U.S. Citizenship & Eligible Noncitizens

A student must be a U.S. citizen or national, a citizen of the Freely Associated States, a lawful permanent resident, or other eligible noncitizen to be potentially eligible for federal student aid. In this chapter, we describe how the student’s FAFSA information is matched with other agencies to determine citizenship or immigration status. We also describe the immigration documents that you may need to collect to ensure the student’s eligibility.

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

The Department matches all applications with the Social Security Administration (SSA) on U.S. citizenship. If U.S. citizenship or nationality cannot be confirmed, the student must provide documents proving U.S. citizenship or nationality, citizenship of the Freely Associated States, lawful permanent residence, or other eligible noncitizen status to satisfy the citizenship requirement for Title IV eligibility. If the student provides an A-Number on the FAFSA form, their record is also sent to the Department of Homeland Security (DHS) to check their eligible noncitizen immigration status or category.

The results of both matches appear on the Institutional Student Information Report (ISIR). A failed match with either agency will produce a “C code” on the student’s ISIR. A student’s U.S. citizenship or nationality (or eligible noncitizen) status only needs to be checked once for the award year; if the student has an eligible status at that time, the student remains potentially eligible for the rest of the award year (except for parolees; see the “Third-Step Verification” 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.

Note that USCIS forms and websites may use the term “alien” as defined in section 101(a)(3) of the Immigration and Nationality Act (8 U.S.C. 1101(a)(3)) instead of “noncitizen.”

A person is a U.S. citizen by birth, naturalization, or operation of law. Persons born in the 50 states, the District of Columbia, Puerto Rico, the U.S. Virgin Islands, Guam, and people born on or after November 4, 1986 in the Northern Mariana Islands are U.S. citizens (except for the children born to foreign diplomatic officers accredited to the United States or other persons with comparable diplomatic status, who are not considered U.S. citizens). Also, many persons born abroad to U.S. citizen parents (or a parent) may be U.S. citizens. All U.S. citizens are considered U.S. nationals, but not all U.S. nationals are U.S. citizens. Persons who are not U.S. citizens, but were born in American Samoa (which includes Swains Islands) (or certain persons born abroad to a noncitizen U.S. national parent) 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 the subject of a full and final adoption abroad prior to the issuance of their IR-3 visa (for orphans) or IH-3 visa (for children from countries party to the Hague Convention on the Protection of Children and Co-operation in Respect of Intercountry Adoption) generally become citizens upon admission to the United States. They generally receive a Certificate of Citizenship within 45 days instead of receiving a permanent resident card. For more information see https://www.uscis.gov/policy-manual/volume-12.

Children who are admitted to the U.S. with an IR-4 visa (for orphans) or IH-4 visa (for children from Hague Convention countries) generally become citizens once their adoption is completed (or they are re-adopted or obtain state recognition of the foreign adoption) in the United States. Parents of these and other children who do not automatically receive a certificate of citizenship can request one by filing Form N-600. For more information, contact USCIS, visit the website at www.uscis.gov, or see the State Department’s intercountry adoption website at http://adoption.state.gov/.

If a student who falls under this category fails the citizenship match, the student would need to provide acceptable proof of citizenship by providing documents such as those listed below under the U.S. citizenship documentation section.

All applications are matched with SSA records to verify U.S. citizenship, name, date of birth, and Social Security number (SSN) (see Chapter 4). The FAFSA Processing System (FPS) 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 and Match Flags section on the FAFSA Submission Summary and ISIR. If the student leaves the citizenship question blank on the FAFSA form, the FPS 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 FPS 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 are acceptable. The Department doesn’t specify all of the acceptable documents, but some documents you might choose to use to prove U.S. citizenship/nationality include:

Before you can disburse aid, the student must present documentation that verifies that they are a U.S. citizen or national. 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 or nationality 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 noncitizens differs, and is discussed later in this chapter. The student can also contact the SSA to update the student’s record. This updating is not required to receive aid but may prevent issues with SSA matching in the future.

At your school’s discretion, you may permit U.S. citizen and U.S. national students to photocopy, scan, or otherwise image their citizenship documents, and submit either electronic images or paper copies of the same to the school’s financial aid office for the purpose of determining their eligibility for Title IV funds. For more information, see Dear Colleague Letter GEN-15-18.

