(GEN-22-06) Changes to 2022-2023 Verification Requirements

Publication Date
May 18, 2022
DCL ID
GEN-22-06
Subject
Changes to 2022-2023 Verification Requirements
Summary
This letter provides information about the extension of a waiver of certain verification requirements for the 2022-2023 award year as a result of the ongoing economic, social, and physical impacts of the COVID-19 pandemic.

Dear Colleague:

The Department of Education (Department) recognizes the need to continue to provide relief to millions of students and colleges facing challenges and barriers resulting from the ongoing national emergency. Therefore, we are continuing our waiver of certain verification requirements into the 2022-2023 award year. This means we are maintaining verification requirements that strictly focus on identity and fraud for the remainder of the 2022-2023 award year and waiving the remaining verification requirements.

As a reminder, this waiver applies no matter where institutions are in the verification process, e.g., if documents have been collected or requested, but verification has not been completed, or if an institution has not started the verification process or requested verification documentation. However, this does not exempt institutions from requirements to resolve conflicting information concerning a student’s eligibility. Please see the section below, “Reviewing Subsequent ISIR Transactions and Resolving Conflicting Information,” for more information. This waiver begins effective the date of this announcement and applies for the remainder of the 2022-2023 FAFSA processing and verification cycle.

Institutions maintain the discretion to select students for verification according to consistently applied institutional policies. However, the Department encourages institutions to consider amending such policies to limit selection in a manner that offers relief to students and families during the ongoing national emergency.

We are confident that institutions will be able to quickly implement these verification changes for students because they are the same changes the Department made for the 2021-2022 award year as outlined in DCL GEN 21-05.

Verification of Identity/Statement of Educational Purpose

Institutions are reminded that we have suspended the in-person submission and notary requirements for verification of Identity/Statement of Educational Purpose, and provided other flexibilities, as described below, through the end of the payment period that begins after the date on which the Federally declared national emergency related to COVID-19 is rescinded.

In completing the verification requirements for the Identity/Statement of Educational Purpose, as described in this DCL, and outlined in the “FAFSA® Information To Be Verified for the 2022–2023 Award Year” Federal Register notice, institutions may accept—

  • copies of the required verification documents electronically. This may occur by uploading a photo of the documents (including from a smartphone), PDF, or other similar electronic document through a secure portal at the institution, by email, etc.

  • an electronic signature using a stylus or finger to sign the statement, or an image of the individual’s signature affixed to the statement in lieu of obtaining a wet signature.

Reviewing Subsequent ISIR Transactions and Resolving Conflicting Information

Although verification is waived for certain information, as explained earlier, institutions are still required to review all subsequent ISIR transactions for the entire processing year, even if an earlier transaction was verified, except if a student is no longer enrolled at the institution.

If an institution has conflicting information concerning a student’s eligibility, including documentation obtained during the verification process, the institution must resolve the discrepancies before disbursing Title IV funds. More information about resolving conflicting information can be found in Chapter 5 of the 2022-2023 Application and Verification Guide.

System Reporting Requirements

Because this change to the verification policy is occurring mid-year, there will still be many 2022-2023 Central Processing System (CPS) transactions selected for verification.

Even if verification is no longer required, institutions must report a valid Verification Status Code for every student selected for verification by the CPS. Institutions should report a “V” (if verification was completed) or an “S”; "blank" is not an acceptable verification status code, except in the case when a student is selected after he or she is no longer enrolled at your institution.

When Verification Is Still Required

Institutions must still verify Identity/Statement of Educational Purpose when the applicant is selected for verification under Verification Tracking Flag “V4” and “V5,” unless a student is excluded from verification as provided under 34 CFR 668.54(b). These exclusions are outlined in Chapter 4 of the 2022-2023 Application and Verification Guide. Please note that Verification Tracking group V5 includes a combination of the verification of income/tax information (which is waived under this notice) as well as Identity/Statement of Educational Purpose (which must still be verified in 2022-2023).

When Verification Is No Longer Required

Institutions are not required to verify students selected under Verification Tracking Flag “V1” as of the date of this letter. Institutions are also not required to verify the other elements (income and tax information) listed under Verification Tracking Flag “V5,” as V5 is a combination of the verification of income/tax information and Identity/Statement of Educational Purpose. Again, the waiver being extended under this notice does not include a waiver of verifying Identity/Statement of Educational Purpose. This means that an application selected for Verification Groups V4 and V5 must still verify Identity/Statement of Educational Purpose. As noted above, this applies to any student file where verification was not completed as of the effective date of this Dear Colleague Letter. We are expanding the applicability of Verification Status Code “S- Selected not verified” to not only students excluded under 34 CFR 668.54(b), but also to all students selected under V1 who are exempt from standard verification under this guidance.

Changes for the 2023-2024 Award Year and Beyond

The Department will continue to monitor and review the federal verification process to consider what adjustments may need to be made to verification long-term to ensure that it is robust and equitable, and takes into consideration the burden on students, families, and institutions of higher education.

These changes will continue to provide relief to students and families affected by this ongoing national emergency. We thank institutions for their cooperation and continued role in safeguarding the integrity of the Title IV programs and in preventing improper payments.

Sincerely,

Annmarie Weisman,
Deputy Assistant Secretary for
Policy, Planning, and Innovation