6.12 Verification
Authority: 34 CFR §668.51-61s
Policy Statement
Verification is the process of confirming the accuracy of student reported data on financial aid applications. Only a portion of the student population is selected for verification.
Selection of Applications to be verified
The Financial Aid Office verifies those applicants identified by the Central Processing Service (CPS). Typically, the selection criterion translates into verifying thirty percent of the financial aid population at SCC. In addition, Aid Administrators may select a student for verification if there is a discrepancy or a condition which is unusual and warrants investigation. Due to increasing instances of fraud or misuse of Federal Student Aid funds, which is a nation-wide concern, all distance-learning students are institutionally selected for verification.
Exclusions
Listed below are certain circumstances where students do not have to complete verification. The Financial Aid Technician must identify and document in the student record why the student is not required to complete verification:
- An applicant who died during the award year.
- A resident of Guam, American Samoa, the Northern Mariana Islands, the Marshall Islands, the Federated States of Micronesia, and the Trust Territory of the Pacific Islands (Palau).
- A student who is incarcerated.
- Applicants whose parents do not live in the United States and cannot be contacted.
- A student immigrant (however, the student must meet the citizenship requirement).
- A dependent student whose parents cannot comply because of specified reasons (i.e., parents are deceased, are mentally incapacitated, the student does not know where the parents reside or the parents reside in another country and cannot be contacted by normal means).
- A student who does not receive Title IV funds.
- A student who is eligible to receive only Federal Direct Unsubsidized aid.
- A student verified by another school if the verification was for the current award year and is or her FAFSA data has not changed. We must get a letter from the previous school stating it verified his/her application and the school provides the transaction number of the valid ISIR.
- A student was selected for verification after ceasing to be enrolled and all disbursements were made.
- An independent student whose spouse cannot comply because of specified reasons (i.e., spouse is deceased, is mentally incapacitated, the student does not know where the spouse resides or the spouse resides in another country and cannot be contacted by normal means).
Regulations allow situations when verification of household size is not required. The Financial Aid Office does not have a systematic way to track these exclusions.
All students selected for verification in groups V1 or V5 must submit a response to the household size question on the Verification Worksheet.
Conflicting Information
If SCC has conflicting information for an applicant or has any reason to believe his/her application information is incorrect, SCC is required to resolve any discrepancies discovered in a student's file.
Verification of Data Elements
SCC verifies only those data elements required by the federal government. However, the Financial Aid technician may ask for additional information if further investigation is needed to resolve a discrepancy.
Acceptable Documentation
For Verification for the 2017-2018 award year, acceptable documentation listed in the Federal Register Volume 81, No. 63, published Friday, April 1, 2016 and Dear Colleague Letter GEN-16-07.
Per Dear Colleague Letter GEN-17-04 issued April 24, 2017, due to the suspension of the IRS Data Retrieval Tool (IRS DRT), ED is providing flexibilities schools may choose to use as part of their Verification procedures.
Effective immediately (April 24, 2017), these flexibilities apply to both the 2016-2017 and 2017-2018 FAFSA Processing cycles. The new guidance replaces the guidance provided in the October 18, 2016 Electronic Announcement (noted below)
The new flexibilities include:
For IRS Tax Return Filers - In lieu of using the IRS DRT, or obtaining an IRS transcript, a school may consider a signed paper copy of the 2015 IRS tax return submitted to the IRS as acceptable documentation to verify FAFSA/ISIR tax return information.
Verification of Nonfiling – Schools are no longer required to collect documentation obtained from the IRS or other tax authorities verifying that the applicant, the applicant’s spouse or the applicant’s parents did not file a 2015 tax return (often referred to as Verification of Nonfiling). However, as currently required, the applicant, the applicant’s spouse or the applicant’s parents, as applicable, must provide to the school—
- A signed statement certifying that the individual has not filed and is not required to file a 2015 income tax return, and a listing of the sources of any 2015 income earned by the individual from work and the amount of income from each source; and
- A copy of IRS Form W–2, or an equivalent document, for each source of 2015 employment income received by the individual.
SCC’s Discretionary Items
The Financial Aid Technician verifies applicants identified by ED. The Financial Aid Technician may also select a student for verification if there is a discrepancy or a condition which is unusual and warrants investigation (i.e., out of state student, number in household, and conflict in EFC).
If a student submits verification documentation, but was not selected (i.e., tax transcript, W2’s), the Financial Aid Office staff must verify the information on the document against the information on the FAFSA. If discrepancies are found corrections must be made.
Interim Disbursements
Because the Financial Aid Office is liable for disbursements made prior to verification, the Financial Aid Office policy does not allow interim disbursements. Students must complete the verification process before aid is awarded or disbursed. There are no exceptions.
If aid is awarded and disbursed, and afterward a new corrected ISIR transaction is received which selects the student for verification, all future aid must be cancelled until the verification process has been completed.
IRS Transfer or IRS Transcript
Students selected for verification will be directed to either go into the FAFSA and complete the IRS transfer or contact the IRS and request an IRS Tax transcript.
- Dependent students must submit their IRS transfer or transcript and the transfer or transcript of their parents.
- Independent students must submit their IRS transfer or transcript and their spouse's if applicable.
