Verification Returns for 2022-2023

Only high school completion status will not be a verification item; FAFSA information to be verified for the 2022-2023 award year

By Rick Cox

On September 1, 2021, the Department of Education announced that verification requirements will return for the 2022-2023 award year. This is a comprehensive article on verification for 2022-2023.

Verification requirements for 2022-2023 will be mostly the same as they were before the verification waiver provided by the Education Department on July 13, 2021. However, for 2022-2023, high school completion status is no longer a required verification item.

On July 13, the department announced that most verification requirements would be waived for the remainder of the 2021-2022 award year. The only verification requirements remaining in effect for 2021-2022 are identity/statement of educational purpose and high school completion. This waiver does not apply to 2022-2023. However, the COVID waivers previously published in 2020 still apply through the end of the payment period that begins after the date on which the federally declared emergency related to COVID-19 is rescinded.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 Education Department on January 15, 2021.

The verification groups remain the same as 2021-2022. Except for high school completion status, all other verification items remain the same as 2021-2022. If waivers are extended again and are applicable to the 2022-2023 award year, we will provide information on those waivers in a separate post.

As a reminder, colleges must report the results of verification of identity for applicants selected for groups V4 and V5. The Education Department has not provided information yet on this process for 2022-2023. It is expected that options related to high school completion status will be removed from the reporting area for the 2022-2023 award year. This information is reported on the FAA Access to CPS Online website and is only reported for those applicants selected by the Education Department. Financial Aid teams should not report these results for applicants the institution selects 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 and should print the confirmation page at the time the reporting is performed to document compliance with this process.

This outlines items to be verified for 2022-2023 for each verification group:

Household Size
Number in College

TAX FILERS

Adjusted Gross Income
U.S. Income Tax Paid
Untaxed Portions of IRA Distributions and Pensions
IRA Deductions and Payments
Tax Exempt Interest Income
Education Tax Credits

NON-FILERS

Income Earned from Work *

Identity/Statement of Educational Purpose **

Household Size
Number in College
Identity/Statement of Educational Purpose **

TAX FILERS

Adjusted Gross Income
U.S. Income Tax Paid
Untaxed Portions of IRA Distributions and Pensions
IRA Deductions and Payments
Tax Exempt Interest Income
Education Tax Credits

NON-FILERS

Income Earned from Work *

* Non-filers must provide a non-filer certification and a W-2 for each source of 2020 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, 2021. However, the confirmation of non-filing status is not required for a dependent student (but still applies to the parents of the dependent student).

** One of the requirements for applicants placed in V4 or V5 is to verify their identity by providing the institution with an unexpired, valid government-issued photo identification. For this purpose, an unexpired valid government-issued photo identification is one 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 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 tax-related identity theft

Tax filers may obtain the TRDBV by calling the IRS’s Identity Protection Specialized Unit (IPSU) 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 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 filed with the IRS, along with one of the following:

A transcript obtained from the IRS that lists 2020 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, a tax filer may not have filed a 1040X but an 07 flag is noted on the ISIR because IRS made changes. In these cases, the school can accept a copy of the IRS notification to the tax filer of the changes made by the IRS instead of a 1040X. The school must still collect one of the items listed in the three bullets above.

Filing Extensions

An individual required to file a 2020 tax return who has been granted a filing extension by the IRS beyond the automatic 6-month extension must provide:

A signed certification that the individual has not yet filed a 2020 income tax return and list all sources of any 2020 income and the amount from each source;
A copy of the IRS approval of the extension;
Confirmation of non-filing from the IRS dated on or after October 1, 2021;
A copy of IRS Form W-2 for each source of 2020 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 2020

These individuals are no longer required to submit a copy of IRS Form 4868 that the individual filed with the IRS.

Please note – An individual called up for active duty or 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 or 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 2020 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 2020 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 school 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 a 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 a SSN, ITIN, or EIN and a list of all sources and amounts of earning, other income, and resources that supported the individual for the 2020 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 – 668.54(b) provides the list of exclusions.

One exclusion pertains to applicants only eligible for unsubsidized aid. Per this regulation, verification would not be required for these applicants. However, the Education Department has indicated that for applicants only eligible for unsubsidized aid who are selected for Verification Groups V4 or V5, the school should verify identity/statement of educational purpose. You would not need to verify any of the 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 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. Click here for the direct link to the Q&A for verification.

Please click here for the Federal Register for 2022-2023 verification.

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