U.S. Citizenship & Eligible Noncitizens

A student must be one of the following to be eligible to receive federal student aid:

The Department of Education (The Department) matches all applications with the Social Security Administration (SSA) on U.S. citizenship status. If the status cannot be confirmed, the student must provide documents proving U.S. citizenship, citizenship of the Freely Associated States, or eligible non-citizen status in order to be potentially Title IV aid-eligible. If the student provides an alien registration number (ARN) on the FAFSA, his record is also sent to DHS to check noncitizen immigration status. The results of both matches appear on the Institutional Student Information Report (ISIR), and a failed match with either agency will produce a “C code” on the student’s ISIR.

A student’s U.S. citizenship (or eligible noncitizen) status only needs to be checked once for the award year; if the status is eligible at that time, it remains so for the rest of the award year (with the exception of parolees and VAWA prima facie cases; see the “Third Step Verification (Formerly Form G-845)” section below).

If a parent wants to take out a PLUS loan for a dependent undergraduate student, both the parent and the student must be a U.S. citizen, national or eligible noncitizen.

A person is a U.S. citizen by birth or by naturalization or by operation of law. Persons (except for the children of foreign diplomatic staff) born in the 50 states, the District of Columbia, and, in most cases, Puerto Rico, the U.S. Virgin Islands, Guam, and the Northern Mariana Islands are U.S. citizens, as are most persons born abroad to parents (or a parent) who are citizens. All U.S. citizens are considered U.S. nationals, but not all nationals are citizens. Persons who are not U.S. citizens, but were born in American Samoa, Swains Island, or the U.S. Minor Outlying Islands are not U.S. citizens but are U.S. nationals, and therefore may also receive Title IV funds.

The CCA became effective on February 27, 2001. As of that date, foreign born children who are not U.S. citizens at birth become citizens once these conditions are met:

Children newly entering the country who are adopted abroad prior to the issuance of their IR-3 visa (for orphans) or IH-3 visa (for children from Hague Convention countries) become citizens upon arrival. They should receive a Certificate of Citizenship within 45 days instead of receiving a permanent resident card and then filing Form N-600 to request a certificate. Children who are adopted after being admitted to the U.S. with an IR-4 visa (for orphans) or IH-4 visa (for children from Hague Convention countries) become citizens once their adoption is full and final. Parents of these and other children who do not automatically receive a certificate of citizenship can get one by filing Form N-600. For more information, contact the USCIS, visit the website at www.uscis.gov, or see the State Department’s inter country adoption website at http://adoption.state.gov/.

All applications are matched with SSA records to verify U.S. citizenship status, name, date of birth, and Social Security number (SSN) (see Chapter 4). The Central Processing System (CPS) will reject the application for insufficient information if name, date of birth or SSN is not provided. The student’s match result is reported in the “SSA Citizenship” field on the SAR, and on the Match Flags section of the SAR and ISIR. If the student leaves the citizenship question on the FAFSA blank, the CPS will still attempt the citizenship match with the SSA. If there is a complete match with the student’s SSN, name, date of birth, and U.S. citizenship, the CPS will report the student to be a U.S. citizen.

Note that U.S. citizens born abroad might fail the citizenship check, unless they have updated their citizenship information with SSA (see “Updating status for U.S. citizens born abroad” later in this chapter).

If a student must prove their status as a U.S. citizen or national, only certain types of documentation is acceptable. The Department doesn’t specify all of the acceptable documents, but here are some documents you might choose to use to prove U.S. citizenship:

Before you can disburse aid, the student must present documentation that verifies he is a U.S. citizen. If the documents indicate that the student is a U.S. citizen or national, you may award and disburse aid to the student and the C-code may remain on the student’s ISIR. Keep a copy of the documentation in the student’s file, even though older versions of the Certificate of Citizenship and of the Certificate of Naturalization instruct the holder not to photocopy them. Citizenship documentation must be kept in the student’s file but does not need to be verified by any outside agency. Handling of documents for eligible non-citizens differs, and is discussed on page 43. The student can also contact the Social Security Administration to update the student’s record. This updating is not required to receive aid, but may prevent issues with SSA matching in the future.

