) changing the verification requirements for the 2021-2022 FAFSA processing and verification cycle, including eliminating the requirement for “V1” verification requirements by all higher education institutions. This is a substantial change for many institutions as ED has historically required institutions to verify income and household information when a student is selected for verification. ED notes in its press release
that it expects that relaxing verification provisions may help “approximately 200,000 more students from low-income backgrounds and students of color enroll in college and continue on the path to a degree.” ED expressed that the current verification requirements, now being waived, required verification of income data that was at times difficult to obtain for those in low-income families. At times, the barriers of providing this data prevented students from obtaining aid that they may have otherwise been eligible for had they been able to provide the proper data.
The verification changes summarized are as follows:
- Institutions are no longer required to verify students selected under the Verification Tracking Flag “V1 – Standard Verification Group."
- Institutions must still reconcile conflicting information that they have in hand, but are not required to obtain any additional information even for in progress verifications.
- Institutions maintain discretion to select students for verification in accordance with their institutional or state policy; however, ED is encouraging institutions to consider amending their policy to limit selections to provide relief to students and families during the ongoing national emergency related to the COVID-19 pandemic.
- Institutions must still complete verification for Verification Tracking Flags “V4-Custom Verification Group” and “V5-Aggregate Verification Group.”
- Institutions must verify high school completion status and identity/statement of educational purpose only.
- ED clarified that many 2021-2022 Central Processing System (CPS) transactions will continue to be selected for verification due to the swiftness of these changes. Institutions must still report a valid Verification Status Code of “V” for verified or “S” if the student met an appropriate exclusion such as this waiver.
The changes noted above are effective immediately, beginning July 13, 2021. ED specified in relation to verification changes for the 2022-2023 award year and beyond that it will “consider what adjustments need to be made to verification long-term to ensure that it is robust and equitable."
Please contact any member of the RubinBrown Colleges and Universities Group for more information.
Readers should not act upon information presented without individual professional consultation.
Any federal tax advice contained in this communication (including any attachments): (i) is intended for your use only; (ii) is based on the accuracy and completeness of the facts you have provided us; and (iii) may not be relied upon to avoid penalties.
On July 13, 2021, the Department of Education (ED) published a Dear Colleague Letter (