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Program Integrity Questions and Answers - Verification

Questions on this topic are divided into the following categories:

UNLESS OTHERWISE NOTED, THE GUIDANCE BELOW APPLIES TO ALL AWARD YEARS BEGINNING WITH 2012-2013.

General Questions (VER)

VER-Q1. Where can I find guidance on the verification requirements?

VER-A1. The following resources provide guidance on the verification requirements:

General

Archived Guidance beginning with the 2024-2025 award year

2025-2026 Award Year

VER-Q2. Does the use of professional judgment by a financial aid administrator (FAA) automatically require an applicant to be selected for verification by the institution, therefore requiring the institution to complete verification prior to making a professional judgment decision?

VER-A2. No. An institution is only required to complete verification prior to making professional judgment adjustments when the applicant's FAFSA information has been selected for verification by the Department or by the institution. (Section 668.53) [Guidance issued 01/26/2012]

VER-Q3. Are adjustments to an applicant's FAFSA information that are based on professional judgment selected for verification?

VER-A3. Archived

VER-Q4. May an institution delay disbursing Title IV student financial assistance until the institution completes verification of the FAFSA information it selected beyond the items required by the Department?

VER-A4. It depends on the FAFSA information that has been selected for verification. An institution may delay disbursing Title IV student financial assistance if the FAFSA information that it has required to be verified would impact the applicant's Title IV student aid eligibility. For example, while not required by the Department, the institution requires verification of an applicant's claim that she is an emancipated minor and thus is independent. Because the result of verification could change the applicant's dependency status and, therefore, her Title IV eligibility, the institution may delay disbursing the federal aid until the question of emancipation has been verified.

However, if the item(s) the institution selects for verification would not impact the applicant's eligibility for Title IV student financial assistance, the institution may not delay disbursing Title IV student financial assistance until verification of those items is completed. For example, the institution requires verification of home equity to determine the applicant's eligibility for state or institutional aid. Because there will be no impact on the applicant's Title IV eligibility regardless of the result of verification, disbursement of Title IV aid may not be delayed while waiting for verification of home equity. (Section 668.58(a)) [Guidance issued 01/26/2012]

VER-Q5. Are Quality Assurance (QA) institutions exempt from the new verification rules beginning with the 2012-2013 award year?

VER-A5. Archived

VER-Q6. Must an institution complete verification for selected applicants who will receive aid only from the unsubsidized Title IV student aid programs and are not eligible for any aid from the Title IV subsidized student aid programs?

VER-A6. No. An institution is not required to complete verification for applicants who are only eligible for aid from the unsubsidized Title IV student aid programs, i.e., Direct Unsubsidized Loans and PLUS Loans, and who are not eligible for any aid from the subsidized Title IV student aid programs. [Section 668.54(b)(1)(iii)] [Guidance issued 03/13/2012; revised 7/7/2015]

VER-Q7. Must an institution complete verification for a selected applicant who is eligible for both subsidized and unsubsidized Title IV student aid when the applicant chooses not to accept the subsidized aid?

VER-A7. An applicant who is eligible for subsidized and unsubsidized Title IV student aid may not avoid completing verification by accepting only the unsubsidized Title IV student aid. In such a case, the institution must complete verification for the applicant to be eligible for any Title IV student aid.

However, except for applicants who are in Verification Tracking Group V4 or V5, an institution may, on a case by case documented basis, disburse unsubsidized Title IV aid to those applicants who are selected for Verification Tracking Group V1 if the institution has determined that there will be a delay in the completion of verification. Also refer to Electronic Announcement dated October 31, 2016. [Sections 668.51(a), 668.54(b)(1)(ii) and (iii)] [Guidance issued 03/13/2012; revised 12/08/2017]

VER-Q8. How should an institution proceed if a selected applicant receives unsubsidized student financial assistance during the first half of the award year, but is later awarded subsidized student financial assistance (i.e., FWS or Perkins Loans) for the second half of the award year?

VER-A8. The institution is not required to complete verification during the first half of the award year because the applicant was only receiving aid under the unsubsidized student financial assistance programs. However, once the institution awarded the applicant subsidized student financial assistance in the second half of the award year, the institution must complete verification for the entire award year according to the new verification regulations. [Sections 668.51(a), 668.54(b)(1)(ii) and (iii)] [Guidance issued 03/13/2012]

VER-Q9. Because graduate students are ineligible for need-based Title IV grants and will no longer be eligible to receive subsidized Direct Loans, are there any conditions under which graduate students' FAFSA information will need verification?

VER-A9. Since graduate students remain eligible for subsidized Title IV aid in the form of FWS and Perkins Loans, if the institution participates in one or both of those programs it is likely that at least some graduate students will need to be verified. Verification would be required if, under the institution's awarding policy for FWS and/or Perkins, the graduate student would be awarded aid under those programs. [Sections 668.51(a), 668.54(b)(1)(iii), 34 CFR 674.10(a)(1) and 34 CFR 675.10(a)] [Guidance issued 03/13/2012]

VER-Q10. Is it acceptable under an institution's FWS and Perkins awarding policy to exclude graduate students from consideration for those programs or to consider graduate students for those programs only after such assistance has been offered to eligible undergraduate students?

VER-A10. No. An institution is not allowed under its packaging policies to exclude eligible graduate students from consideration for assistance under the FWS or Perkins Loan programs or to consider eligible graduate students for assistance under those programs only after such assistance has been offered to eligible undergraduate students. The regulations provide that assistance under the FWS and Perkins Loan programs must be made reasonably available to all eligible students, including graduate students. [Sections 34 CFR 674.10(a)(1) and 34 CFR 675.10(a)] [Guidance issued 03/13/2012]

VER-Q11. May an institution disburse unsubsidized Title IV student aid, i.e., Direct Unsubsidized Loans and PLUS Loans, prior to completing verification for a selected applicant who is eligible for both subsidized and unsubsidized Title IV student aid?

VER-A11. Except for applicants who are in Verification Tracking Group V4 or V5, an institution may, on a case by case documented basis, disburse unsubsidized Title IV aid to those applicants who are selected for Verification Tracking Group V1 if the institution has determined that there will be a delay in the completion of verification. When determining the amount of the unsubsidized aid to be disbursed, the institution must ensure that the subsidized aid the applicant is estimated to receive is considered. After verification is completed, the institution must ensure that both the subsidized assistance and the unsubsidized assistance are adjusted, if necessary. Also refer to Electronic Announcement dated October 31, 2016. [Sections 668.51(a)] [Guidance issued 10/10/2012; revised 12/08/2017]

VER-Q12. Can an institution determine which of its staff are authorized to review the identity of an applicant selected for verification groups V4 or V5?

VER-A12. Archived

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Introductory Verification Questions (IVQ)

IVQ-Q1. What is the effective date of the new regulations on the verification and updating of student aid application information for applicants who receive subsidized student financial assistance?

IVQ-A1. Archived

IVQ-Q2. What are the subsidized and unsubsidized student financial assistance programs?

IVQ-A2. Archived

IVQ-Q3. What is the impact on the Department's verification selection when FAFSA corrections are made by a financial aid administrator (FAA) or by a student?

IVQ-A3. If the Department did not select the student for verification on an earlier transaction, subsequent corrections could result in the student being selected for verification since the corrected record will be reassessed in the verification selection process. However, if the correction is the result of professional judgment by the FAA (assuming the FAA properly flagged the correction as being made under professional judgment), the record will not go through verification selection again.

If the Department selected the student for verification on the earlier transaction, every subsequent transaction for that award year will indicate that the student is selected for verification, even a transaction that was the result of professional judgment. Prior to making professional judgment adjustments, an institution is required to complete verification when the student's FAFSA information has been selected for verification by the Department or the institution. (Section 668.56) [Guidance issued 03/13/2013; revised 7/7/2015]

IVQ-Q4. Will the Verification Tracking Group to which the student had been initially assigned ever change as a result of subsequent corrections?

IVQ-A4. Archived

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Applicants Selected for Verification by the Department (DS)

DS-Q1. May an institution require an applicant who was selected for verification by the Department to verify other FAFSA information in addition to those items identified by the Department for the award year?

DS-A1. Archived

DS-Q2. When an applicant is not selected for verification by the Department on the applicant's initial transaction, is it possible for that applicant to be selected for verification by the Department on a subsequent transaction?