Per an Electronic Announcement issued by ED, dated April 24, 2017, for the remainder of the 2016-2017 and 2017-2018 FAFSA Award Year verification process, a signed paper copy of a IRS tax return (IRS 1040, IRS 1040A, IRS 1040EZ) is considered acceptable documentation for income and tax related verification information.
If the Financial Aid Technician finds it necessary to verify conflicting information, the student may be requested to provide additional information.
Non-citizen Spouse (Policy added July 1, 2017)
If a student is married but his/her spouse is a non-citizen and not residing in the U.S., the IRS allows the student to file as single if the student meets the criteria for filing as Head of Household for the tax year.
If a student indicates he/she is married but is filing as single, the student must have met the requirements for and must have filed as Head of Household and the student must provide:
- Information on the non-citizen spouse’s income in the form of a written, signed statement from the student if the spouse earned no income.
- If the non-resident spouse lives in a country where tax filing is required, the student must supply a copy of the tax return, translated into U.S. currency if necessary.
- If tax filing is not required, a written statement of equivalency of currency.
If the student does not meet the requirements for filing as Head of Household, the student must have filed as married (married filing jointly, or married filing separately) unless they meet the requirements of other statuses such as widowed or divorced during the tax year.
Procedure
Notification of Verification to Applicants
Students are initially notified of being selected for verification from the Department of Education through an email or paper Student Aid Report (SAR). In addition, the tracking letter sent out from the financial aid office indicates to the student he/she has been selected for verification.
Verification Time Frame
Upon receipt of the FAFSA, when the student record is activated after receipt of a federal transmission, a tracking letter (email) listing missing items is sent to the student. This email informs the student of any additional information required to complete his/her financial aid file.
If the student is selected for verification, the tracking letter requests the appropriate verification documents (i.e., verification form, student and parent tax transcripts, etc.). Students are informed the majority of financial aid funds are awarded on a first-come, first-serve basis and that the file will not be processed further until the missing items are submitted to the Financial Aid Office.
Tracking letters are sent to students every 30 days informing the student of documents or information still outstanding for Verification. This process is handled electronically and notifications are sent out to students by email. If an email is rejected, then a Missing Information Letter is sent to the student by postal mail. If a student submits an incomplete document, it is returned for completion. If a student does not submit the required information in the appropriate time span, the application will become inactive and no further correspondence will be sent.
Documentation submitted to the Financial Aid Office must be legible, appropriate, and have the student's Social Security Number or Colleague ID number for identification purposes. If the student submits a document which is not legible or appropriate (i.e., a copy of a tax transcript in which the income numbers are not identifiable or a verification worksheet missing a signature), the documents will be returned and a request for additional documentation or corrections is requested. The return of documentation is recorded on the Colleague system as “incomplete” and a comment is made in the verification section of Colleague.
Students who fail to submit verification documents never have completed files so aid is not awarded to these students.
If a student submits documentation which appears fraudulent, the Financial Aid Office staff member must notify the Administrative Director of Financial Aid.
Once the requested information is received, Verification is completed, corrections are sent to the Central Processing System (CPS), corrections are imported into the Colleague system (within 3 business days) and an award notification email is sent out to the student with instructions on how to log in to SCC’s HUB/Web Advisor for Students to accept or reject his/her financial aid offer.
Document Collection Procedures
Required documentation items are tracked on the Colleague system and a missing document CRI code, along with a CRI tracking letter code are kept on the student’s computer file. When documents arrive, Financial Aid staff will enter a receipt date beside the document name on the Colleague tracking screen. When all required documents are received, the student is considered “complete” and ready to be verified. The Financial Aid Technician runs reports to determine which students are “complete”.
Students assigned to the V4 or V5 Verification Tracking Group will have 45 days to supply the requested information. SCC must report back to the Central Processing System (CPS) within 60 days of sending out the first tracking letter.
To submit the verification results for Tracking Groups V4 and V5, the Administrative Director of Financial Aid will report the information via the CPS Online website. Results may be submitted either individually or as a flat file for up to 2,000 students.
Corrections to the FAFSA data are submitted to CPS via the CAPX function on the Colleague system. In order for verification to be completed and aid to be awarded, all required documentation must be received within 120 days after the last day of the student’s enrollment. Any necessary corrections to the FAFSA data must be submitted through FAA Access to CPS Online by the date announced annually by the Department of Education in the Federal Register.
Notification to Students
In order for the student to receive his/her financial aid offer the student must be accepted to the College in a degree seeking program. Students are notified of the results of verification in the form of an Award Notification email. The student is given instructions to log into the HUB/Web Advisor for Students at (thehub.southeast.edu), Financial Aid, Financial Aid Award Letter) to view the financial aid offer. By clicking on the Financial Aid Award Letter option, the student is given the Terms and Conditions to read and are required to enter the Financial Aid Year in order to view his/her financial aid offer. Once the student has viewed his/her offer the student needs to accept or reject the student loan offer. At Web Advisor for Students, Financial Aid, the student clicks on “Accept/reject my student loan awards”. The student is again given the Terms and Conditions to read, along with instructions and a link for completing a Master Promissory Note (MPN) and Entrance Counseling at www.studentloans.gov.