Students born abroad to U.S. citizen parents are U.S. citizens if they meet certain requirements, and their status is usually noted in the SSA’s database when they receive an SSN. But occasionally, a student may not have provided sufficient proof of U.S. citizenship to SSA in order for the record to be updated. Therefore, these students will fail the U.S. citizenship match even if they have an SSN. If this occurs, the student must provide the school proof of U.S. citizenship as outlined below. The student should contact the SSA to have their record corrected, however, this update is not required to receive aid.

Such students can document US. citizenship by providing a “Consular Report of Birth Abroad” (Form FS-240, which is proof of U.S. citizenship), a “Certification of Report of Birth” (Form DS-1350, which is evidence of U.S. citizenship and equivalent to a birth certificate), or a Certificate of Citizenship issued by USCIS. The DS-1350 is no longer issued, but is still accepted as documentation of U.S. citizenship. If the birth of the student was registered with the American consulate or embassy in a foreign country before he turned 18, he can request the FS-240 or Certificate of Citizenship by sending a written, notarized request to the U.S. Department of State’s Passport Vital Records Section. The State Department does not reissue new DS-1350s. If the student had a DS-1350 and lost it, or never received a FS-240 or Certificate of Citizenship before turning 18, the student may apply for a Certificate of Citizenship using form N-600 at the State Department webpage: https://www.uscis.gov/n-600.

For pictures of the U.S. citizen documents listed above, see the end of this chapter.

A student may apply for a U.S. passport card, which may be considered acceptable documentation of U.S. citizenship, at the U.S. State Department website: https://travel.state.gov/content/travel/en/passports/apply-renew-passport/card.html. For more detail, see 22 CFR 51.4(b)(2).

Anthony is a U.S. citizen, but SSA doesn’t confirm his U.S. citizenship status. The aid administrator asks him to submit documentation of his status. Anthony first submits a Social Security card, but the administrator explains that the card doesn’t document his status because noncitizens can have Social Security cards. Anthony then brings in his Certificate of Naturalization. The administrator makes a copy of the certificate for his file and tells Anthony his citizenship has been documented. She also advises Anthony to have the SSA correct its database so that he won’t have this problem again.

If you are able to discern that a document is fraudulent, you must deny the student Title IV aid. If the student submits conflicting information regarding immigration status on the FAFSA, you must resolve any discrepancies before disbursing Title IV aid. Report altered or misreported information to the Department’s Office of Inspector General at 1-800-MIS-USED or the OIG’s website at: www2.ed.gov/about/offices/list/oig/index.html.

Whenever a student legally changes their name because of marriage, divorce, court order or any other reason, they must tell the Social Security Administration so they can get a corrected card and have correct SSN matches in the future. The student must bring the appropriate documents to prove the change to their local SSA office. See https://secure.ssa.gov/ICON/main.jsp.

Because documents such as a certificate of citizenship can go to minors, they may be signed by a parent or guardian instead of the minor child. This does not affect the legitimacy of the document.

The Compact of Free Association (P.L. 99-239) created three political entities from the former Trust Territory of the Pacific Islands. Two of these entities, the Marshall Islands and the Federated States of Micronesia, voted in 1986 to end political ties with the U.S.. The third entity, Palau, voted to ratify the compact in 1994; its independence was effective October 1, 1994. These three entities are the Freely Associated States. See 34 CFR 600.2. (EX-SB)

Students who are citizens of the Freely Associated States—the Federated States of Micronesia and the Republics of Palau and the Marshall Islands—are eligible for Pell Grants (citizens of Palau are also eligible for FWS and FSEOG; see below) but are not eligible for Title IV loans. These students should have a passport from the Freely Associated States or an I-94.

The student should indicate on the FAFSA that he/she is an eligible noncitizen and leave the ARN item blank. If the student doesn’t have an SSN, he enters 666 and ED will give him a number to use, or if he was given a number in the previous year, he must continue to use the same ED-assigned pseudo-SSN due to Pell Lifetime Eligibility Used (LEU) rules (see the November 20, 2013 Electronic Announcement for more details).

Because he isn’t providing an ARN, the student’s application won’t go through the DHS match. Do not complete a third step verification for these students—they will fail the match. Instead, request documentation of his Freely Associated States citizenship. Once you have received the student’s document establishing his status, as a citizen of the Freely Associated States, make a copy of the document and place it in the student’s file. You can reuse the original document in future years if it hasn’t expired.

The Compact of Free Association Amendments Act of 2003, or the Compact Act, eliminated eligibility for citizens of the Republic of the Marshall Islands (RMI) and the Federated States of Micronesia (FSM) for FSEOG and FWS funds. To mitigate this loss, the Compact Act authorizes Supplemental Education Grants (SEGs) that are awarded to the FSM and RMI. For more information, students of the FSM and RMI should contact their local education authority. Also under the Compact Act and the Palau Compact Review Agreement, students who are citizens of the Republic of Palau continue to be eligible for FWS and FSEOG funds through the 2020-21 award year.

The DHS assigns to all legal aliens an Alien Registration Number (ARN), which FSA uses to identify which applications must be sent to DHS for immigration status verification. If the applicant indicates on the FAFSA that he is an eligible noncitizen and provides an ARN, identifying information is sent to the DHS for eligible noncitizen matching.

The results of the match are shown by a match flag in the “FAA Information” section of the output document, under the headings “DHS Match Flag,” “DHS Sec. Conf. Flag (Secondary Confirmation Flag), and “DHS Verification Number” on the ISIR and SAR. There will also be a comment about the results on the output document.

Because all applications are matched with the SSA, an application with an ARN will be matched with both DHS and SSA records. When results are received from both matches, a positive SSA match will indicate that the student is a U.S. citizen. If the SSA match is negative, the DHS match flag will determine the student’s eligible noncitizen status.

A correction to the student’s ARN made while the DHS is conducting the automated secondary confirmation may start the process over, i.e., the correction may be sent through primary confirmation. Though unlikely, if the new primary confirmation match yields a “Y,” the transaction can be used to award aid. The new transaction may have a new DHS verification number assigned. A correction made to a transaction that contains secondary confirmation results of “Y” or “C” (or a transaction with a primary confirmation result of “Y”) will not be sent through the DHS match again. Otherwise the record will be re-sent for matching.

On his original application, Theo didn’t give his ARN and reported that he was a citizen. When the SSA didn’t confirm this, Theo told the aid administrator at Fowler University that he was a permanent resident. He added his ARN and changed his citizenship status to eligible noncitizen, but SAVE didn’t confirm his status as an eligible noncitizen. He explained to the aid administrator that he had applied for permanent resident status but didn’t have documentation yet. The aid administrator told him that when he received documentation that his application was approved, he should bring it to Fowler so that it could be submitted to the USCIS for confirmation. The aid administrator told him to bring any information supporting his current immigration status to Fowler so that it could be submitted to the USCIS for confirmation. Depending on the documentation Theo provides, he may be considered an eligible noncitizen in a class other than permanent resident.

When a record is processed through the CPS match with DHS, a 15-digit verification number is assigned to the student and printed in the “FAA Information” section of the SAR and ISIR. This 15 digit number is needed to access the student’s SAVE record, and to submit a third step verification request through SAVE.

If the student didn’t pass secondary verification or if you have conflicting information about his immigration status after receiving a primary or secondary match result, you must review the record for third step verification.

For more on using the SAVE system to complete third step verification, see the section titled “Using the SAVE System for third step verification” later in this chapter.

Certain non-U.S. citizens may be eligible for Title IV aid. The following types of “eligible noncitizens” are among the classes of persons who may be eligible (see bulleted list below).

For classes of eligible noncitizens other than permanent residents, evidence of their status is typically on the I-94, but other documentation may also be acceptable. Customs and Border Protection (CBP) no longer issues a paper I-94 form, with the exception of asylees and certain parolees. In September 2015, CBP automated the refugee admission process. Refugees will no longer receive a paper form I-94, but will have access to an electronic form. Students without paper I-94 documentation may have their status confirmed by the electronic I-94 printout and/or a CBP stamp, showing class of admission and date admitted or paroled in their passport to confirm this status.

