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2017-18AUTHORIZED EVENTS

CREDENTIALEDTRAINING

VERIFICATION

Slide Handout

© 2010–2017 by National Association of Student Financial Aid Administrators (NASFAA). All rights reserved. NASFAA has prepared this document for use only by personnel, licensees, and members. The information contained herein is protected by copyright. No part of this document may be reproduced, translated, or transmitted in any form or by any means, electronically or mechanically, without prior written permission from NASFAA. NASFAA SHALL NOT BE LIABLE FOR TECHNICAL OR EDITORIAL ERRORS OR OMISSIONS CONTAINED HEREIN; NOR FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE FURNISHING, PERFORMANCE, OR USE OF THIS MATERIAL. This publication contains material related to the federal student aid programs under Title IV of the Higher Education Act and/or Title VII or Title VIII of the Public Health Service Act. While we believe that the information contained herein is accurate and factual, this publication has not been reviewed or approved by the U.S. Department of Education, the Department of Health and Human Services, or the Department of the Interior. The Free Application for Federal Student Aid (FAFSA®) is a registered trademark of the U.S. Department of Education. NASFAA reserves the right to revise this document and/or change product features or specifications without advance notice. April 2017

NASFAA U Authorized Event 2017–18 Verification

© 2017 NASFAA 1

Slide 1 © 2017 NASFAA

National Association of Student Financial Aid Administrators


2017–18 VerificationA NASFAA Authorized Event

2017–18


Lesson 1:Introduction to Verification


Introduction

The process used by the institution to check for

accuracy of FAFSA data

Reduce error rates in applicant-reported data

Insure eligible applicants receive correct amount of

Title IV aid


© 2017 NASFAA 2


Introduction

• Regulations define which applications, data elements, and documentation

• Verification applies to recipients of subsidized Title IV aid:

Federal Pell Grant

Federal Supplemental Educational Opportunity

Grant (FSEOG)

Federal Work-Study (FWS)

Federal Perkins

Loan

Direct Subsidized

Loans


Conflicting Information

Must be resolved for all award years, even retroactively, unless:• Student dies during the award year; or• Conflicting data are received after the

student is no longer enrolled at the school and does not intend to re-enroll


Selection Process

• Applications can be selected by:

Central Processing

System (CPS)InstitutionOR


© 2017 NASFAA 3


Verification Exclusions

• Verification not required under certain circumstances

Entire application

Spousal data

Parental data

Certain data elements

Institutional exemption


Exclusions

Entire application excluded if student:• Only eligible for unsubsidized Title IV aid

(see exceptions)• Transfers and was verified at another school• Will not receive aid for reason other than

failing to complete verification

Entire application

Spousal data

Parental data




Exclusions

Entire application excluded if student:• Is selected for verification or changes

verification tracking groups after ceasing to be enrolled at the school and all aid is paid

• Dies during the award year

Entire application

Spousal data

Parental data




© 2017 NASFAA 4


Exclusions

Entire application NOT excluded if selected for:• High school completion, and• Identity/Statement of Educational PurposeNOTE: Student eligibility issues must be verified if selected in tracking group V4 or V5 while still enrolled

Entire application

Spousal data

Parental data




Exclusions

Parental data is excluded if both parents:• Die, or the only parent on the FAFSA dies• Are mentally incapacitated, or the only

parent on the FAFSA is incapacitated

Entire application

Spousal data

Parental data




Exclusions

Parental data is excluded if both parents:• Cannot be contacted and whereabouts are

unknown• Reside in a country other than the U.S. and

cannot be contacted by normal means of communication

Entire application

Spousal data

Parental data




© 2017 NASFAA 5


Exclusions

Spousal data excluded if applicant’s spouse:• Is deceased or mentally incapacitated• Cannot be located because contact

information is unknown and cannot be obtained by the applicant

Entire application

Spousal data

Parental data




Exclusions

Spousal data excluded if applicant’s spouse:• Is residing in a country other than the U.S.

and cannot be contacted by normal means of communication

Entire application

Spousal data

Parental data




Exclusions

Number in dependent student’s household if:• Parents are married and household size is 3• Parent is unmarried and household size is 2

Entire application

Spousal data

Parental data




© 2017 NASFAA 6


Exclusions

Number in independent student’s household if:• Student is married and household size is 2• Student is unmarried and household size is 1

Entire application

Spousal data

Parental data




Exclusions

Institution excluded (exempt) if a foreign school participating in Direct Student Loan program and not located in a stateNOTE: Quality Assurance (QA) schools are no longer exempt from federal verification after 2016–17

Entire application

Spousal data

Parental data




Verification Selection Process

CPSFAFSA

School

• Customized approach

• Varies from applicant-to-applicant

• May be information not used in expected family contribution (EFC)


© 2017 NASFAA 7


Standard Verification Group

Custom Verification Group

Aggregate Verification Group

V1

V4

V5

Verification Tracking Groups



• Tax filer income information• Nontax filer income information• Household size• Number in college

V1



• High school completion• Identity and Statement of

Educational PurposeV4


© 2017 NASFAA 8



• Tax filer income information• Nontax filer income information • Household size• Number in college• High school completion• Identity and Statement of

Educational Purpose

V5


Data Element to Verify(any tracking group)*

Dependent Student’s Parent(s)

Independent Student

(and Spouse)

Adjusted gross income Tax filers Tax filers

Income earned from work Nontax filers Nontax filers

Household size No Yes

High school completion, identity, and SEP V5 only V5 only

* If applicant does not qualify for Automatic Zero EFC, update the application and verify remaining data elements applicable to tracking group.

Automatic-Zero EFC Qualifiers



© 2017 NASFAA 9


• Is ED’s customized approach to verification appropriate, or should all students who are selected for verification be required to verify all of the same data elements? Please explain why you feel this way.

• Does your institution verify data elements beyond those which are selected by the CPS? If so, for which data elements? What research does the institution do to justify the selection of each additional data element? Are there valid reasons for the selection?


• Should your institution be selecting additional data elements (such as dependency status, assets, other real estate and investments, etc.) for verification? If so, which data elements and why?

• For 2017–18, ED eliminated federal verification of other untaxed income, indicating that historical data revealed no significant changes in expected family contributions (EFCs) as a result of verifying untaxed income. Do you agree? Why or why not? Do you have institutional data that conflict with ED’s findings?

Page 12


Required Data Announced Annually

Federal Register

Dear Colleague Letter


© 2017 NASFAA 10


General Documentation Requirements

• May file FAFSA using estimated data, but must complete verification on actually filed taxes

• Specified year equals prior-prior year (PPY) data for 2017–18 (i.e., 2015)

• Can use same 2016–17 documentation to verify certain 2017–18 data elements

• Tax data elements are verified if either 2016–17 or 2017–18 ISIR contains IRS Request Flag of “02”


General Documentation Requirements

2016–17 Documents• AGI• Income from work• Taxes paid• IRA distributions• IRA deductions/payments• Untaxed pensions• Tax-exempt interest• Education tax credits• High school completion

2017–18 already verified


IRS DRT:• Tax return type• Tax filing status• Exemptions claimed• AGI• Income from work• Taxes paid• Untaxed IRA

distributions• IRA deductions• Untaxed pensions• Tax-exempt interest• Education tax credits


© 2017 NASFAA 11


IRS DRT Cannot Be Used

• Tax return has not yet been filed• Amended tax return filed• Puerto Rican or foreign (non-U.S.) tax

return filed• Taxes filed electronically within last 3 weeks• Taxes filed by mail within last 11 weeks• Parents are unmarried and living together• Change in marital status after end of tax

year and before filing FAFSA


IRS DRT Cannot Be Used

• Married independent student and spouse filed separate tax returns

• Married parents filed separate tax returns• Married and filed taxes as head of

household• First 3 digits of Social Security Number

(SSN) are “666” for Pacific Islanders• Neither married parent has a valid SSN• Both parents entered all zeros for SSN


Tax Return Transcript

Can be requested:• IRS Get Transcript

Online• IRS Get Transcript by

Mail• 1.800.908.9946• Mail or fax IRS Form

4506-T or 4506T-EZ• Income Verification

Express Service


© 2017 NASFAA 12


Acceptable Alternative Tax Transcripts

Record of Account

Transcript

Record of Account

Transcript

Tax Return Database View

(TRDBV) Transcript

Tax Return Database View

(TRDBV) Transcript

Return Transcript for

Taxpayer (RTFTP)

Return Transcript for

Taxpayer (RTFTP)