Students born abroad to U.S. citizen parents are U.S. citizens if they meet certain requirements. Their status is usually noted in the SSA’s database when they receive an SSN. Occasionally, a student may not have provided sufficient proof of U.S. citizenship to SSA for the record to be updated. 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:

The Forms DS-1350 and FS-545 are no longer issued but are 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 they turn 18, they can request the FS-240, Consular Report of Birth Abroad 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-1350 forms. If the student had a Form DS-1350 and lost it, or never received a Form FS-240 or Certificate of Citizenship before turning 18, the student may apply for a U.S. Passport from the Department of State or for a Certificate of Citizenship from USCIS. To apply for a Certificate of Citizenship, the student should file Form N-600, available at the USCIS webpage: https://www.uscis.gov/n-600.

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

Whenever a student legally changes their name because of marriage, divorce, court order, or any other reason, they must tell the SSA 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 the SSA name change page for more information.

Because documents such as a certificate of citizenship can be issued 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 United States has entered into Compacts of Free Association with three independent nations from the former Trust Territory of the Pacific Islands: the Republic of the Marshall Islands (RMI), the Federated States of Micronesia (FSM), and the Republic of Palau. These three entities are collectively known as the Freely Associated States (FAS). See Pub.L. 118-42; HEA Sec. 103(20)(B); and 34 CFR 600.2.

Students who are citizens of the Freely Associated States (FAS) are eligible for Pell Grants, and as of the 2024 revision to the Compact Amendments Act, FWS and FSEOG as well (see the “Compact Amendment Act 2024 Revision section below). FAS students are not eligible for Direct Loans. These students should have a passport from the Freely Associated States or a Form I-94.

Each FAS student should indicate on the FAFSA form that they are an “eligible noncitizen” and leave the A-Number item blank. Because the student isn’t providing an A-Number, their 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 the student’s Freely Associated States citizenship. Once you have received the student’s document establishing their 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.

Under the 2024 Consolidated Appropriations Act of 2024, a public school must charge students who are citizens of the FAS no more than the in-state tuition rate.

The original Compact of Free Association Amendments Act of 2003, or the Compact Amendments Act, eliminated eligibility for citizens of the RMI and the FSM for FSEOG and FWS funds. To mitigate this loss, the Compact Amendments Act authorized students from the FSM and RMI to receive Supplemental Education Grants. However, in 2024, the Compact Amendments Act was revised in Public Law 118-42. Section 209(b)(1)(D) restored FSEOG eligibility for students from the FSM and RMI. Additionally, the Compact Amendments Act added Federal Work Study (FWS) eligibility for these students (provided they meet all other eligibility criteria). Citizens of the FAS are also still potentially eligible for Pell Grants. Note that Supplemental Education Grants (not to be confused with FSEOG) have been discontinued. For more details, see the Electronic Announcement GEN-24-50.

The U.S. Department of Homeland Security (DHS) assigns an A-Number to most individuals who are not U.S. citizens, which FSA uses to identify which applications must have their data sent to DHS for immigration status/category verification. If the applicant indicates on the FAFSA form that they are an “eligible noncitizen” and provides an A-Number, identifying information is sent to DHS for eligible noncitizen verification. DHS verification is conducted by SAVE, an online service administered by USCIS, an agency within DHS.

The results of the match are shown by a match flag in the “FAA Information” section of the output document, under the headings “DHS Primary Status,” “DHS Secondary Match Status” (Secondary Confirmation Flag), and “DHS Case Number” on the FAFSA Submission Summary and ISIR. There will also be a comment about the results on the output document.

Because all applications are matched with the SSA records, an application with an A-Number will be matched against both SSA records and records available to DHS. When results are received from both agencies, a successful SSA match will indicate that the student is a U.S. citizen. If the SSA match is unsuccessful, the DHS match status will determine the student’s eligible noncitizen status/category.

The following are some common DHS match results:

For additional guidance on the DHS-SAVE system and DHS Match statuses, see the SAVE Instructions for U.S. Department of Education (School) Users 4.0 document. For assistance with interpreting a SAVE response, please email the student’s DHS Verification number to applicationsystemsdivision@ed.gov .

The secondary match process with the DHS is not currently available. As a result, if the DHS Primary Match Status is “N” (Not confirmed eligible noncitizen), institutions should search for the case in the SAVE system and proceed with the third-step verification process. See EA GEN-24-100 for more detail.

When a record is processed through the FPS match with DHS, a 15-digit case number is assigned to the student and printed in the “FAA Information” section of the FAFSA Submission Summary and ISIR. This 15-digit number, along with the applicant’s date of birth, is needed to access the student’s SAVE record, and to submit a third-step verification request through SAVE.

If the initial match result status is "N," or if you have conflicting information about their immigration status/category after receiving a primary or secondary match result, you must review the record for third-step verification.

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

Certain individuals who are not U.S. citizens or nationals may be eligible for Title IV aid. Eligibility for Title IV aid, as a federal public benefit, is restricted under the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) to persons who can demonstrate certain types of eligible noncitizen statuses/categories as a “qualified alien” under 8 U.S.C. § 1641(b) and (c). In addition, Title IV of the HEA requires such individuals to be able to provide documentation that they are “in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident” in order to establish their eligibility for federal student aid. In determining eligibility under both PRWORA and Title IV of the HEA, the Department accepts the following types of eligible noncitizen statuses/categories as sufficient to demonstrate a person’s eligibility for Title IV aid (see bulleted list below).”

The U.S. Department of Homeland Security (DHS) – including its component agencies U.S. Citizenship and Immigration Services (USCIS); Immigration and Customs Enforcement (ICE); and U.S. Customs and Border Protection (CBP) – and the U.S. Department of State (DOS) issue documents to individuals who are not U.S. citizens, including documentation that may serve as evidence of eligible noncitizen status. For general information and sample images, see the USCIS SAVE Commonly Used Immigration Documents page.

For classes of eligible noncitizens other than lawful permanent residents, evidence of their status/category is typically on Form I-94, but other documentation may also be acceptable. DHS generally no longer issues a paper Form I-94 as they are generally available electronically from CBP’s website. However, asylees and certain parolees continue to receive paper Form I-94. In September 2015, CBP automated the refugee admission process. Refugees will have access to an electronic form and will no longer receive a paper Form I-94. Students without paper Form I-94 documentation may have their status confirmed by the electronic Form 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 (Notice of Action) is USCIS’s formal communication with customers and is issued when an application or petition is received or approved or to confer an immigration benefit.

Only when students have unsuccessful SSA and DHS matches, you have conflicting information, or you or the student disagrees with the SAVE response, must you perform third-step verification using SAVE to confirm that their documentation supports one of the following eligible noncitizen statuses or categories for Title IV eligibility purposes:

Each of these eligible noncitizen statuses/categories are discussed in their respective subsections below.

Lawful permanent residents (LPRs) are individuals who are not U.S. citizens who are legally permitted to live and work in the U.S. permanently. The standard document for demonstrating LPR is the Permanent Resident Card (Form I-551 since 1997) or Resident Alien Card (Form I-551 before 1997). Both forms are referred to colloquially as “green cards,” though they have changed colors over the years. Possessors of the older Alien Registration Receipt Card (Form I-151, issued prior to June 1978) should have replaced it with a newer card, but for receiving Title IV funds, it is acceptable as evidence of permanent residence. In general, students whose Permanent Resident Card (PRC) has expired may still be considered lawful permanent residents for FSA eligibility purposes; therefore, if they submit expired documentation, submit it to SAVE and base eligibility on the response.

Note: USCIS may extend the validity of Permanent Resident Cards for lawful permanent residents who properly filed Form I-90, Application to Replace Permanent Resident card, to renew their PRC. If a PRC’s validity has been extended, the student will have a Form I-797, Notice of Action, receipt notice that extends the validity of the PRC.

LPRs may also present an Arrival/Departure Record (Form I-94) or the Departure Record (Form I-94A), with the endorsement “Processed for I-551. Temporary Evidence of Lawful Admission for Permanent Residence. Valid until _______. Employment Authorized.” If available, a Form I-551/PRC (also known as a “green card”) is preferable to establish LPR status. The form will have an A-Number annotated on it and is acceptable. Sometimes a temporary stamp expires but the student will retain LPR status. If the student’s temporary stamp is expired but the student believes that he or she is an LPR, submit the expired document to SAVE and a status verifier will confirm the student’s status.

The U.S. Department of State issues a machine-readable immigrant visa (MRIV) in the holder’s passport. The MRIV will have a U.S. CBP inspector admission stamp, and the statement “UPON ENDORSEMENT SERVES AS TEMPORARY I-551 EVIDENCING PERMANENT RESIDENCY” will appear directly above the machine-readable section. An MRIV with this statement, contained in an unexpired foreign passport and endorsed with the admission stamp, constitutes a temporary Form I-551, valid for one year from the date of endorsement on the stamp.

USCIS issues the U.S. Travel Document (mint green cover), which contains the Reentry Permit (Form I-327) and the Refugee Travel Document (Form I-571). It is used by lawful permanent residents, as well as refugees and asylees, and is annotated with “Permit to Reenter Form I-327 (Rev. 9-2-03).”

If the student has a Form I-551 with a baby picture, they should update the Form I-551 with the USCIS. LPRs are expected to get a new picture and be fingerprinted at the age of 14. But you can submit the documents to USCIS and disburse Title IV funds to a student who has a Form I-551 with a baby picture if you can confirm that it belongs to the student. You can do this by comparing the Form I-551 to a current photo ID that has the student’s name, date of birth, and signature. The current ID must also be consistent with any identifying information in the student’s file.

A student who has an approved application for LPR status on file with the USCIS and who is waiting for a permanent resident card should have a Form I-797 from USCIS with "Notice Type: Approval Notice," as well as an A-Number, which will give notice of current status. Note that a pending application for lawful permanent resident status alone is not sufficient for determining eligibility for Title IV funds.

If a person is granted suspension of deportation or cancellation of removal (including special rule cancellation of removal) by an immigration judge or by USCIS, USCIS will issue the individual a Form I-551, which is evidence of LPR status. There is no special category for persons who have been granted suspension of deportation or cancellation of removal (including special rule cancellation of removal).

Some applicants from Afghanistan may be eligible as Afghan Special Immigrant Lawful Permanent Residents (SI LPRs). These applicants may have MRIVs and/or foreign passports with a DHS, U.S. Customs and Border Protection (CBP) stamp admitting them with an SQ1, SQ2, SQ3, SQ7, SQ8, SW1, SW2, or SW3 Class of Admission. Others may have a temporary Form I-551 stamp in their passport or on a Form I-94. Others may have a Permanent Resident Card, whose expiration date may be extended by a Form I-797C, Notice of Action. Eligible SI LPRs will receive the “Lawful Permanent Resident” response in SAVE. Note that some SI LPRs may not have a physical immigrant visa in their passport and may not have a temporary Form I-551 stamp. For more details, see Dear Colleague Letter GEN-23-04.

Conditional permanent residents are eligible for aid if their documentation has not expired. They may have a valid Form I-551, I-94, I-94A, or a passport with an MRIV bearing the statement, “Upon endorsement serves as temporary I-551 evidencing permanent residency.”

Reasons an individual may receive conditional permanent residence are described below:

A Form I-551 for a conditional permanent resident is the same Form I-551 that is issued to regular lawful permanent residents, except that the card for a conditional permanent resident expires in two years, as opposed to 10 years for the regular card. A conditional permanent resident must file a petition to remove the conditions on permanent residence. USCIS will review the petition and, if eligibility criteria are met, remove the conditions on permanent residence and issue a new PRC with a 10-year expiration date. Conditional permanent residents may also have a Form I-797 that reflect an extension of the I-551 while the petition to remove the conditions on permanent residence is pending.

Conditional entrants are refugees who entered the U.S. under the seventh preference category of P.L. 89-236 or whose status was adjusted to lawful permanent resident alien under that category. Students may have a Form I-94 with a stamp displaying “Section 203(a)(7)” and indicating that the person was admitted to the U.S. as a conditional entrant. Because this category stopped being used after the enactment of the Refugee Act on March 31, 1980, you should not disburse Title IV funds if the student has a Form I-94 with conditional entrant status granted after that date.

The stamps mentioned use blue security ink. The stamp contains three codes: the first is a two-digit code to the left of the date that designates the field office with jurisdiction over the port of entry. On most stamps, this code will be two numbers and no letters. Letters are currently only used on HQ stamps. The three-letter code located under the word “ADMITTED” shows the port of entry. The third code, to the right of the date, is the unique four-digit number. When referring to a particular stamp, the port of entry code and the stamp’s unique number should be used.

The endorsement or stamp can be placed anywhere on the Form I-94. If the original stamp does not copy well due to the ink color, you should replicate it by hand on the photocopy. Because CBP offices don’t have uniform procedures or stamps, you should contact the local office with questions regarding acceptable immigration documents.

Refugee status continues unless terminated by DHS. Refugees are required to apply for Lawful Permanent Residency (LPR) status one year after admission into the United States as a refugee. In September 2015, CBP automated the refugee process. A refugee will have an electronic Form I-94 showing “RE” as the class of admission and an admit until indicator of “D/S” (indicating duration of status). The refugee travel letter provided by the Department of State will be annotated with a stamp showing admission under Section 207 of the Immigration and Nationality Act (INA). While the form is now automated, a refugee may be in possession of an older paper Form I-94 or I-94A or be provided a paper form upon request. The paper Form I-94 or I-94A is annotated with a stamp showing admission under Section 207 of the Immigration and Nationality Act (INA). They may also have a Form I-766, Employment Authorization Document, with an “A03” category. They may also have the old Refugee Travel Document (Form I-571) or the newer U.S. Travel Document annotated with “Refugee Travel Document Form I-571 (Rev. 9-2-03).”

Persons granted asylum can be approved for lawful permanent resident status after they have been physically present in the U.S. for at least one year since being granted asylum. Asylee status continues unless rescinded or terminated by DHS or the Department of Justice or until lawful permanent resident status is granted. Asylees will have a Form I-94 or Form I-94A with a stamp showing a grant of asylum under Section 208 of the INA. They may also have a Form I-766, Employment Authorization Document, with a “A05” category. They may also apply for and receive a refugee travel document. Asylees who leave the U.S. and attempt to return without proper travel documentation may have difficulty being readmitted to the U.S. as an asylee.

Persons paroled into the U.S. for at least one year must provide documentation of their parole category (such as a Form I-94 or Form I-766, Employment Authorization Document, with a “C11” category) and it must indicate that the student has been paroled into the U.S. for at least one year, with a date that has not expired (Title IV funds cannot be disbursed after the document has expired). They also must provide evidence, such as having filed a Form I-485, Application to Register Permanent Residence or Adjust Status, or are a beneficiary on a Form I-130, Petition for Alien Relative, from DHS to demonstrate that they are in the U.S. for other than a temporary purpose and intend to become a citizen or LPR. DHS will usually respond to the filing of a Form I-485 with a Form I-797C, Notice of Action, indicating receipt of an application and a parolee must provide this Form I-797C or any other immigration document from DHS showing the student is in the U.S. for other than a temporary purpose and intends to become a U.S. citizen or LPR.

If the student does not submit a Form I-797C, send their alternative documentation during third-step verification to SAVE and ensure that the SAVE response is “Parolee-Expires”, or “Parolee-Indefinite” and that the Pending Applications or DHS Comments sections indicate one of the documents mentioned above. Note that individuals classified as “Advance parolees” are never considered potentially eligible for Title IV aid.

Ukrainian citizens or nationals (or noncitizens who last habitually resided in Ukraine) paroled into the United States between February 24, 2022 and September 30, 2024 are eligible for entitlement programs and other benefits available to refugees admitted under section 207 of the Immigration and Nationality Act (8 U.S.C. § 1157) for the term of parole granted, or through a new period of parole if applicable, unless the parole has been terminated by the Secretary of Homeland Security. In addition, Ukrainian citizens or nationals (or noncitizens who last habitually resided in Ukraine, regardless of citizenship) paroled into the United States after September 30, 2024, are eligible for these benefits if they are the spouse or child (unmarried and under 21) of a Ukrainian paroled between February 24, 2022, and September 30, 2024, or the parent, legal guardian or primary caregiver of an “unaccompanied alien child” (UAC) who was paroled between February 24, 2022, and September 30, 2024. The spouse, child, parent, legal guardian, or primary caregiver are eligible for these benefits for the term of parole granted, or through a new period of parole if applicable, unless the parole has been terminated by the Secretary of Homeland Security.

For additional information, please see the Department of Homeland Security’s Uniting for Ukraine webpage and Fact Sheet. Persons paroled under the Uniting for Ukraine (U4U) process can obtain a copy of their electronic Form I-94, Arrival/Departure Record, from the U.S. Customs and Border Protection website. This Form I-94 record will include a “UHP” class of admission (COA). Parolees into the United States under U4U may also have one or more of the following:

Ukrainian citizens or nationals (or persons who last habitually resided in Ukraine) who were paroled into the United States outside of the U4U process may also obtain, or may have, the same documentation as those paroled under U4U, but with a general parole COA, such as “DT” or “PAR” listed in their Form I-94, Arrival/Departure Record, and/or a parole stamp in their foreign passport. The “DT” COA indicates parole authorized by U.S. Customs and Border Protection District Office or Port of Entry. The “PAR” COA indicates parole authorized by USCIS.