DS-A2. Archived

DS-Q3. May an institution require an applicant selected for verification by the Department to submit a tax transcript and only accept a signed copy of the income tax return if the applicant is unable to obtain the tax transcript?

DS-A3. An institution may request a copy of a tax return transcript in lieu of a signed copy of an income tax return but not require it.  However, if an institution has concerns about the validity of the income tax return submitted, it may require a tax return transcript or any other documentation specified in the annual Federal Register notice.  The institution must document the reason why the income tax return was not acceptable.  (Sections 668.54(a), 668.56 and 668.57) [Guidance issued 11/19/2019]

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Applicants Selected for Verification by the Institution (IS)

IS-Q1. May an institution select applicants for verification other than those selected by the Department?

IS-A1. Archived

IS-Q2. Must an institution require an applicant it selects for verification to verify all of the FAFSA information identified by the Department for the award year? Must the institution comply with the "acceptable documentation" requirements for the FAFSA information it selects for verification?

IS-A2. Archived

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Verification Items (VI)

VI-Q1. Are tax filers who filed or will file a tax return required to verify income earned from work?

VI-A1. No. Tax filers who filed or will file a tax return are not required to verify income earned from work. (Section 668.56) [Guidance issued 01/26/2012]

VI-Q2. Are institutions required to verify the receipt of - Supplemental Nutrition Assistance Program (SNAP) – Food Stamps - benefits that was reported on a verification worksheet or other documentation at the institution, but not reported on the applicant's FAFSA?

VI-A2. Archived

VI-Q3. Must an institution require an applicant selected for verification to verify receipt of SNAP benefits (food stamps) if the applicant or someone in the applicant's household, or if applicable, the applicant's parent's household, also reported receipt of one of the other means-tested federal benefits that would make the applicant eligible for one of the alternate EFC calculations?

VI-A3. Archived

VI-Q4. How are distributions from an Individual Retirement Account (IRA) handled by the FAFSA-IRS Data Retrieval Tool, and how should a school address any portion of such a distribution that is "rolled over" into another qualified IRA? How are distributions from pensions and other annuities treated?

VI-A4. Archived

VI-Q5. Must an institution complete verification of all FAFSA information identified by the Secretary in the July 13, 2011, Federal Register notice for selected applicants who are eligible for either of the alternate expected family contribution (EFC) calculations: Automatic Zero EFC (Auto Zero EFC) or Simplified Needs Test (SNT)?

VI-A5. Archived

VI-Q6. Are institutions required to verify the payment of Child Support that was reported on a verification worksheet or other documentation at the institution, but not reported on the applicant's FAFSA?

VI-A6. Archived

VI-Q7. Must an institution complete verification of all FAFSA information identified in Verification Tracking Groups V1 or V5 even if the selected applicant is eligible for either of the alternate expected family contribution (EFC) calculations: Automatic Zero EFC (Auto Zero EFC) or Simplified Needs Test (SNT)?

VI-A7. Archived

VI-Q8. What is the language in the "Statement of Educational Purpose" that institutions must use for students placed in Verification Tracking Groups V4 or V5?

VI-A8. Archived

VI-Q9. Must an institution complete verification of all FAFSA/ISIR information identified in Verification Tracking Groups V1, V4, V5 or V6, even if the selected applicant is eligible for either of the alternate expected family contribution (EFC) calculations: Automatic Zero EFC (Auto Zero EFC) or Simplified Needs Test (SNT)?

VI-A9. Archived

VI-Q10.  What FAFSA/ISIR information must be verified if an institution receives an ISIR with an IRS Request Flag value of 07?

VI-A10.  An IRS Request Flag with a value of 07 indicates that the applicant or parent filed an amended tax return. Therefore, if an institution receives an ISIR with an IRS Request Flag value of 07, it must contact the applicant to obtain the documentation needed to make changes to any of the FAFSA/ISIR data items that were amended, regardless of whether those items are required to be verified.   [Guidance issued 12/08/2017; and applies beginning with the 2018-2019 FAFSA processing year]

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Updating Applicant's FAFSA Information (UPD)

UPD-Q1. When an FAA updates an applicant's marital status "to address an inequity or to reflect more accurately the applicant's ability to pay" under §668.55(c), what other information must also be updated?

