A Comprehensive Guide to Verification for 2023-2024
Verification has returned for 2023-2024 after a year of waivers and reinstatements that were part of the effort to ease hardships from COVID-19
By Rick Cox
On July 8, 2022, the U.S. Department of Education published the Federal Register and Dear Colleague Letter GEN-22-09 to announce verification requirements for the 2023-2024 award year, which remain the same as they did when originally published for 2022-2023.
The department published DCL GEN-22-06 on May 8, 2022, to announce that most verification requirements would be waived for the remainder of the 2022-2023 award year. The only verification requirements remaining in effect for 2022-2023 are identity/statement of educational purpose.
This waiver does not apply to 2023-2024. However, COVID waivers published in 2020 still apply through the end of the payment period that begins after the date on which the federally declared COVID-19 emergency is rescinded. The COVID waivers published in 2020 do not waive verification requirements but do allow some flexibility. To review those flexibilities, please see the summary published by the Department of Education on January 15, 2021, which also provides the reference documents.
This is a comprehensive guide to verification for 2023-2024. Verification groups and required items will remain the same as 2022-2023. If the waivers are extended again and are applicable to the 2023-2024 award year, Global will post information on those waivers.
As a reminder, colleges must report the results of verification of identity for applicants selected for groups V4 and V5. This information is reported on the FAA Access to CPS Online website and is only reported for those applicants selected by the Department of Education. Colleges should not report these results for applicants they select for verification. The results need to be reported within 60 days after your first request for verification documentation. If you need to make a change to previously reported information, the change should be reported within 30 days. You are not able to review information previously submitted. Therefore, to document compliance with this process you need to print the confirmation page at the time the reporting is performed.
These items should be verified for 2023-2024 for each verification group:
V1
Household Size
Number in College
Tax Filers
· Adjusted Gross Income – 1040 Line 11
· U.S. Income Tax Paid – 1040 Line 22 minus Schedule 2 Line 2
· Untaxed Portions of IRA Distributions and Pensions – 1040 (lines 4a+5a) minus (4b+5B)
· IRA Deductions and Payments – Schedule 1 Lines 15+19
· Tax Exempt Interest Income – 1040 Line 2a
· Education Tax Credits – Schedule 3 Line 3
Non-Filers
· Income Earned from Work *
V4
Identity/Statement of Educational Purpose **
V5
Household Size
Number in College
Identity/Statement of Educational Purpose **
Tax Filers
· Adjusted Gross Income – 1040 Line 11
· U.S. Income Tax Paid – 1040 Line 22 minus Schedule 2 Line 2
· Untaxed Portions of IRA Distributions and Pensions – 1040 (lines 4a+5a) minus (4b+5B)
· IRA Deductions and Payments – Schedule 1 Lines 15+19
· Tax Exempt Interest Income – 1040 Line 2a
· Education Tax Credits – Schedule 3 Line 3
Non-Filers
· Income Earned from Work *
*Non-filers must provide a non-filer certification and a W-2 for each source of 2021 employment income received or an equivalent document. Additionally, non-filers must provide confirmation of non-filing status from the IRS or other relevant taxing authority dated on or after October 1, 2022. However, the confirmation of non-filing status is not required for a dependent student, but this still applies to the parents of the dependent student.
**One requirement for applicants placed in group V4 or V5 is to verify their identity by providing the college with an unexpired valid government-issued photo identification. For this purpose, any unexpired valid government-issued photo identification is one that is issued by the U.S. government, any of the 50 states, the District of Columbia, the Commonwealth of Puerto Rico, a federally recognized American Indian and Alaska Native Tribe, American Samoa, Guam, the Virgin Islands, the Commonwealth of the Northern Mariana Islands, the Republic of the Marshall Islands, the Federated States of Micronesia, or the Republic of Palau.
The language used for the Statement of Educational Purpose must be exactly the same as the language provided in the Federal Register.
