 – Parent W-2 for the previous year c. xxSINC – Student tax return for the previous year d. xxSW-2 – Requested if student has wages but does not have to file tax return e. VERIFY – A verification worksheet filled out and signed by student and parent f. LOWINC – Income Verification Worksheet g. CHLDPA – Child Support Paid h. CHLDRE – Child Support Received i. SNAP – Receipt of SNAP benefits ii. INDVER 1. AFSAxx – Is there and Official FAFSA for the Aid Year a. Satisfied programmatically based on Official STATUS from RNARSxx 2. V1 – Standard Verification Group a. xxSINC – Student tax return for the previous year b. xxSW-2 – Requested if student has wages but does not have to file tax return c. VERIFY – A verification worksheet filled out and signed by student and parent d. CHLDPA – Child Support Paid Page 10 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES e. CHLDRE – Child Support Received f. SNAP – Receipt of SNAP benefits 3. V2 – SNAP Verification Group a. SNAP – Receipt of SNAP benefits 4. V3 – Child Support Paid Verification Group a. CHLDPA – Child Support Paid 5. V4 – Custom Verification Group a. STAPUR – Statement of Purpose b. HIGHSC – Verification of Completion of High School c. SNAP – Receipt of SNAP benefits d. CHLDPA – Child Support Paid 6. V5 – Aggregate Verification Group a. xxSINC – Student tax return for the previous year b. xxSW-2 – Requested if student has wages but does not have to file tax return c. VERIFY – A verification worksheet filled out and signed by student and parent d. CHLDPA – Child Support Paid e. CHLDRE – Child Support Received f. SNAP – Receipt of SNAP benefits g. STAPUR – Statement of Purpose h. HIGHSC – Verification of Completion of High School 7. V6 – Household Resource Group a. xxPINC – Parent tax return for the previous year b. xxPW-2 – Parent W-2 for the previous year c. xxSINC – Student tax return for the previous year d. xxSW-2 – Requested if student has wages but does not have to file tax return e. VERIFY – A verification worksheet filled out and signed by student and parent f. LOWINC – Income Verification Worksheet g. CHLDPA – Child Support Paid h. CHLDRE – Child Support Received i. SNAP – Receipt of SNAP benefits iii. Unusual Enrollment History Flags 1. UEH’2’ a. TRAN1 – We check to see if student receive a PELL grant at our institution 2. UEH’3’ a. TRAN2 – 2013-2014 Unusual History Form iv. Additional Information that could be requested 1. ASSET – Asset Verification Worksheet 2. LOWINC – Low Income verification Worksheet 3. Others … See RTVTREQ d. Upon receipt of verification documentation the clerical staff will update the corresponding tracking requirements. i. If the information is complete the requirement will be satisfied (S) Page 11 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES ii. If the information is incomplete then the requirement will be marked as incomplete (E) and a follow up tracking form will be sent out with the information required to make the requirement complete. e. Once the file is complete it will be handed off to a counselor to be verified. i. If during verification any of the information is deemed insufficient the requirement will be marked as incomplete and a tracking form will be sent with the information required to complete verification. ii. If additional information is necessary the additional requirements will be added to the requirement form (RRAAREQ) and a tracking letter explaining what is needed will be sent. f. Once the counselor has all the required documentation, they will proceed through the verification checklist to complete the process. g. All corrections will be made on the FAFSA Correction form in Banner (RNAVR13) h. Once the verification is complete the FAFSA record will be locked. There will be a programmatic process to unlock the record to download the correction file and to lock the record again once download is complete. i. Detailed Checklist Procedure (Attachment 10) i. Information collected and input on Requirement screen by clerical staff ii. Clerical staff follow up on incomplete information with tracking letter, if necessary. iii. Complete information presented to counselor for review. iv. RPAAWRD 1. Check EFC, Packaging, Awarding v. RRAAREQ 1. Check to make sure that all requirements are satisfied 2. When requesting any additional information add the FLLWUP requirement to show a follow up was sent vi. RNARSxx 1. Make sure FAFSA is official and there are no C-Flags 2. If FAFSA is unofficial or there is a C-Flag Verification stops and a tracking letter is sent to either assist the student in getting FAFSA official or to request additional information to satisfy C-Flag 3. To find what C-Flag is use the Miscellaneous Results Form (RNIMSxx) on the School/Housing Info/Comments Tab to find issue to follow up on. vii. RNIMSxx 1. The last tab on this form allows the viewer to see what the exact error from RNARSxx represents. viii. RNANA12 1. To find any discrepant information – Address, parent marital status, tax filing status, etc… ix. RNAVRxx 1. This screen is used to make changes to the FAFSA information. A tax return transcript to tax return comparison can be found in Attachment 10. 2. Fill out a FAFSA Change Form that shows all changes made to the FAFSA. One copy is sent to the student, and another copy is retained in the student’s file. 3. Once Application has been updated run Calculate Need from Option Menu. Page 12 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES x. ROAPELL 1. Update the verification field to indicate the process is complete. 