UPD-A1. Usually when the applicant's marital status changes, there is no updating of the applicant's dependency status or, for applicants selected for verification, household size or number in college. However, under §668.55(c), an FAA may update the applicant's FAFSA information due to a change in the applicant's marital status if the FAA determines it is necessary to address an inequity or to reflect more accurately the applicant's ability to pay.

If an FAA chooses to exercise the authority allowed under §668.55(c), all relevant FAFSA information must be updated to be consistent with the new marital status, including the spouse's financial information, for applicants whose dependency status changes, or for applicants who are selected for verification. The FAA updates these applicants' marital status on a case-by-case basis and must document the reason for the decision.

Likewise, for an applicant who was independent only because he or she was married when the FAFSA was first completed, if the FAA changes the applicant's marital status to unmarried, making the applicant dependent, the FAFSA must be updated with parental information. [Section 668.55(c)] [Guidance issued 01/26/2012; revised 03/13/2012]

UPD-Q2. What happens when a change to an applicant's marital status is made?

UPD-A2. When an applicant's marital status is updated, the Department's Central Processing System (CPS) will reject the resulting transaction. The FAA may use FAA Access to CPS Online to enter an FAA-only reject override that will result in a new transaction with the updated dependency status. [ISIR Guide] [Guidance issued 03/13/2012; revised 04/04/2014]

UPD-Q3. If an applicant changes his or her marital status on the FAFSA and the institution agrees with the change by overriding the reject, must the institution recalculate the applicant's need-based aid based on the new Expected Family Contribution (EFC)?

UPD-A3. Archived

UPD-Q4. If an institution decides to update a student’s marital status, must it first complete verification if the student had been selected for verification under the current marital status?

UPD-A4. No. This is not a case of an institution having to perform verification before making professional judgment changes to the FAFSA. If an institution determines that updating a student’s marital status is warranted—i.e., necessary to address an inequity or to reflect more accurately the applicant’s ability to pay—it should change the student’s marital status and other relevant data first and then complete verification of the updated application, which would include verifying the information of the student’s spouse or parents, as appropriate. [Guidance issued 09/03/2014]

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Acceptable Documentation for FAFSA Information Selected for Verification (DOC)

DOC-Q1. How can the IRS Data Retrieval Process be used to satisfy the verification requirement if the tax filer has not filed an income tax return at the time of completing the FAFSA?

DOC-A1. Archived

DOC-Q2. What documentation must be collected from an applicant who was selected for verification if the applicant and/or spouse, or parent(s) filed an amended tax return with the IRS?

DOC-A2. Archived

DOC-Q3. May an applicant have an IRS Tax Return Transcript sent directly to a college or university?

DOC-A3. Archived

DOC-Q4. May an institution decide what documentation is acceptable for its institutionally selected applicants?

DOC-A4. Archived

DOC-Q5. Is the information provided on a verification worksheet or other documentation at the institution sufficient to verify household size, number in college, or income earned from work for nontax filers; since the applicant signs the verification worksheet or other documentation submitted to the institution acknowledging that the information is correct?

DOC-A5. A verification worksheet or other documentation at the institution may serve as the signed statement to verify household size, number in college, or income earned from work for nontax filers, as long as the worksheet or other documentation has a certification statement similar to what is included on the Department's suggested verification text. An institution is not required to use the suggested verification text developed by the Department. It may use its own worksheet or require other documentation. [Guidance issued 01/26/2012; revised 12/08/2017]

DOC-Q6. What documentation must be collected from an applicant who was selected for verification and whose Institutional Student Information Record (ISIR) shows receipt of Food Stamps – Supplemental Nutrition Assistance Program (SNAP)?

DOC-A6. Archived

DOC-Q7. For verification of nontax filer wages, are institutions required to collect both the W-2(s) from all employers and the signed statement certifying that the individual has not filed and is not required to file an income tax return, listing all income and sources?

DOC-A7. Archived

DOC-Q8. For verifying child support paid, please clarify whether the institution is required to obtain the signature of the person who paid the child support?

DOC-A8. Archived

DOC-Q9. May an institution accept or make a copy of an IRS transcript that was originally obtained from the IRS?

DOC-A9. Archived

DOC-Q10. May an institution use a Record of Account Transcript, a Return Transcript for Taxpayer (RTFTP), or an Information Returns Processing Transcript Request - Wages (IRPTR-W) provided by the IRS to meet the verification requirements?

DOC-A10. Archived

DOC-Q11. In some cases, tax filers who have visited an IRS field office have been provided with a copy of their IRS tax return stamped "official" in lieu of an IRS Tax Return Transcript. May an institution use an IRS tax return that has been stamped "official" by the IRS as a substitute for an IRS Tax Return Transcript to meet the verification requirements?

DOC-A11. Archived

DOC-Q12. May an institution meet the signature requirements for verification documentation submitted by an applicant, parent or spouse through an electronic process?

DOC-A12. For verification documentation purposes, an institution may collect an electronic signature for an applicant, parent or spouse if the process for obtaining the electronic signature includes assurances that the person providing the electronic signature is the person whose signature is being collected. Often, this is accomplished through a PIN or password process where the PIN or password has been assigned only after authentication of the identity of the person to whom the PIN or password is assigned. [Guidance issued 06/21/2012]

DOC-Q13. Is there an instance when an IRS Request Flag code of "02" would not carry forward to a subsequent transaction?

DOC-A13. Archived

DOC-Q14. What tax information should an institution use when both the IRS Data Retrieval Tool is used and an IRS Tax Return Transcript is obtained?

DOC-A14. Archived

DOC-Q15. What documentation is required for an applicant, parent or spouse who is the victim of identity theft and, as a result, is unable to use the IRS Data Retrieval Tool or obtain an IRS Tax Return Transcript until the matter has been resolved by the IRS?

DOC-A15. Archived

DOC-Q16. May an institution require an individual who has been granted a tax filing extension by the IRS to use the IRS Data Retrieval Tool (IRS DRT) or obtain an IRS Tax Return Transcript before completing verification? Must the tax return information be submitted to the institution after the income tax return has been filed?

DOC-A16. Archived

DOC-Q17. Can an institution rely on documentation of a student's high school completion status or documentation that a student has the equivalency of a high school diploma that it collected for purposes other than completing verification to verify a student's high school completion status?

DOC-A17. Archived

DOC-Q18. Must an institution complete verification for students placed in verification groups V4 or V5 who are only eligible for unsubsidized student financial assistance?

DOC-A18. An institution should verify identity/statement of educational purpose for a student who is only eligible for unsubsidized student financial assistance and who was placed in Verification Tracking Groups V4 or V5. This will help ensure that only eligible students receive aid and will improve the integrity of the Title IV, HEA programs. Institutions need not verify any of the other FAFSA information listed under Verification Tracking Group V5 for such students. [Guidance issued 04/25/2013; revised 3/10/2023]

DOC-Q19. Are high school diplomas from other countries acceptable documentation to verify a student's high school completion status?

DOC-A19. Archived

DOC-Q20. What must institutions collect when a student established Title IV eligibility under one of the ability-to-benefit (ATB) alternatives but is selected under verification groups V4 or V5 to verify the student's high school completion status?

DOC-A20. Archived

DOC-Q21. After a tax filer uses the IRS Data Retrieval Tool (IRS DRT) and the ISIR shows an IRS Request Flag code of '02' (IRS data were imported to the FAFSA and not changed), he or she makes a correction to one or more of the items that were imported (e.g., the amount for Untaxed IRA Distributions). The resulting CPS transaction would no longer have an IRS Request Flag code of '02'. Does the institution need to require the student to submit an IRS Tax Return Transcript to verify all of the IRS-related verification items, or can it use the original unchanged values and only verify the changed value?

DOC-A21. Archived

DOC-Q22. Is further verification needed to resolve differences between what was included on the ISIR and what the student provided as part of the verification process?

DOC-A22. No, unless the institution has reason to believe that the information provided on a verification document is inaccurate. When an institution obtains acceptable documentation for a verification item, that documentation will either confirm that the information on the ISIR is correct or be used to make changes to the ISIR. For example, if upon reviewing an IRS Tax Return Transcript, the institution finds that the AGI amount from the transcript differs from what was reported on the FAFSA and shown on the ISIR, the institution simply submits a change to the CPS (or directs the student to do so). The institution need not attempt to determine the reason for the difference. [Guidance issued 05/02/2014]

DOC-Q23. What is IRS identity theft for purposes of submitting the alternative verification documentation discussed in Dear Colleague Letter GEN-13-16 posted to IFAP on June 13, 2013 and in Dear Colleague Letter GEN-14-05 posted to IFAP on March 25, 2014?

