Verification

Report
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
Verification
IRS DRT
Student
FAFSA
CPS
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School
3
Verification
Foreign
Tax
Return
Identity
Theft
Amended
Return
Tax
Extension
Tax
Transcript
SNAP
Child
Support
Paid
V1
V5
V3
Number in
College
Household
Size
IRS DRT
V2
V6
Student
FAFSA
Statement of
Educational
Purpose
Name
Change
V4
School
CPS
High
School
Completion
Home
School
Completion
GED
Notary
Public
Doogie
Howser?
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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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Verification Tracking Groups and Codes
2013–14
V1
Standard
V2
SNAP
V3
Child Support
V4
Custom
V5
Aggregate
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2014–15 Tracking Groups and Codes
2013–14
V1
V2
2014–15
Standard
SNAP FSA Use Only
V1
V2
V3
Child Support
V3
V4
Custom
V4
V5
Aggregate
V5
Household Resources
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V6
8
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
V1 V3 V4 V5 V6
Tax Filers
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 7thsemester 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)
Secondary School
Completion Credential
– Lists secondary school courses
completed
– Documents successful
completion of a secondary
school education
– Issued for home school
– Recognized under state law
– Signed by parent or guardian
V1 V3 V4 V5 V6
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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:
[email protected]
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