Any IRS Tax Transcript with All Required

Data

Any IRS Tax Transcript with All Required

Data


Verification Worksheets

• ED provides suggested text annually• School may:

– Use ED’s suggested text or create its own– Create a comprehensive worksheet or

customize it according to selected data• School must use ED’s Identity and

Statement of Educational Purpose text as is


Acceptable Signature Formats

SignatureFormat

“Wet”

Photo-copied Faxed

Electronic


© 2017 NASFAA 13



AGI—Tax Filers

Unaltered IRS DRT data

Tax Return Transcript

Acceptable alternative IRS tax transcripts

Foreign tax returns

U.S. Territory tax returns


AGI—Tax Filers


© 2017 NASFAA 14


AGI—Tax Filers: Alternative Documents

Tax return filing extensions

Amended tax returns

Tax account information cannot be located

Inability to obtain a Tax Return Transcript


U.S. Income Tax Paid—Tax FilersU.S. Income Tax Paid

Tax

Ret

urn

Tran

scrip

t

1040 Transcript—Income Tax After Credits Per Computer minus Excess Advance Premium Tax Credit Repayment Amount

1040A Transcript—Tentative Tax Per Computer minus Total Credits Per Computer

1040EZ Transcript—Total Tax Liability TP Figures Per Computer minus Health Care: Individual Responsibility

1040 Line 56 minus Line 46

1040

A

Line 28 minus Line 36

1040

EZ

Line 10

FAFS

A Student Question 37Parent Question 86


Income Earned from Work—Nontax Filers

• Statement or verification worksheet;• Form W-2 from each employer; and• IRS Verification of Nonfiling Letter

U.S. individuals

Foreign residents• Wage and Tax Statement or equivalent;• Statement or verification worksheet; and• Verification of Nonfiling from tax authority


© 2017 NASFAA 15


Income Earned from Work—Nontax Filers

Income Earned from Work

Tax

Ret

urn

Tran

scrip

t

1040 Transcript—Wages, Salaries, Tips, etc. + Business Income or Loss Sch. C Per Computer + Farm Income or Loss (Schedule F) Per Computer

1040A Transcript—Wages, Salaries, Tips, etc. + Business Income or Loss Sch. C Per Computer + Farm Income or Loss (Schedule F) Per Computer

1040EZ Transcript—Wages, Salaries, Tips, etc.

1040 Lines 7 + 12 + 18 + Schedule K-1, Box 14, Code A

Form W-2, Box 1

1040

A Line 7Form W-2, Box 1

1040

EZ Line 1Form W-2, Box 1

FAFS

A Student Questions 39 and 40Parent Questions 88 and 89


Untaxed Income and Benefits—Tax Filers

Untaxed portions of IRA distributions

IRA deductions and payments

Untaxed portions of pension/annuity distributions

Tax-exempt interest income

Education tax credits


Untaxed Income and Benefits—Tax Filers


© 2017 NASFAA 16


Tax Filers—Untaxed Income and Benefits


Tax Filers—Untaxed Income and Benefits



© 2017 NASFAA 17


Dependent Household Size

• Applicant• Applicant’s parents living in household• Parents’ other children (including graduate students but not

foster children supported by another entity), if parents will provide more than half support from 7/1/17 through 6/30/18

• Applicant’s children, if parents will provide more than half support from 7/1/17 through 6/30/18

• Parents’ or applicant’s unborn child, if born before 6/30/18, and parents will provide more than half support from projected birth date to 6/30/18

• Other persons living with and receiving more than half support from applicant’s parents from application to 6/30/18


Independent Household Size

• Applicant• Applicant’s spouse living in household• Applicant’s children (including graduate students but not

foster children supported by another entity), if applicant will provide more than half support from 7/1/17 through 6/30/18

• Applicant’s/spouse’s unborn child, if born before 6/30/18, and parents will provide more than half support from projected birth date to 6/30/18

• Other persons living with and receiving more than half support from applicant from application through 6/30/18


High School Completion

• High school diploma always preferred• Several types of documents can be used• School may accept alternative

documentation only when:– Secondary school documentation is

unavailable (e.g., closed school, deceased parent who provided home schooling)

– Foreign refugees, asylees, and victims of human trafficking who cannot obtain diploma or secondary school leaving certificate