If third-step verification is required, the financial aid office must ensure they provide one of the documents noted above as part of the third-step verification request. If SAVE can verify that the applicant is a parolee, SAVE will provide a “Parolee-Expires” response and the period of parole. If there is a federal immigration record reflecting Ukrainian citizenship, the SAVE response will also state that the financial aid applicant is a Ukrainian citizen.

Unlike other parolee applicants, eligible beneficiaries paroled into the U.S. from Ukraine are not required to have been paroled for at least one year (although they generally have been), nor are they required to have additional documentation (such as a Form I-797C, Notice of Action, indicating receipt of a Form I-485 Application to Register Permanent Residence or Adjust Status) in order to show that they are “in the U.S. for other than a temporary purpose with intent to become a U.S. Citizen or Permanent Resident” (which is a requirement in under Section 484 of the HEA).

Ukrainian citizens or nationals paroled into the United States outside of the applicable timeframes will be required to comply with the standard parolee procedures as outlined in the bullet “Persons paroled into the U.S. at least one year” above.

Please note that some Ukrainian citizens or nationals may have other immigration statuses or categories that make them eligible for Title IV student aid, such as Refugee or Asylum. These applicants can also have their immigration status/category verified through SAVE.

Afghan citizens or nationals (or those who last habitually resided in Afghanistan) paroled into the U.S. between July 31, 2021, and September 30, 2023 may be eligible as Afghan Special Immigrant Parolees (SI Afghan Parolees) or Non-Special Immigrant Afghan Parolees (Non-SI Afghan Parolees) for resettlement assistance, entitlement programs, and other benefits available to refugees admitted under section 207 of the Immigration and Nationality Act (8 U.S.C. § 1157) until March 31, 2023, or the term of parole granted, whichever is later, unless parole has been terminated by the Secretary of Homeland Security. In addition, Afghan citizens or nationals (or persons who last habitually resided in Afghanistan) paroled into the United States after Sept. 30, 2023 are eligible for these benefits if they are the spouse or child of an Afghan paroled between July 31, 2021 and Sept. 30, 2023, or the parent or legal guardian of an unaccompanied Afghan child who was paroled between July 31, 2021 and Sept. 30, 2023.

SI Afghan Parolees may have a separate Form I-94 with the following notation:

SI Afghan Parolees may also have a Form I-766, Employment Authorization Document (EAD), with a C11 parolee category. SI Parolees will receive the “Parolee-Expires” or “Parolee-Indefinite” response in SAVE, with SQ4 or SQ5 as the Class of Admission (COA).

Other applicants from Afghanistan may be eligible as Non-Special Immigrant Afghan Parolees (sometimes referred to as “humanitarian parole” or “OAR parole”). These students may also have an Employment Authorization Document (EAD), with a C11 category or a CBP “PAROLED” stamp in their passport. Some of these passports may have an “OAR” notation in the parole stamp. DHS recently began using this code to help distinguish these Afghans from other parolees. Non-SI Afghan Parolees will receive the “Parolee-Expires” or “Parolee-Indefinite” response in SAVE, with OAR, PAR, or DT as the Class of Admission (COA). For more on Afghan arrival categories and documents, see DHS-SAVE’s Afghan Fact Sheet.

Unlike other Parolee applicants, neither SI Afghan Parolees nor Non-SI Afghan Parolees are required to have been paroled into the U.S. for at least one year (although they generally have been), nor are they required to have additional documentation to show that they are “in the U.S. for other than a temporary purpose with intent to become a U.S. citizen or Lawful Permanent Resident.” This flexibility is a result of the Afghanistan Supplemental Appropriations Act, 2022 and only applies to Afghans paroled between July 31, 2021, and September 30, 2023, or Afghans paroled into the United States after Sept. 30, 2023 if they are the spouse or child of an Afghan paroled between July 31, 2021 and Sept. 30, 2023, or the parent or guardian of an unaccompanied Afghan child who was paroled between July 31, 2021 and Sept. 30, 2023. This flexibility lasts until March 31, 2023, or the term of parole granted, whichever is later, unless the parole is terminated by the Secretary of Homeland Security. After that time, the Afghan arrival will be required to comply with the standard parolee requirements. For more details, see Dear Colleague Letter GEN-23-04.