Form I-797 is USCIS’s formal communication with customers, and is issued when an application or petition is approved or to confer an immigration benefit.

Only when students fail the citizenship match or have conflicting information must you perform third-step verification using the SAVE system to confirm that their documentation supports one of the following noncitizen status categories:

Customs and Border Protection (CBP) creates admission records electronically. The I-94 website allows travellers (and schools, if the traveller grants permission) to access admission records online (the website contains records from April 2011 to present). Legacy paper I-94s are also still valid.

DHS-Customs and Border Patrol began issuing I-94s with an alpha character in the 10th position of the 11-character identifier beginning in May, 2019. See https://i94.cbp.dhs.gov/I94.

In most cases you will examine and copy original immigration documents, and you must keep a copy in the student’s file with the results from the third step verification/SAVE. While generally not permitted, for the purpose of applying for Title IV aid, students may legally photocopy, scan, or otherwise image immigration documents (such as Forms I-551 or I-94) to complete the third step verification process. See DCL GEN-15-08.

When an eligible noncitizen student changes his or her name, the student needs to update it with SSA and DHS. To update their name with DHS, students can schedule an INFOPASS appointment by calling their local USCIS office or by scheduling an online appointment at https://my.uscis.gov/en/appointment/v2. For the SSA update, the student must bring the appropriate documents to prove the change to their local SSA office. See https://secure.ssa.gov/ICON/main.jsp.

The USCIS’s Systematic Alien Verification for Entitlements (SAVE) Program office publishes the SAVE Guide to Immigration Documents. To access the Guide, go to: https://save.uscis.gov/web/media/resourcesContents/SAVEGuideCommonlyusedImmigrationDocs.pdf

Note that a refugee or an asylee may apply for permanent resident status. During the period in which the application is being reviewed, the student may have a copy of the I-94 that includes the endorsement “209a (or 209b) pending. Employment Authorized.” Students with this form of documentation are eligible for Title IV funds as long as the I-94 has not expired. For more sample citizenship documents which may be used to substantiate various types of citizenship status, see the end of this chapter.

U.S. Citizenship & Immigration Services (USCIS) uses blue colored ink for its secure stamps. The red ink previously used for such stamps has been retired and is no longer used (note also that some stamps still use black ink).

Section 289 of the Immigration and Nationality Act (INA) gives persons with at least 50% Native American blood who were born in Canada the legal right to live and work indefinitely in the U.S. This is based on the Jay Treaty of 1794 and subsequent court decisions. Such individuals are not subject to the legal restrictions typically imposed on aliens by the DHS, are not required to obtain documentation from the DHS, and are considered “lawfully admitted for permanent residence.” They must obtain an SSN for purposes of applying for Title IV aid.

Students who may be eligible for Title IV funds should enter their valid ARN (or a A999999999 if they don’t have an ARN) on the FAFSA and indicate they are eligible noncitizens. If they fail the DHS match, you must submit a third step verification with the documentation. If they fail third step verification, they can still be considered eligible if they meet the documentation requirements below for students without an ARN. Students who enter all 9’s for their ARN will receive comment 144 on the output document. The school must obtain proof that such a student has 50% Native American blood and was born in Canada. To do so, the student should provide one or more of the following documents:

If the student can provide this documentation and is otherwise eligible, the school must note this in the student’s file and can award Title IV funds.

Several types of documentation do not prove a student’s eligible noncitizen status. Below, we list a variety of forms and their related statuses which are ineligible. If a student does not provide a document that proves his eligibility for Title IV aid, he is not eligible with these documents alone. Generally, if a student has both an eligible noncitizen status as well as an ineligible status, the eligible status will trump the ineligible status, and the student will be potentially eligible for Title IV aid (pending other aspects of student eligibility as discussed in this Volume).