Special Circumstances
Tax-Related Identity Theft
An individual who was the victim of IRS tax-related identity theft must provide:
· A tax return database view (TRDBV) transcript obtained from the IRS; and
· A statement signed and dated by the tax filer indicating he or she was a victim of IRS tax-related identity theft and that the IRS has been made aware of the theft
Tax filers may obtain the TRDBV by calling the IRS’s Identity Protection Specialized Unit at 1-800-908-4490. Tax filers who cannot obtain a TRDBV transcript may instead submit another official IRS transcript or equivalent document provided by the IRS if it includes all the income and tax information required to be verified. Tax filers unable to obtain the TRDBV or other official IRS document are permitted to submit a signed copy of the tax return that was filed with the IRS, including any applicable schedules.
Amended Returns
An individual who filed an amended return must provide a signed copy of the IRS 1040X that was filed with the IRS along with one of the following:
· A transcript obtained from the IRS that lists 2021 tax account information
· IRS DRT data that was transferred and not changed; or
· A signed copy of the paper return, including any applicable schedules
In some cases, the tax filer may not have filed a 1040X but an 07 flag is noted on the ISIR as a result of the IRS making changes. In cases of changes made by the IRS, the college can accept a copy of the IRS’s notification to the tax filer of the changes that were made instead of a 1040X. The college must still collect one of the items listed above.
Filing Extensions
An individual required to file a 2021 tax return and granted a filing extension by the IRS beyond the automatic six-month extension must provide:
· A signed certification that the individual has not yet filed a 2021 income tax return and list all sources of any 2021 income and the amount from each source
· A copy of the IRS’s approval of the extension
· Confirmation of non-filing from the IRS dated on or after October 1, 2022
· A copy of IRS Form W-2 for each source of 2021 employment income received or an equivalent document; and
· If self-employed, a signed statement certifying the amount of AGI and U.S. income tax paid for the tax year 2021
Please note: For an individual called up for active duty or for qualifying National Guard duty during a war or other military operation or national emergency, an institution must accept a statement from the individual certifying that he/she has not filed an income tax return or a request for a filing extension because of that service.
Joint Tax Returns When Only One Filer’s Income is Used on the FAFSA
If a tax filer files a joint tax return but is now separated, divorced, widowed, or married to someone other than the individual included on the 2021 joint tax return, the filer must provide:
· A tax return transcript or signed copy of the tax return and applicable schedules that were filed with the IRS or other relevant tax authority; and
· A copy of IRS Form W-2 for each source of 2021 employment income received or an equivalent document
Non-Filer Confirmation from the IRS or Other Relevant Tax Authority
If a non-filer is unable to obtain the required verification of non-filing status from the IRS or other tax authority, the college may accept a statement from the non-filer that they attempted to obtain the non-filing verification but were unable to obtain the required documentation.
Non-filers who do not have an SSN, ITIN or EIN are unable to obtain confirmation of non-filing status from the IRS. These individuals are permitted to submit a signed and dated statement certifying they do not have an SSN, ITIN or EIN and a list of all sources and amounts of earning, other income and resources that supported the individual for the 2021 tax year. However, this will only be acceptable if their taxable income is below the IRS filing threshold.
Verification for Applicants Eligible Only for Unsubsidized Aid
Under certain circumstances an applicant may be excluded from verification. Exclusions are provided in 668.54(b). One exclusion pertains to applicants who are only eligible for unsubsidized aid. Per this regulation, verification would not be required for these applicants. However, the department has indicated that for applicants only eligible for unsubsidized aid who are selected for groups V4 or V5, the college should verify identity/statement of educational purpose. You would not need to verify any other items included in verification for group V5 for these applicants. Although verification is not required for these applicants, the department believes verification of identity will help ensure that only eligible students are receiving federal student aid. For information on this issue, please see the regulation cited above as well as the verification section of the Program Integrity Information Page Q&A on IFAP – VER-Q6/A6 and DOC-Q18/A18. This is the direct link to the Q&A for verification.
Although this is not required from a regulatory standpoint, Global believes verifying this item for these students is a good practice.
To access the Federal Register for 2023-2024 verification, please click here.
To access DCL GEN-22-09, please use this link.
Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance