Verification

1. Verification Where We are and What’s Ahead

2. Agenda • General Purpose and Policies • 2013-2014: Where we are • 2014-2015: What’s ahead • Impact of GEN-13-12 • Resources

3. 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

4. General Policies • Required of all applicants selected by the Department of Education who are eligible or receiving subsidized Title IV aid: • Pell Grants • Subsidized Loans • FSEOG • FWS • Perkins

5. General Policies, cont. • Not required if applicant only receiving: • Unsubsidized loans • PLUS loans • TEACH Grant • School may select applicants for verification who were not originally selected by the Department • School may use institutional criteria for choosing who to select • School may select which data elements to verify and is not required to verify federal data elements if not selected by the Department

6. 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

7. 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

8. General Policies, cont.Marital Example 1 • 20 Year Old DependentFemale student • Parental info required • Filed 2013-14 FAFSA on 2/15/2013 • Gets married on 7/4/2013 If selected for verification, school may: • Make no change • 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

9. General Policies, cont.Marital Example 2 • The parent of a dependent student remarries between application and verification • (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)

10. 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

11. 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

12. Verification 2013-14 Where We Are

14. 2013-2014 Verification • Introduction of verification groups • V1, V2, V3, V4, V5 • Introduction of identity and high school completion elements

15. Tracking Groups and Data Elements

16. V1: Data and Documentation • Data elements: • Household size • Number in college • Income and tax information • Child support paid • SNAP • Documentation • Signed worksheets, DRT, tax transcript, etc. • Largely unchanged from prior year

17. V2: Data and Documentation • Data element: • SNAP Benefits • Documentation • Signed statement of receipt or • 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

18. V3: Data and Documentation • Data element: • Child support paid • Documentation • 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

19. V4: Data and Documentation • Data element: • High School Completion and Statement of Identity/Purpose • May also include Child Support Paid and SNAP (if indicated on the FAFSA) • Documentation • Verification worksheet (or appropriate SNAP/Child support paid documentation) • Proof of high school completion or alternative documentation • Proof of identity and statement of educational purpose

20. V4: Data and Documentation, cont. • High School Completion: • High School Diploma • Copy of Final HS Transcript Showing Graduation Date • Alternative Documentation • GED, State Exam, Transcript of 2-year Program with Credit toward Bachelor’s Degree, OR…

21. “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”

22. 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

23. 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)

24. 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

25. 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

26. V5: Documentation and Data • Data elements that must be answered: • 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

27. Verification 2014-15 What’s Ahead

29. 2014-2015 Verification • Federal Register published June 13, 2013 • Dear Colleague Letter, GEN-13-16, published June 13, 2013

30. What’s Changing? • V2 Tracking Group (SNAP only verification) • SNAP will still be verified in other groups: V1, V4, V5 and…

31. What’s New? • V6: Household resources (untaxed income)

32. What’s New? cont. • Modifications to documentation requirements • Updated process for verification of identity for V4 and V5 tracking groups

33. VerificationTracking Groups

34. V6: Household Resources • Applies to tax filers and non-filers • Requires all elements from groups V1 as well as other untaxed income

35. 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

36. 2014-2015 Verification – Other Untaxed Income • Acceptable documentation includes: • 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

37. 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.

38. 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: • Welfare benefits • Additional child tax credit • Earned income credit • Untaxed social security benefits • Supplemental security income (SSI)

39. 2014-2015 Verification – Other Untaxed Income • Household Resources • ED will not be specifying an income threshold • Leaving that to the institution to define • How will you determine your “magic” number? • Use poverty guidelines? • What seems appropriate/necessary for a certain family’s size and geographic location?

40. 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. • The IRS will not be issuing until after June 15, 2014. • FAA should know income thresholds for filing

41. Income Filing Thresholds for 2012

42. Modifications to Acceptable Documentation • High School Completion Status • 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

43. 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) • Household Size • Includes parents who are married or unmarried and living together, irrespective of gender • GEN-13-12

44. 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.

45. 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.

46. 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.

47. Additional Requirements • Required to enter Identity Verification Results into FAA Access (V4 and V5) • Manually enter information into CPS one student at a time until… • FAA Access to CPS online will accept a batch file after April 2014.

48. 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: • 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 • 5) No response from applicant or unable to locate.

49. Impacts to Consider • Impact to your verification forms • Impact to your student systems • Impact to your website • Impact to your Policy and Procedure Manual

50. Resources • Federal Register, published June 13, 2013 • http://ifap.ed.gov/fregisters/attachments/FR061313FAFSAInformationToBeVerifiedforthe20142015AwardYear • Dear Colleague Letter (GEN-13-16), published 6/13/13 • http://ifap.ed.gov/dpcletters/GEN1316.html