If the document a student submits is for an ineligible status, you shouldn’t submit the documentation for third step verification. Unless you have conflicting information or the student compels you to do so. USCIS will only confirm current immigration status based on the document presented; it doesn’t determine whether the student is eligible for Title IV funds. Unless the student can submit documentation for an eligible status, as described above, or USCIS confirms the student’s status as an eligible student, the student can’t receive aid.

If the student’s immigration documentation appears to support an eligible noncitizen status, or if you have conflicting information after receiving a secondary match result, you must complete a third step verification request through the SAVE system. What was once known as the “Paper Secondary Confirmation” step, which required you to submit a paper form G-845, is now performed electronically, and is called “third step verification.” USCIS now returns third step verification responses via the SAVE system.

To access the SAVE system, go to: https://save.uscis.gov/web/vislogin.aspx?JS=YES

In a collaborative effort, DHS and the Department of Education designed and implemented special functionality for schools to submit third step verification requests through the SAVE system, to check students’ eligibility for Title IV aid. A unique SAVE user ID was issued to the Primary Destination Point Administrator (PDPA) at each school to access the SAVE system.

All the instructions you need to access and navigate the SAVE system are available on the DHS-SAVE, Eligible Noncitizen-Dear Colleague Letters and Electronic Announcements page on the Knowledge Center, including:

If the student’s immigration documentation appears to support that he/she is an eligible noncitizen, or if you have conflicting information after receiving a match result, you must complete a third step verification request.

When you determine that third-step confirmation cannot be completed for a student, for example, when the case status is “closed,” or the SAVE response doesn’t match the immigration documentation provided by the student, you must complete the “resend record to matches” process in the FAA Access to CPS Online system. This replaces the “requesting a new DHS verification number” process. See the “Resend Record to Matches to Generate a new ISIR with a new DHS Verification Number” section of the SAVE instructions for U.S. Department of Education (School) Users Version 3.0 document.

A USCIS status verifier will search the SAVE databases, and enter the student’s immigration status in the SAVE system within three to five business days of the request. If you don’t receive a response from the USCIS after at least 15 business days from the date you sent the third step verification request, if you have sufficient documentation to make a decision, and if you have no information that conflicts with the student’s documents or claimed status, you should review his file and determine whether he meets the eligible noncitizen requirements. If he does meet the requirements, make any disbursement for which he is eligible and note in his file that SAVE exceeded the time allotment and that noncitizen eligibility was determined without their verification.

When third step verification results in an eligible status, you must keep a copy of the SAVE response screen. If the confirmation process indicates a discrepancy, you must ask the student to correct the discrepancy with the USCIS. No certification of loans or further disbursement of funds can be made until the discrepancy is corrected. If the discrepancy isn’t reconciled, the student must repay all aid except wages earned under FWS. Whenever the student is able to provide new information, it must be submitted to the USCIS as a third step verification request.

If you have followed the procedures outlined here, including notifying the student of the discrepancy and withholding further payments and loan certifications as soon as a discrepancy is found, your school isn’t liable for aid disbursed prior to third step verification. This assumes that you had no other conflicting information prior to making the disbursement and had reviewed the available documentation and concluded that the student was otherwise eligible.

Javier is a refugee and received aid from Schwarber University. His status wasn’t confirmed through the DHS match, so Schwarber performed third step verification. The DHS didn’t respond in time, so Schwarber paid Javier without any response. When Javier applies again, the CPS still doesn’t confirm his status. Even though Schwarber began third step verification for Javier last year and his documents haven’t expired, because the school never received a DHS response, it must perform third step verification again.

SAVE is responsible for verifying the student’s imigration documentation. The SAVE response does not directly state whether the student is eligible for Title IV funds. It is the school’s responsibility to determine if the student is eligible, based on the student’s immigration documentation and the SAVE response. When you receive the SAVE response, compare it with the list of responses below. If it matches with a response, and the student’s documentation, but does not support an eligible status tell the student they are ineligible until/unless they can provide documentation that supports an eligible status, and stop third step verification for the student.

If the student’s documentation supports an eligible noncitizen status but the SAVE system response shows an ineligible status, read the DHS comments and resolve issues raised there (for example, provide a cleaner copy of the student’s documentation if instructed by USCIS). Once resolved, use the Resend to Matches process (see above) and resubmit third step verification. If you have questions about the SAVE response or about the student’s documentation, contact applicationprocessingdivision@ed.gov and briefly describe your issue.