© 2017 NASFAA 18


Identity/Statement of Educational Purpose

Statement of Educational Purpose


Optional Institutionally Selected Data

Assets

• Cash, savings, and checking

• Real estate and investments

• Other forms of untaxed income

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 not reported

elsewhere on FAFSA• Money received or paid on

student’s behalf


Optional Institutionally Selected Data

• Cannot include resources specifically excluded from need analysis, such as:– Federal veteran’s educational benefits– Military housing/housing allowance– Combat pay– Means-tested welfare benefits– Foreign income exclusions

• School must decide what constitutes acceptable documentation– Can be same as current or past ED requirements


© 2017 NASFAA 19


Financial Aid Administrators and Tax Expertise Aid Administrator must know:• Whether required

to file a tax return• Correct tax filing

status for a tax filer

• Cannot be claimed as an exemption by more than one person


Verification Status Codes

Verified

Without documentation

Selected/Not verified

Not verified

V

W

S

Blank



© 2017 NASFAA 20


Learning Activity: Required Verification Documentation

Page 44


Learning Activity: Required Verification DocumentationReview the case studies described on pages 44-46. In each case, determine what documentation must be collected to complete verification on federally selected applications, and what signatures are required, if any. Record your answers to the questions on pages 44-46.

Page 44


Learning Activity: Required Verification Documentation1. Karl

What is the Verification Tracking Flag for this Tracking Group? _________

What documentation is federally required from Karl?

Page 44


© 2017 NASFAA 21


Learning Activity: Required Verification Documentation1. Karl

What documentation is federally required from Rick?

Which documents require Karl’s signature?

Which documents require Rick’s signature?

Page 44


Learning Activity: Required Verification Documentation2. Lizzie


What documentation is federally required from Lizzie?

Page 45


Learning Activity: Required Verification Documentation2. Lizzie

Who must sign all of the documentation requested? Yes No Lizzie’s signature Yes No Carol’s and Tyreese’s signatures Yes No Carol’s or Tyreese’s signatures

You have reason to believe the number in college may be inaccurate. What must you collect from Lizzie?

Page 45


© 2017 NASFAA 22


Learning Activity: Required Verification Documentation3. Maggie


What documentation is federally required?

Page 46



What documentation is federally required?

Page 46



Who must sign all of the documentation requested? Yes No Maggie’s signature (worksheet) Yes No Glenn’s signature (worksheet) Yes No Both signatures (tax documentation)

You learn Glenn filed an amended return for 2015. What must you collect from Maggie and/or Glenn?

Page 46


© 2017 NASFAA 23


Lesson 2:Changing Applicant Data


Corrections

CorrectionChanges to

data that were

incorrect when FAFSA

was filed

UpdateChanges to data correct when FAFSA was filed but later changed

AdjustmentChange

made by aid administrator

using professional

judgment (PJ)


• Change in a single dollar item of $25 or more

• Any errors in nondollar items

• School may choose to submit all corrections to CPS

• Disburse grants

• FWS employment may begin

• Originate and disburse loans

Corrections

Data Correct as Reported

Required CPS

Reprocessing

OptionalCPS

Reprocessing


© 2017 NASFAA 24



Quick Quiz 1:1. What is a correction?2. What makes a SAR or ISIR valid?3. A school must submit corrections to the CPS for changes

in a single dollar item of $25 or more. True False

4. How are overawards treated differently for the campus-based programs, compared to others such as the Federal Pell Grant Program?

5. What does Comment Code 399 indicate?

Page 108


Learning Activity: Corrections

Page 109


© 2017 NASFAA 25


Learning Activity: Corrections1. Damaris is a dependent, second-year student. Before the

FAFSA was filed, Damaris and her family moved. Since her FAFSA was a renewal, the old address carried over. She used the IRS Data Retrieval Tool successfully. She was selected for verification and is eligible for subsidized aid. The institution completed verification, but noticed on all of Damaris’ documentation, her address was different. She explained the circumstances.

Is this correction: Optional Required

Page 109


Learning Activity: Corrections2. Timothy is in his last year of college. He has never been

selected for verification—until now. This year, he is now Pell-eligible, despite the fact that 2015 tax and income information was used to complete both the 2016–17 and 2017–18 FAFSA. He initially reported four people in his household, but on the verification form, he reported seven. His family had been supporting his aunt and her two children since December of the prior year, after she lost her job and her apartment building was destroyed in a fire. Is this correction: Optional Required

Page 109


Updates


data that were


was filed


AdjustmentChange


using professional

judgment (PJ)


© 2017 NASFAA 26


Updates

• Dependency status (not due to student marital status change)

Required anytime

• Household size/Number in college (not due to student marital status change)

Required at verification

• Dependency/marital status• Household size• Number in college

Optional anytime to address

inequity/ability to pay



Quick Quiz 2:1. An update is a change to data elements that were

incorrect at the time the FAFSA was filed. True False

2. What items can be updated on the FAFSA under certain conditions?

Page 113


© 2017 NASFAA 27


Quick Quiz 2:3. A school may allow an update to marital status under

which of the following circumstances? To address an inequity To more accurately reflect the student’s ability to pay

educational costs For a student in special circumstances For a dependent student’s parents after verification is

completed in special circumstances

4. Household size and number in college may be updated only for applicants selected for verification. True False

Page 113


Learning Activity: Can an Update Be Made?

Page 114


Learning Activity: Can an Update Be Made?1. Jasmine was selected for verification. All necessary

documentation was submitted and verification was completed. The next month, Jasmine’s mother goes to the courthouse to marry her longtime love. Can an update be made? Yes No

Why or why not?

Page 114


© 2017 NASFAA 28


Learning Activity: Can an Update Be Made?2. Desmond completed his undergraduate program at the

end of the summer session in July. He is scheduled to begin his graduate program at the same institution in September. Summer marked the beginning of his institution’s academic year. Can an update be made? Yes No

Why or why not?

Page 114


Learning Activity: Can an Update Be Made?3. Tina is an incoming freshman with four people in her

household—her mother, her father, and her twin sister Toya. Toya was going to work for a few years first, before college. Tina only included herself in the number in college. Tina’s FAFSA was selected for verification. Toya decided to attend the same college. Tina has not yet completed verification. Can an update be made? Yes No

Why or why not?

Page 114


• How does your institution handle changes in dependency status? Do students self-report or do you flag changes on student ISIRs?

• Do you think it is fair that parental data associated with a change in marital status can only be updated if the dependent applicant is selected for verification? Why or why not?

• For what reason may you deny an update due to a change in an applicant’s marital status?

Page 115


© 2017 NASFAA 29


Professional Judgment Adjustments


data that were


was filed


AdjustmentChange


using professional

judgment (PJ)


Professional Judgment Adjustments

• Optional• Discretion granted to financial aid

administrators under section 479A(a) of Higher Education Act of 1965 (HEA), as amended

• Verification of specified-year data and resolution of conflicting information required before PJ


Loss of employment

Extraordinary dependent

care

Secondary school tuition

Unusual uncovered medical/dental

expensesParent/spouse death

Divorce

Possible Special Circumstances


© 2017 NASFAA 30



Quick Quiz 3:1. Financial aid administrators must use professional

judgment for special circumstances. True False

2. If a student is selected for verification, the student must be __________ and any conflicting information __________ before professional judgment is performed.

3. Define specified year.

Page 118


Quick Quiz 3:4. The specified-year data for the 2017–18 award year is for

________. 2015 2016 2017

5. The institution is required to maintain documentation to substantiate any PJ decisions that are made. True False

Page 118


© 2017 NASFAA 31


Quick Quiz 3:6. The HEA identifies which of the following as examples of

special circumstances for which the financial aid administrator may exercise PJ on a case-by-case basis? Housing status that results in an individual being homeless Unemployment of a family member or independent student Medical expenses that are covered by insurance Elementary and secondary school tuition expenses Unusually high child care or dependent care costs A student or family member who is a dislocated worker The number of parents enrolled at least half time in a

degree, certificate, or other program leading to a recognized educational credential at a Title IV-eligible institution

Page 118


Learning Activity: Professional Judgment and Verification

Page 119


Learning Activity: Professional Judgment and Verification1. During the verification process, Shruti, a first-year student,

reveals that her mother is also enrolled half-time at the institution. Normally, parents are not included in the number in college. Can the institution use professional judgment to include Shruti’s mother in college? Can an update be made? Yes No

