Verification Recap and a Look Ahead from FSATC 2021

By Rick Cox

The FUTURE Act, which will help simplify the application for college student aid, allows data sharing between the U.S. Department of Education and the Internal Revenue Service. The requirements of this act will be implemented in phases until full implementation is achieved in the 2024-2025 award year.

Dear Colleague Letter GEN-21-05 waived most of the verification items for 2021-2022. The department chose to focus on identity and fraud for the remainder of the award year. This shift provided colleges with administrative relief so efforts could be focused on disbursing emergency aid and exercising professional judgments to ensure the student’s awards properly reflected their economic situation.

For the 2022-2023 award year, verification is back to normal except high school completion status, which is no longer a required verification item.

Colleges and universities are still required to report verification results for applicants selected for V4 and V5. The Department of Education has updated the reporting options for this to remove high school completion status for 2022-2023.

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Traditionally, the department selected about 30 percent of all applicants for verification. In 2018, the department conducted a cost-benefit analysis and determined that the appropriate number to select was about 22 percent. This analysis was updated in 2020 and it was determined that 18 percent was the appropriate number for selection for verification. The verification waiver applicable to the 2021-2022 award year reduced the number verified to 3 percent to 4 percent.

The department is still reviewing verification requirements for 2022-2023 to determine if any adjustments will need to be made. Additionally, the department will look at long-term changes that need to be made to the selection criteria to ensure the verification process is strong and equitable.

The Department of Education’s Machine Learning Model is retrained every year.

Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance.