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Verification. 2012 New Aid Officer Workshop Consuela Mitchell Director of Student Financial Aid Services Tarrant County College-NE Campus 2012-2013 Application & Verification Guide (AVG) Chapter 4 “Verification, Updates, and Corrections”
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Verification 2012 New Aid Officer Workshop Consuela Mitchell Director of Student Financial Aid Services Tarrant County College-NE Campus 2012-2013 Application & Verification Guide (AVG) Chapter 4 “Verification, Updates, and Corrections” http://ifap.ed.gov/fsahandbook/attachments/1213AVGCh4.pdf
Verification Topics • Quality Assurance Program • Policies and procedures • Whose application must be verified • Verification requirements • Acceptable documentation • Data element corrections-vs-updates • Interim disbursements • Verification time frames • Changes beyond 2012-2013 • Available resources
Verification • Process of verifying accuracy of FAFSA data • Regulations define: • Whose application must be verified(AVG-76) • Data elements to be verified(AVG-76) • Documentation used to verify data elements(AVG-81) • Regardless of verification selection, must always resolve discrepancies and conflicting information
Quality Assurance Program • Participation voluntary • ED provides guidelines, tools, and incentives for participation • Participating schools exempt from prescribed verification requirements • School sets verification parameters • School must reassess and self-correct verification process on ongoing basis • Every other year – Random Sample must be completed • Quality Assurance Website: http://ifap.ed.gov/qahome/Default.html (AVG-84)
Verification Policies andProcedures Your school must have written P&P’s about: • Time period students must submit verification documentation, • Consequences for failing to submit documents in time, • Method school uses to notify students if their EFC and Title IV aid amounts change, • Procedures school or students will follow to correct FAFSA data, • Procedure school will follow to refer a student to the Office of Inspector General (AVG-76)
Whose Application Must Be Verified? • Applicants selected by Central Processing System (CPS) • Applicants selected by institution
Programs to Which Verification Applies • Subsidized student financial assistance programs • Federal Pell Grant • Campus-based programs • Subsidized Direct Loan program *excludes TEACH Grant, Direct Unsubsidized Loan, & Direct PLUS Loan*
Institutionally-Selected Applications • Institution can select additional applications not selected by CPS • Selection may be based on such data elements as: • Estimated tax figures • Low family income levels • Large household size or number in college • Completion of certain FAFSA data elements • Other institutional criteria
Verification Exclusions • Certain types of applicants and data elements exempt from verification • Reason for verification exclusion should be documented in student’s file • Except in the case of student’s death, none of the exclusions excuse school from requirement to resolve conflicting information (AVG-77)
Verification Exclusions • Death of student • Not an aid recipient • Only eligible for unsubsidized student aid • Applicant verified by another school • Must get letter from school which completed verification that includes transaction # of valid ISIR • Post enrollment • Few other exclusions (AVG-77-78)
Number in Household & Number in College • Statement or verification worksheet listing each household member’s: • Name • Age • Relationship to applicant • Postsecondary school (if any) attending at least half-time in an eligible college • If institution doubts statement, it should obtain statement from each postsecondary institution listed by applicant (AVG -80-81)
Child Support PAID If ISIR indicated student or parent paid child support in 2011
Child Support PAID Documentation Request additional documentation if information provided appears inaccurate • Copy of separation agreement or divorce decree • Signed statement from parent providing support • Copies of canceled child support checks or money order receipts (AVG-82)
SNAP benefits (food stamps) If ISIR indicates someone in parents’ or student’s HH received SNAP benefits in 2010 or 2011, student must provide signed statement indicating receipt of benefit (AVG-82)
Tolerance Option • $25 tolerance for any dollar item • No tolerance to non-dollar items like # in HH & # in college
Tax Filing Extensions • Collect W-2’s and one of following: • IRS Form 4868; or • Copy of IRS approval of extension beyond 4-month extension • May collect and review tax return transcript when filed (AVG-79)
Verification Corrections For students not selected for verification, school orstudent must correct and submit for processing any errors reported on the original FAFSA that would change the EFC or that determine the students’ eligibility for aid. (AVG 84)
Verification Updates • FAFSA considered “snapshot” of family’s financial situation as of date application was submitted • After this date, only following items can be updated: • Dependency status throughout the award year except when the update is caused by a change in the student’s marital status • Household size & # in college to be correct as of date of verification unless change is due to change in the student’s marital status (AVG-82)
Verification Updates Number in Household and Number in College • If selected, data must be accurate as of verification • If not selected, • Cannot update for changes occurring after original application filed • School not required to monitor data element change
Verification Updates • Generally, cannot update change in student’s marital status • Mustupdate household size if dependent student’s parent remarries after application, before verification
Professional Judgment • You must complete verification for a selected student before you exercise professional judgment to adjust any values that are used to calculate the EFC. • But making a PJ adjustment does not require you to verify an application that isn’t selected. (AVG-76)
Interim Disbursements In the absence of conflicting information or reason to believe information isinaccurate, institutions have the following disbursement options when verification still incomplete (school liable for overpayment): • Federal Pell Grant and campus-based programs: • Withhold payment • Make 1 disbursement for 1st payment period • Employ applicant up to 60 days under FWS (AVG-84)
Interim Disbursements Direct Subsidized Loans: • Refuse to certify or originate loan; or • Certify or originate loan, but not disburse/deliver loan proceeds (AVG-84)
Verification Time Frames Verification Deadlines • Campus-based and Direct Loans: • Institutionally-established deadline • Federal Pell Grant: • Institutionally-established deadline • Institution must have verification documents and valid SAR/ISIR by earlier of 120 days after last day of enrollment or deadline published annually by ED in Federal Register (expected to be September 27, 2013) (AVG-89)
Verification Beyond 2012-13 Several changes have been made. Specific data elements will be targeted, rather than requiring the same data to be verified for all applicants. Additional data elements beyond the five that have been historically targeted may be added in future years. These may include whether families have qualified for means tested benefits or certain categories of financial independence. The Secretary will publish a list each year of the data elements that will be included in the verification process 4-6 months prior to the start of the application processing cycle. Source: Final Federal Register October 29, 2010 Regulations: 668.51.61
Verification Beyond 2012-2013 Source: Final Federal Register October 29, 2010 Regulations: 668.51.61 The results of verification & PJ changes cannot be submitted on the same day. The changes impose new requirements for the recovery of Title IV funds if a school opts to use interim disbursements. Conflicting documentation -- regardless of verification -- must still be resolved.
Available Resources • Federal Student Aid Handbook • Application and Verification Guide http://ifap.ed.gov/fsahandbook/attachments/1213AVGCh4.pdf • Institutional Policies and Procedures • IRS Publication 17 found at http://www.irs.gov/pub/irs-pdf/p17.pdf • Me! consuela.mitchell@tccd.edu 817-515-6792