DOC-A23. IRS identity theft is identity theft that has affected a tax filer’s IRS tax records. The IRS refers to this as Tax Administration Identity Theft. This occurs most often when someone other than the tax filer files a tax return using the tax filer’s identifiers – usually to fraudulently receive a tax refund. The tax filer may be the first to identify the identity theft or the IRS may be the first to suspect that there has been Tax Administration Identity Theft. Only a determination by the IRS of a “Tax Administration Identity Theft” is applicable for purposes of completing verification for Federal student aid eligibility.

While the IRS may acknowledge Non-Tax Administration Identity Theft, such an acknowledgement is not applicable for verification. Examples of a Non-Tax Administration Identity Theft are identity thefts that are a result of a privacy breach at a bank, credit card company, retail or web business, or because of lost or stolen identity documents. Victims of Non-Tax Administration Identity Thefts, even if reported to the IRS, may not submit the alternative documentation discussed in Dear Colleague Letters GEN-13-16 and GEN-14-05 to complete verification. [Guidance issued 09/03/2014]

DOC-Q24. If, prior to the March 25, 2014, release of the 2014-2015 identity theft guidance provided in Dear Colleague Letter GEN-14-05, an institution completed verification for 2014-2015 using the identity theft guidance provided in Dear Colleague Letter GEN-13-16, must the institution re-verify the student for 2014-2015 following the guidance in Dear Colleague Letter GEN-14-05?

DOC-A24. Archived

DOC-Q25. If a student who reported an item on the FAFSA, such as SNAP or child support, then later informs the institution that he or she did not receive the item, must an institution obtain documentation from the student confirming non-receipt of that item?

DOC-A25. Archived

DOC-Q26. Is a government-issued photo identification that is not compliant with the REAL ID Act of 2005, e.g., one marked “not for federal identification,” acceptable documentation for an applicant selected to verify identity/statement of educational purpose?

DOC-A26. Archived

DOC-Q27. What documentation is required for an applicant, parent or spouse who is the victim of IRS tax-related identity theft?

DOC-A27. Archived

DOC-Q28. Institutions may only accept a signed copy of a non IRS income tax return for tax filers who are unable to obtain a free copy of their tax account information. Which tax authorities charge a fee to obtain this information?

DOC-A28. The tax authorities for Guam, the Commonwealth of the Northern Mariana Islands, the Commonwealth of Puerto Rico and the U.S. Virgin Islands charge a fee to obtain tax account information. Therefore, a tax filer who filed an income tax return with these tax authorities may provide institutions with a signed copy of his or her income tax return that was filed with the relevant tax authority. However, if the institution questions the accuracy of the information on the signed copy of the income tax return, the tax filer must provide the institution with a copy of the tax account information issued by the relevant tax authority before verification can be completed.

A tax filer who filed an income tax return with the Internal Revenue Service or the tax authority for American Samoa must provide institutions with a copy of his or her tax account information if selected for verification since these tax authorities do not charge a fee to obtain this information.

A tax filer who filed an income tax return with tax authorities not mentioned above, i.e. a foreign tax authority, and who indicates that he or she is unable to obtain the tax account information free of charge, must provide the institution with documentation that the tax authority charges a fee to obtain that information, along with a signed copy of his or her income tax return that was filed with the relevant tax authority. [Guidance issued 6/7/2016]

DOC-Q29. Since a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number is required to obtain a verification of nonfiling from the IRS, how can a nontax filer without one of these identifiers meet the verification requirement to obtain confirmation of nonfiling from the IRS?

DOC-A29. We are aware of circumstances where one or both of the parents of a dependent student or the spouse of an independent student does not have a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number and therefore is unable to obtain a verification of nonfiling from the IRS. Individuals in these cases and whose income is below the IRS filing threshold must submit to the institution:

  • A signed and dated statement--
    • Certifying that the individual(s) does not have a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number; and
    • Listing the sources and amounts of earnings, other income, and resources that supported the individual(s) for the appropriate tax year; and
  • If applicable, a copy of IRS Form W–2 for each source of employment income received for the appropriate tax year or an equivalent document.