Page 119


© 2017 NASFAA 32


Learning Activity: Professional Judgment and Verification2. Terrell, a third-year independent student, was selected for

verification in the V1 verification tracking group. He used the IRS Data Retrieval Tool to transfer his 2015 income tax data. He lost his job at the local bottling plant in early 2016 and has been unable to find work since that time. Can the institution use professional judgment to account for Terrell’s loss of income? Can an update be made? Yes No

Page 119


Learning Activity: Professional Judgment and Verification3. After verification is complete, Chris speaks to his financial

aid counselor regarding medical expenses his family has accumulated. The expenses were covered by insurance. Chris’ parents used a flexible spending account provided by an employer to cover the copays. Can the institution use professional judgment for their medical expenses? Can an update be made? Yes No

Page 119


• Does your institution use PJ? If so, what circumstances does your institution consider for PJ? If not, why?

• Why do you think PJ may be a good tool to use?

• How do you think PJ may be used incorrectly?

• Why do you think there may be an increase in the use of PJ resulting from the use of prior-prior year (PPY) data?

Page 120


© 2017 NASFAA 33


Lesson 3: Disbursements, Timeframes, and Policies and Procedures


Conditions

• Prior to verification• After verification,

but prior to receipt of SAR/ISIR

Interim Disbursements


Program-Specific Interim Disbursement Requirements

• One interim disbursement for first payment period only

Federal Pell Grant,

FSEOG, and Federal

Perkins Loans

• Employ up to 60 consecutive days after student enrolls

FWS


© 2017 NASFAA 34


Program-Specific Interim Disbursement Requirements

• Originate, but not disburseDirect

Subsidized Loans

• Not subject to interim disbursement rules

• Other disbursement rules apply

Direct Unsubsidized Loans, PLUS, TEACH Grant,

IASG


Student Deemed Ineligible for Interim Disbursement

Disbursement becomes an overpayment if:• Verification shows student was not eligible

for those funds;• Verification not completed before

appropriate deadline; or• School does not receive valid SAR or ISIR

reflecting corrections within deadline specified in regulations


Ineligible for Interim Disbursement

Attempt to resolve overpayment by:

Applying $300 campus-based

overaward tolerance

Adjusting subsequent

disbursements in award year

Reimbursing Title IV program account by

requiring student to return funds


© 2017 NASFAA 35


Ineligible for Interim Disbursement

If unable to resolve overpayment, the school:• Is liable for the overpayment• Must return funds to Title IV program

account by earlier of 60 days after last day of attendance or award year

• Must reimburse FWS Program and pay student’s wages from institutional funds


Other Program-Specific Disbursement Requirements

For unsubsidized-only aid recipients:• Verification exclusion does not apply to high

school completion, identity, or Statement of Educational Purpose in V4 or V5

• Not required to verify other data elements if selected for V5 (income, household size, number in college)


Other Program-Specific Disbursement Requirements

• Cannot circumvent verification by requesting only unsubsidized aid

• If not making interim disbursements, and selected for verification:– No further disbursements/FWS earnings can

be paid until verification is completed– Do not return previously disbursed funds while

waiting to complete verification


© 2017 NASFAA 36


Verification Never Completed for Tracking Group V1

Aid Program

Disbursements/FWS Earnings

Pending Verification?

School Returns Funds

Already Disbursed?

Student/Parent Returns Funds

Already Disbursed?

Title IV Grants No No Yes

Perkins Loans No No Yes

FWS No No NoDirect Subsidized

Loans No No No

Direct Unsubsidized Loans and PLUS

Yes, if verification

delayedNo No


Verification Never Completed for Tracking Group V4 or V5

Aid Program

Disbursements/FWS Earnings

Pending Verification?

School Returns Funds

Already Disbursed?

Student/Parent Returns Funds

Already Disbursed?

Title IV Grants No No Yes

Perkins Loans No No Yes

FWS No No No

Direct Subsidized Loans No No Yes

Direct Unsubsidized Loans and PLUS No No Yes



© 2017 NASFAA 37



Learning Activity: Interim Disbursements

Page 142


Learning Activity: Interim DisbursementsAmelia will be a first-year student at Big Sky University (BSU) in the fall of 2017. BSU’s goal is to notify incoming students of their financial aid awards by January 2. The financial aid office does not complete verification before awarding newly admitted students.

Amelia’s parents separated in March 2017 and are in the middle of a contentious divorce. They both want custody of Amelia’s younger brother and disagree over how to pay for Amelia’s college education. As a result, the financial aid office was unable to complete verification before the fall semester started on September 7.

Page 142


© 2017 NASFAA 38


Learning Activity: Interim DisbursementsBig Sky University tentatively awarded Amelia the following aid for the 2017–18 award year:

Page 142


Learning Activity: Interim Disbursements1. Under what conditions could BSU make interim

disbursements to Amelia?

2. If BSU makes interim disbursements to Amelia, which Title IV funds could it disburse?

Page 142


Learning Activity: Interim Disbursements3. Amelia is anxious about earning some money to help

cover personal expenses, so the financial aid office places her in a FWS position at the library. On what date will Amelia have to stop working through the FWS Program if BSU does not complete verification?

Page 143


© 2017 NASFAA 39


Learning Activity: Interim Disbursements4. On September 22, Amelia sees her financial aid counselor.

Amelia tells her counselor that she has decided to decline her Direct Subsidized Loan and would like to borrow a Direct Unsubsidized Loan instead, in case it takes her longer than anticipated to complete her bachelor’s degree. BSU has yet to complete verification. May Amelia borrow a Direct Unsubsidized Loan now? Why or why not?

Page 143


• Do you think interim disbursements are a good idea? Why or why not?

• What issues should a school consider before making interim disbursements?

• Do you agree with the regulatory provision allowing schools to originate—but not disburse—a Direct Subsidized Loan before completing verification? Why or why not?

Page 144


Verification and the Award Cycle

Upon receipt of ISIR

Before making tentative award

After making tentative award, but before

award confirmation

After student accepts award, but before

disbursement

After interim disbursement, but

before second disbursement


© 2017 NASFAA 40


Verification Deadlines

Institutional deadline

Federal Pell Grant

deadline Campus-Based and Direct Loan deadlines



Quick Quiz 2:1. Define award cycle.2. All schools must complete verification at the same point in

the award process, as determined by ED each year. True False

3. Schools can complete verification: When a student applies for admission When a student’s application (SAR or ISIR) is received At a time selected by the student Before making a tentative award offer After making a first—but before making a second—

disbursement

Page 147


© 2017 NASFAA 41


Quick Quiz 2:3. What happens if a student fails to submit required

verification documents by an institution’s established deadline?

4. What documentation must the school have in its possession before the final ED-established award year processing deadline in order for a student to avoid forfeiting a Federal Pell Grant award due to verification being incomplete?

Page 147


Learning Activity: Interview

Page 148


Learning Activity: Interview1. What is your institution’s deadline for submitting verification

documentation? Are there different deadlines for different students?

2. Will your school award aid to an otherwise eligible student if he or she submits verification documentation after your school’s deadline? Why or why not?

3. How does your school publicize verification deadlines to students? Are these methods effective?

Page 148


© 2017 NASFAA 42


Verification Policies and Procedures

SelectionProcedures

How are students selected

Information Shared

Documentation requirements

Student responsibilities

Document Submission

Deadlines

Consequences for

noncompliance

Post-Verification

Process to correct data

Outcome notification to

student



Quick Quiz 3:1. Define policy and procedure.2. The verification regulations give schools some flexibility

when establishing policies and procedures. True False

3. Schools are required to have verification policies and procedures addressing: When documentation requirements may be waived Selection procedures Information shared with selected applicants Applicant verification document submission Post-verification procedures

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Quick Quiz 3:4. What information must an institution share with applicants

selected for verification?5. The school must send a written notification of the results of

verification to applicants in a timely manner. True False

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• Do you agree that institutions should have written verification policies and procedures? Why or why not?

• How does your financial aid office notify an applicant of the results of verification and any change to his or her EFC?

• How does your school define “a timely manner” for providing this notification?

• What additional policies and procedures should schools have for verification? Why?

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Question and Answer Segment

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1801 PENNSYLVANIA AVENUE NW, SUITE 850WASHINGTON, DC 20006

202.785.0453 FAX. 202.785.1487 WWW.NASFAA.ORG

© 2017 National Association of Student Financial Aid Administrators

The National Association of Student Financial Aid Administrators (NASFAA)

provides professionaldevelopment for financial

aid administrators; advocates for public policies that increase

student access and success;serves as a forum on student financial aid issues; and is

committed to diversitythroughout all activities.