2. Ensure that the new EFC is reflected in the PELL EFC block. xi. RHACOMM 1. Notate any comments pertaining to the verification process. xii. RRAAREQ 1. Final review is conducted to ensure that all requirements are correctly entered and have the correct status codes. xiii. RPAAWRD – Enter new Federal award amounts on Correction Worksheet 2) Student has claimed to be independent for any reason other than over 24 years of age, married, veteran, active duty: a. Banner has been programmatically set up to create requirements for any student that is claiming independence for any reason other than those stated above. Below are the codes assigned by Banner (depending on the student’s situation), and the corresponding information required to verify the student’s independence: i. Graduate or Professional: 1. GRAD – Asks if student is actually working toward a Graduate degree 2. If student is actually working on or has a graduate degree then aid will be adjusted accordingly. ii. Child or Other Dependent the student is providing over 50% of the Support: 1. xxSINC – Student tax return for the previous year 2. xxSW-2 – Student W-2 for previous year 3. VERIFY – A verification worksheet filled out and signed by student and parent 4. INDEP – Satisfied once student is deemed actually independent 5. INDREV – Independent Review Form iii. Orphan, Ward of Court, Foster Care: 1. WRD CT – Asks for actual documentation showing one of the options above 2. INDEP – Satisfied once student is deemed actually independent 3. INDREV – Independent Review Form iv. Legal Guardianship: 1. GUARD – Request actual Legal Guardianship documentation 2. INDEP – Marked as satisfied once student is deemed actually independent 3. INDREV – Independent Review Form v. Unaccompanied Youth by school or HUD, At Risk of Homelessness: 1. HOMLESS – Requests information from the appropriate source to show student was actually considered at risk of homelessness 2. INDEP – Satisfied once student is deemed actually independent 3. INDREV – Independent Review Form b. Should any of these “independent” students also be selected for verification from the Federal government, the appropriate verification requirements will be included on the requirement form as well. Any student selected for verification or who is claiming to be independent on the basis he/she provides more than 50% of the support for a child or other dependent will go through the verification process outlined in Part 1 of this procedure. If it is determined that the student was not truly Page 13 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES independent, the parental tax information would be added to the student’s requirement information as well. c. Detailed Checklist Procedure i. Information is collected and input on the Requirement screen in Banner by clerical staff ii. Incomplete information is followed up on by clerical staff with a tracking letter, as needed. iii. Complete information is assigned to a counselor for review. iv. File is reviewed by a counselor and a determination is made with input from Director, if necessary. v. If information shows the student is truly independent, the INDEP requirement will be updated as satisfied in Banner. vi. If student is not deemed independent based upon the information received, we send a letter to the student notifying them. vii. If we lack sufficient information to prove independence a letter requesting additional information is sent until resolved. 3) Student has received a C-Flag from the Federal Processor: a. Banner is programmed to place a C-Flag on the requirement form for follow up. This C-Flag will be unsatisfied every time a new FAFSA is downloaded so that we continue to verify the student meets the requirements and no new issues have occurred. b. A program is run on a weekly basis after the FAFSAs have been processed to identify students that have an unsatisfied C-Flag requirement. c. We will use RNIMSxx to determine the corresponding C-Flag comment so we can request the correct documentation. d. Once we determine the C-Flag, a tracking letter is sent to the student requesting the necessary documentation to correct the situation or providing the required actions for the student to get the information corrected. e. A code describing the C-flag is also added to the requirement form to give further clarification, as follows: i. NSLDS – For any issues dealing with NSLDS. Overpayment, Default, etc… ii. SELSV – For those students that have not registered for the selective service iii. CITIZE – For those students with citizenship issues iv. DD-214 – For those students that claim to be veterans vi. ACTIVE – For those students that claim to be on active duty 4) If a discrepancy is identified during the course of reviewing the financial aid information: a. If during the course of reviewing a student’s file/FAFSA/Awards there seems to be a discrepancy in the data provided, a tracking letter will be sent to the student to verify the information in question. b. The Financial Aid Office will collect all supporting documentation to determine the response to the conflicting information. i. Continue to request documentation until a final decision can be made. c. Corrections to the FAFSA will be made by the Financial Aid Office to correct any discrepancies. Page 14 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES 5) Campus receives financial aid related documentation provided by a student or parent: a. Any documentation provided concerning the student’s FAFSA information will be reviewed and corrections will be made, as appropriate. b. If the documentation results in a discrepancy with the information on file, a tracking letter will be sent requesting additional information. i. The Financial Aid Office will collect all supporting documentation to determine the most accurate response to the conflicting information. 1. Continue to request documentation until a final decision can be made. ii. Corrections to the FAFSA will be made by the Financial Aid Office to correct any discrepancies. 6) Students Selected in Verification statuses V4 or V5 a. Institutions must report the verification results of identity and high school completion status for applicants whose 2014-2015 ISIR had a Verification Tracking Group of V4 or V5. b. See grid below: Verification Results Value Of Value = 1 Value = 2 Report When Description Verification of both identity and high school completion status were satisfactorily completed by the applicant in person, and no issues were found. The applicant appeared in person, presented acceptable governmentissued photo identification, signed the Statement of Educational Purpose, and presented (not necessarily in person) acceptable documentation of the high school completion status as indicated on the ISIR. Verification of both identity and high school completion status were satisfactorily completed remotely by use of a notary, and no issues were found. The applicant submitted an original notarized Statement of Educational Purpose, a copy of his/her government-issued photo identification, and acceptable documentation of high school completion status as indicated on the ISIR. Page 15 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Verification was attempted, and no issues were found with high school completion, but issues were found with identity. Value = 3 The applicant presented (not necessarily in person) acceptable documentation of high school completion status as indicated on the ISIR. No documentation of identity was submitted or the documentation that was presented was not acceptable and no signed or notarized Statement of Educational Purpose was received. NOTE: If issues were found with both identity and high school completion status, use Results Value 3. Value = 4 Value = 5 Verification was attempted, and no issues were found with identity, but issues were found with high school completion status. The applicant presented (either in person or with an original notarized statement) a signed Statement of Educational Purpose with an acceptable government-issued photo identification. Either no documentation of high school completion status was presented or the documentation that was presented was not acceptable. The applicant did not respond to the request for documentation or the applicant could not be located. Verification of neither identity nor high school completion status was completed and no signed or notarized Statement of Educational Purpose was received because the applicant did not respond to the request for documentation or the applicant could not be located. Any information provided to or gathered by the Campus during this process that is used in determining financial aid will be filed in the student’s folder. Students that fail to provide the necessary documentation in the time frame required will not be eligible to receive federal aid. Page 16 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 1 Page 17 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 2 Page 18 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 3 Page 19 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 4 Page 20 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Page 21 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 5 Page 22 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 6 Page 23 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 7 Page 24 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 8 Page 25 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 9 Page 26 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 10 Verification Checklist Receiving Information _____ 1) Signed verification worksheet (Married students spouse’s signature is optional) _____ 2) Parents’ Signed Tax return/W2s _____ 3) Student’s signed tax return (Married students spouse’s signature is optional) 1) Independent student only one signature is mandatory. 2) Dependent student one parent one student signature required. _____ 4) RRAAREQ – Make sure all requirements are established and are satisfied. Requirements xxPINC+ – Parent income documentation – For dependent students xxPW-2+ – Parent W-2 – For dependent students xxSINC+ – Student income taxes VERIFY – Verification Worksheet FLLWUP – If we need additional Information please put this xxSW-2 – Student W-2 – For independent students or student that have wages but were not required to file Status Codes E – Unsatisfied Requirement S – Satisfied Requirement Verifying Information _____1) RPAAWRD – Make sure that if financial aid awards are done that they are correct prior to verification. _____2) RRAAREQ – Make sure all requirements are established and are satisfied. _____3) RNARSxx** – We need to make sure the FAFSA is official and that there are no c-flags. These must be corrected before we start the verification process _____4) RNIMSxx** – Form used to find out what a C-Flag requirement should be _____5) RNANAxx** – Review all FAFSA for accuracy base on Verification Form. _____ Review Verification Worksheet Make sure no conflicting information from FAFSA, Verification Worksheet and tax returns. o Independent Status o Address information o Etc… Household size Page 27 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Number in College Taxes filed: parents/student? Other income: parent/student? *Child support *Workman’s Compensation *Untaxed Pensions, etc. _____ Verify FAFSA using verification worksheet, tax return and W2s Adjusted gross income (AGI) U.S. taxes paid Certain types of untaxed income/benefits: o Child support o IRA/Keogh deductions o Interest on tax-free bonds All other untaxed income included on U.S. tax return, excluding information on the schedules If no income reported follow up using Low Income Worksheet. _____6) RNAVRxx** – From used to update any changes to RNANAxx _____7) RNAOVxx** - Used to Lock the ISIR once verification is complete _____8) ROAPELL – Update the verification box _____9) RHACOMM – Please write a comment on any decision made concerning verification process. _____10) RRAAREQ – If additional information is requested create a follow up requirement. Requirement FLLWUP – If additional information is requested. _____11) Fill out FAFSA Change Form and send one copy to student and one copy goes in folder. _____12) RNANAxx** – If changes were made go to top of form – Options – Calculate Need. _____13) RPAAWRD – Put new financial aid information on FAFSA Change Form. There is a Quick Flow Process set up if you want to use it. This will take you through the checklist in BANNER. Type in VERIFYxx** at the main screen to start the process. + Where xx = the last two digits of previous year. (example – the parent tax returns for the 2010-2011 academic year would be 09PINC) ** Where xx = the last two digits of the aid year Page 28 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 11 Page 29 of 30 Updated 10/29/2014 VERIFICATION POLICY and PROCEDURES Attachment 12 Found AVG – 81 of 2013-2014 Application and Verification Handbook Page 30 of 30 Updated 10/29/2014