Federal Student Aid Regulation Changes: Verification Requirements

By Luke Hoey, FAAC® | August 3, 2021

As part of the wide range of regulatory changes, the Department of Education (ED) recently altered the verification process for some Free Application for Federal Student Aid (FAFSA) information. As of July 13, ED waived the requirement to verify students selected under the V1 Verification Tracking Group and will continue to do so for the remainder of the 2021-22 processing and verification cycle.

The waiver also applies to the V1 verification items of the V5 Verification Tracking Group. ED has focused its efforts on the elements of verification associated with identity and fraud. Therefore, the Identity/Statement of Educational Purpose (SEP) and High School Completion Status under V4 and V5 Verification Tracking Groups are still required.

Keep in mind ED has previously permitted the following flexibilities for “V4” and “V5” Verification Tracking Groups:

  • In-person submission and notary requirements for the Identity/SEP are rescinded through the end of the payment period that begins after the date on which the federally declared national emergency related to COVID-19. Acceptable documentation includes:
    • Verification documents submitted electronically (i.e., secure portal, email, etc.).
    • An electronic signature using a stylus or finger to sign the statement, or an image of the individual’s signature affixed to the statement in lieu of obtaining a wet signature.
  • Acceptable documentation of High School Completion Status can be the documentation the institution received for other purposes, such as documents received for admission purposes.

The waiver applies in all phases of the verification process, including if, for example:

  • Verification is required but has not been started.
  • Documents have been requested but verification has not been completed.
  • Documents have been collected but verification has not been completed.

However, the waiver does not apply if the institution discovers conflicting information regarding a student’s Federal Student Aid eligibility. Institutions must still review subsequent Institutional Student Information Records (ISIR) for the 2021-22 processing year and resolve any discrepancies before disbursing Title IV funds.

The waiver is part of an effort to provide a measure of relief to students and institutions amid the ongoing national emergency caused by the COVID-19 pandemic, as verification can present challenges and a hefty burden even in normal times. Nevertheless, it remains unknown if the waiver will stay in place for the 2022-23 cycle.

Reporting Requirements

The Central Processing System (CPS) will continue to select students for verification and institutions are still required to report a valid Verification Status Code for all students selected.

Institutions should report:

  • V: Verification was complete
  • S: Selected not verified (extended to all students selected under “V1” who are exempt under this guidance)

If you’re looking for information on verification and more about the changing regulations, McClintock & Associates’ staff is here to help you and your institution navigate the new regulatory environment and identify personalized solutions to any problems you face. Schedule a call today or sign up for our newsletter for up-to-date information on the industry.

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