Note: Individuals who submit W-2s that total a gross income that equals or exceeds the IRS tax filing threshold must request a Social Security Number, an Individual Taxpayer Identification Number, or an Employer Identification Number and file an income tax return before the student is eligible to receive Title IV aid. [Guidance issued 10/6/2016; and applies beginning with the 2017-2018 award year]

DOC-Q30. The Department has provided guidance on how to obtain verification of non-filing from the IRS. What do individuals who are subject to foreign tax authorities do?

DOC-A30. If another tax authority can provide documentation similar to the IRS that indicates the individual did not file taxes for the appropriate tax year, we expect the individual to request such documentation and provide it to the institution. If such documentation does not exist, or if the individual is unable to obtain the documentation, the institution may accept a signed and dated statement from the individual stating either that the tax authority does not provide such documentation or that the individual was unable to obtain the documentation after contacting the tax authority.

Since nontax filers selected for verification are already required to provide a signed and dated statement related to their claim of being a nonfiler, those nontax filers may also include in that statement the attestation specified above. [Guidance issued 1/13/2017; and applies beginning with the 2017-2018 award year]

DOC-Q31. Must an institution collect documentation of an applicant’s high school completion status for graduate students placed in Verification Tracking Groups V4 or V5?

DOC-A31. An institution is not required to collect proof of high school status if admission into the graduate program requires the completion of at least two years of undergraduate coursework as provided in Q&A RED-Q1/A1. [Guidance issued 1/13/2017]

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Changing Applicant's FAFSA Information (CHD)

CHD-Q1. Is an institution required to submit changes to a FAFSA dollar item that is less than $25 if the institution has to submit a change to a nondollar item? What if the other item is a dollar item where the change is $25 or more?

CHD-A1. Yes. If an institution is required to submit any change as a result of verification it must submit all changes. For example, if there is a change in number of family members and also a change in the Education Credit amount of only $15, the institution must submit both changes to the CPS even though the difference in the amount of the Education Credit is less than the $25 tolerance. Likewise, if, for example, the difference for AGI is $100, and the difference for taxes paid is $20, the institution must submit both the AGI and the taxes paid changes, not just the AGI change that exceeded the $25 tolerance. [Section 668.59] [Guidance issued 06/21/2012]

CHD-Q2. Since IRA rollovers are not reflected on the IRS Tax Return Transcript or transferred into an online FAFSA using the IRS Data Retrieval Process, is changing the FAFSA to reflect the rollover exclusion a "correction," an "update" or "professional judgment?"

CHD-A2. Archived

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Identity Verification (IDV)           

IDV-Q1: If a student is selected for V4 or V5 verification for the 2025-26 award year but the institution has not yet fully disbursed the student’s 2024-25 aid, is the school required to wait for verification to be completed for the 2025-26 award year before disbursing 2024-25 aid?

IDV-A1: No. However, if a student has been selected for V4 or V5 verification for the 2025-26 award year and the school has not yet completed disbursements for the 2024-25 award year, we encourage the school to delay disbursing any remaining 2024-25 award year funds until V4 verification or the identity component of V5 verification has been completed. Though verification is award year-specific, issues with the student’s identity could impact all Title IV disbursements across all award years. 

If the student’s identity is confirmed and is otherwise eligible for Title IV aid, the school may make all appropriate disbursements from either award year.  If the student does not complete verification (fails to provide documentation, withdraws before completing verification, etc.) but there is no indication of fraud, the student would not be eligible for any Title IV funds for the 2025-26 award year but could receive any remaining 2024-25 funds as long as all the late disbursement requirements are met. Please note that failing to complete verification should not be treated the same as identity fraud that is confirmed.

However, if a school has unresolved conflicting information or determines with certainty that a student has falsified their identity or is otherwise not eligible for Title IV aid, it must not make any disbursements of Title IV, HEA funds to the student or on their behalf. In the case of confirmed fraud or student ineligibility, the school must treat any disbursements already made on behalf of such an individual as overpayments and follow the process in Volume 4, Chapter 3 of the Federal Student Aid Handbook under Treatment of Overpayments [Guidance issued 7/21/2025; revised 9/10/2025]

IDV-Q2: Can you confirm that institutions may accept any one of the methods listed under the Changes to Identity Confirmation Requirements for V4 and V5 Verification section in the Electronic Announcement (APP-25-16) to verify an applicant’s identity?

IDV-A2: For the most part, yes. However, as noted in APP-25-16, the video call and notary methods are only available if the institution determines that an applicant is unable to appear in person to present an unexpired, valid, government-issued photo identification. We encourage in-person verification as the preferred method, but if the school determines that a student is unable to appear in person, it can continue to use the signed notary statement option or it can use the new method of having a video call between the student and institutional personnel. The other new method is for the school to obtain documentation that the student had his or her identity verified by a third party using a method satisfying the National Institute of Standards and Technology (NIST) Identity Assurance Level 2 (NIST IAL2) standard. Unlike with the video call, the NIST IAL2 option may be used even if the student can appear in person to validate identity.  [Guidance issued 7/21/2025] 

IDV-Q3: Can you confirm that verification by an NIST IAL2-compliant entity fully satisfies an institution’s obligations for identity verification?

IDV-A3: Yes. As of June 6, 2025, satisfying the NIST IAL2 standard is one of the acceptable methods institutions can use to verify an applicant’s identity. To use the NIST IAL2 method, the institution must receive documentation directly from the third party confirming:

  1. The identity of the student—i.e., that the school and third party are referring to the same person; 
  2. The date verification took place; and
  3. The student’s identity is verified under the NIST standard.  [Guidance issued 7/21/2025] 

IDV-Q4: Does the guidance in APP-25-16 supersede state law restrictions on retaining biometric data? If not, are institutions in these states required to obtain a scanned copy (electronic or hardcopy) of the identification and document the name of the authorized representative who reviewed it?

IDV-A4: Our guidance does not intend to supersede state law restrictions. If there is a law imposing restrictions of screen capture in an institution’s state, then the institution could choose not to use the video call method to verify a student’s identity and instead use one of the other three methods mentioned above. You may want to consult your legal counsel about the advisability of the video call option.  [Guidance issued 7/21/2025]

IDV-Q5: What is NIST IAL2 and how does it work?

IDV-A5: NIST IAL2 stands for the National Institute of Standards and Technology Identity Assurance Level 2.  NIST IAL2 is a framework for confirming an individual’s ownership of a genuine identity. Under this framework, to verify an individual’s identity a service provider collects three types of data from the individual: personal information (e.g. name, address, or date of birth), identity evidence (i.e. a driver’s license or passport), and, if applicable, a biometric characteristic (e.g. a photo or video taken in real-time). The service provider then confirms that the personal information is consistent with a genuine identity, authenticates the evidence, and verifies the individual is the true owner of the claimed identity. For more information, please refer to NIST's digital identity guidelines on IAL2 at https://pages.nist.gov/800-63-3-Implementation-Resources/63A/ial2remote. [Guidance issued 8/10/2026] 

IDV-Q6: Which IAL2 service provider may an institution use to verify a student’s identity? 

IDV-A6: Institutions must use a service provider that adheres to the NIST IAL2 standards. The Department recognizes the Kantara Initiative’s Trust List as one way to find NIST-compliant service providers; however, institutions are not limited to using only this list of providers. Institutions may use other service providers as long as they have documentation proving that they meet the NIST IAL2 standards. [Guidance issued 8/10/2026] 

IDV-Q7: What are the documentation requirements for institutions using NIST IAL2 to verify a student’s identity?

IDV-A7: The institution must receive an email directly from the service provider confirming that the student's identity was verified under the NIST IAL2 standards and the date the verification took place. If an institution chooses to use one of the service providers on the Kantara Initiative’s Trust List, no additional documentation of general compliance with the NIST IAL2 standards is necessary. However, if an institution chooses to use a service provider that is not on the Kantara Initiative’s Trust List, the service provider must provide the institution with a third-party audit or a self-assessment that verifies their security controls and policies align with the NIST IAL2 standards. [Guidance issued 8/10/2026] 

Program Integrity Q&A | Verification-Archived Guidance

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Page Last Reviewed:
August 10, 2026