The following list explains whether a response means the student is eligible or ineligible for Title IV aid. For descriptions of the following immigration statuses, see the earlier sections on eligible and ineligible noncitizens and their documentation:

Potentially eligible statuses:

“Lawful Permanent Resident”

“Conditional Resident”

“Asylee or refugee status”

“Parolee-Expires or Parolee-Indefinite” The student is eligible for aid if paroled into the U.S. for one year or more. The SAVE response will include the parole expiration date which must be after the day the student starts classes AND has evidence from the DHS (such as a form I-797 Notice of Approval of I-485 Permanent Residence Status) that he is in the U.S. for other than a temporary purpose and intends to become a U.S. citizen or permanent resident. The SAVE response will include a comment in the DHS Comments section of the Pending Applications section that the student’s I-485 application is pending. Note that if the student has not filed the I-485, nor had that application accepted by DHS, they are not an eligible noncitizen parolee.

“U.S. citizen” Because the verification request is used to check the status of noncitizens, this box should be infrequently checked. You should not see this in the financial aid office because, as explained earlier in the chapter, you would have reviewed the student’s documentation, which identified them as a U.S. citizen, and you would not have submitted it to the USCIS.

“Cuban/Haitian Entrant” SAVE has a special box that you click to receive a Cuban-Haitian Entrant response.

“American Indian born in Canada” For details, see the Jay Treaty section earlier in this chapter.

“Texas or Oklahoma Band of Kickapoo Indians” If this response is received, the financial aid administrator must contact U.S. Department of Education staff by emailing applicationprocessingdivision@ed.gov.

“VAWA Self-Petitioner” If you have questions about VAWA status, contact applicationprocessingdivision@ed.gov. See GEN-10-07.

Ineligible statuses:

Each of the following statuses are by themselves insufficient to make a student eligible for Title IV funds. If the SAVE response is an eligible status, followed by an ineligible status (for example, Lawful Permament Resident - Employment Authorized), ignore the ineligible status portion of the response. Unless an eligible status is also submitted, or the student can provide other documentation that can be confirmed by the USCIS, the following types of student are not Title IV eligible:

“Employment Authorized”

“Not Employment Authorized”

“Application Pending” A pending application for an immigration status doesn’t by itself make the student eligible for Title IV funds; he must have an eligible status indicated on the SAVE response.

“Nonimmigrant”

“Deferred Action for Childhood Arrivals (DACA)”

“Family Unity”

“Temporary Protected Status (TPS)”

“Deferred Action Status”

“Withholding of Removal”

“Document Expired, Altered, or Counterfeit.” Notify the student that unless corrective action is taken with the USCIS, the case will be submitted to the Office of Inspector General (OIG). Until this is resolved, no further aid may be disbursed, awarded, or certified. If the student does not take corrective action in a timely manner, you must report the case to the OIG (part of which will include resubmitting the document).

“Unable to verify status based on the document provided.” DHS-USCIS was not able to verify the student’s status based on the documentation provided. The student must contact the appropriate agency, i.e., USCIS, Immigration and Customs Enforcement (ICE), or Customs and Border Protection (CBP) to correct their records.

If SAVE was unable to process the request, one of the following messages may appear in the response or in the DHS Comments section:

You must allow the student at least 30 days from the time you receive the SAVE response to provide documentation of his immigration status. During this period and until the results of the third step verification are received, you can’t deny, reduce, or terminate aid to him. Unless you can determine that the documentation doesn’t support an eligible noncitizen status, you must submit the student’s immigration documents within ten business days of receipt. If the documentation supports the student’s status as an eligible noncitizen, and if at least 15 business days passed since the date on which the documentation was submitted to the USCIS, you can disburse aid to an otherwise eligible student pending the USCIS response.

Your school isn’t liable if you erroneously conclude that a student is an eligible noncitizen, provided that you had no conflicting data on file and you relied on:

The student (or parent borrower of a PLUS loan) is liable for any Title IV funds received if he is ineligible. If you made your decision without having one of the documents above, your school is held responsible for repaying Title IV funds to the Department. Your school should establish procedures to ensure due process for the student if Title IV funds are disbursed but the aid office later determines (using third step verification) that the student isn’t an eligible noncitizen.

The student must be notified of his ineligibility and given an opportunity to contest the decision by submitting to your school any additional documents that support his claim to be an eligible noncitizen. If the documents appear to support the student’s claim, you should submit them to USCIS using third step verification. You must notify the student of your office’s final decision based on the third step verification results.

For every student required to undergo third step verification, you must furnish written instructions providing:

There are several cases in which you must document a student’s immigration status in a subsequent award year if that student is not confirmed as an eligible noncitizen on the SAR/ISIR process. For example, a student who presented a Temporary Form I-551 in a prior award year should have received a permanent I-551 by the next year and shouldn’t still have a temporary card. You should refer the student to USCIS to obtain a permanent I-551 or an updated endorsement on the previous card.

You must also document the eligible noncitizen status each award year for a conditional permanent resident, a refugee, a Cuban-Haitian entrant, or a person granted asylum. Students in any of these categories may have been redesignated to permanent-resident status or may have had their statuses revoked. You will have to send the documents for third step verification if the student’s status isn’t confirmed through the USCIS match. Also note that VAWA prima facie status generally expires after 180 days or 1 year, and that parolees can potentially become Lawful Permanent Residents if their I-485 is approved.

You don’t have to document a student’s eligible noncitizen status in subsequent award years if you’ve documented that the student is:

You must also have no conflicting information or reason to doubt the student’s claim of having eligible noncitizen status. Also note that you must have confirmed the status in a previous award year. You may disburse aid without the USCIS response if the USCIS doesn’t respond in time for that award year, but you can’t count that lack of response as confirmation for the following year.

If a student can’t locate his official USCIS documentation, the student must request that the documents be replaced because noncitizens who are 18 years and older must have immigration documentation in their possession at all times while in the United States. Requests for replacement documents should be made by the student to the nearest USCIS District Office.

The student will be asked to complete a Form I-90, “Application to Replace Alien Registration Card” or a Form I-102, “Application for Replacement/ Initial Nonimmigrant Arrival-Departure Document.” PDF versions of these forms can be downloaded from the USCIS website at uscis.gov. A temporary I-94 may be issued while the replacement documents are pending. Documents can also be replaced at the following links (the document to be replaced listed first, followed by the form which must be completed):

In cases of undue hardship, where the student urgently needs documentation of his status, the Freedom of Information Act (FOIA) allows him to obtain photocopies of the documents from the USCIS District Office that issued the original documents. The student can submit a Form G-639 to make this request or can simply send a letter to the district office. If he is not sure which district office issued the original documents, he can submit the request to the field office nearest to his place of residence.

A naturalized U.S. citizen student who lost documents or surrendered them when entering prison is responsible for getting copies of them before third step verification is submitted for the student. You can request copies of immigration documents directly from penal institutions at the request of the student.

The next few pages show some common documents used to demonstrate citizenship for various categories/types of citizenship and eligible noncitizenship. Note that not all documents shown satisfy citizenship requirements in all cases. See the specific notes on each document shown, and also refer to the discussion of citizenship requirements described in detail earlier in this chapter.

The Certificate of Citizenship is issued to persons who were born abroad of U.S. parent(s), who became citizens when their parents were naturalized, or who were adopted by U.S. parents.

For permanent resident status, must be stamped “Processed for I‑551” with expiration date or “Temporary Form I-551” with appropriate information filled in. For other eligible noncitizens, must be stamped with the proper information as described for Refugee, Asylum Status, Conditional Entrant (before April 1, 1980), Parolee, or Cuban- Haitian Entrant.

Permanent residents are issued identification cards that they are required to have in their possession at all times. The first Alien Registration Receipt Card was introduced in 1946 and through various revisions was primarily green, which caused it to be known as a “green card.” This term is still used, though the cards have changed color over the years.