Cuban-Haitian Entrant as defined by Section 501(e) of the Refugee Education Assistance Act of 1980. Cuban-Haitian entrant designation relates to benefit eligibility rather than an immigration status. All Cuban-Haitian entrants are potentially eligible for federal student aid. Note that certain documents showing that the holder is a Cuban-Haitian entrant may continue to demonstrate an individual meets the Cuban-Haitian entrants definition even if the expiration date has passed. Please see Information for SAVE Users: Cuban-Haitian Entrants for examples of documentation, SAVE verification procedures, and other information regarding Cuban-Haitian entrants. If you are not sure whether documentation establishes that someone is a Cuban-Haitian entrant, submit it as part of a third-step verification request following the instructions in the SAVE Cuban-Haitian entrant information sheet. The SAVE response will let you know (in the “Cuban/Haitian Immigration Details” section) whether the submitted information and documentation is sufficient to verify that the student is a Cuban-Haitian entrant. Remember to select the Cuban/Haitian Entrant Button in SAVE to verify whether the individual meets the Cuban-Haitian entrant definition. DHS will not verify Cuban-Haitian entrants if you do not select this button.

Victims of a severe form of trafficking in persons are eligible for federal benefits to the same extent as refugees under the Victims of Trafficking and Violence Protection Act (VTVPA). The Department of Health and Human Services (HHS), rather than the DHS, is responsible for certifying individuals that may have an I-94 with a T1 Class of Admission code for principal T nonimmigrants (other T-visa classifications will be identified through DHS’ SAVE process noted below). Because of this, these students will not pass the DHS match, and the normal paper third-step confirmation does not apply. You must instead review the student’s certification or eligibility letter from the HHS and call the Office on Trafficking in Persons at 1-866-401-5510, as noted on the letter, to verify its validity and confirm that the eligibility has not expired. You must note the date, time, and results of the call and retain a copy of the letter. If the student applies for federal student aid in a subsequent year at your school, you must call again to ensure that the student’s status is still in force.

Individuals granted derivative T nonimmigrant status are also eligible for federal benefits to the same extent as refugees, under the VTVPA, but do not require a certification or eligibility letter from HHS. Derivative T nonimmigrants will have a Form I-94 with a T-2 (spouse), T-3 (child), T-4 (parent), T-5 (sibling under age 18), or T-6 (adult or minor child of derivative beneficiary) Class of Admission code. SAVE can verify the immigration status of these derivative T nonimmigrants. Once SAVE returns a third-step response, you should see “T2,” “T3,” “T4”, “T5”, or “T6” under the Class of Admission (COA) heading. If you do not see one of those codes in the SAVE response, but you believe that the individual is in fact the spouse, child, parent, or sibling of a victim of human trafficking, or the adult or minor child of a derivative T beneficiary, please email applicationsystemsdivision@ed.gov for assistance. SAVE may also return a response that indicates the individual would be ineligible (such as “nonimmigrant” or “application pending”). These statuses are usually not eligible for federal student aid; however, if any of the COAs noted above are indicated in the SAVE response you can disregard any reference to an ineligible status in the SAVE response.

Battered or Abused Spouses or Children adjudicated by DHS as victims of abuse by their U.S. citizen or lawful permanent resident (LPR) spouse, former spouse, or parent may, with their designated children, self-petition for immigration classification under the Violence Against Women Act (VAWA) and be eligible for certain federal and state public benefits, including federal student aid. Note that both men and women may be approved as victims under VAWA.

These applicants can indicate on the FAFSA form that they are "eligible noncitizens," though they will not pass the automated DHS match. Instead, they will need to obtain and provide you with documentation based on their case type: self-petition, prima facie, suspension of deportation, or cancellation of removal. Check the student’s documentation carefully. If the immigration documents match the description below for an approval of petition or a prima facie case, the student should be considered an "eligible noncitizen." Third-step verification through SAVE is not required.

If you have reservations about the documentation provided, or are unclear about the outcome reflected in the documentation, you must submit the student’s documentation for third-step verification through SAVE. In SAVE, select the “VAWA” button (in the “Agency Requests” section) for VAWA Verification. You will determine the student’s eligibility for aid based on the result of the submission.

In self-petitioning cases under VAWA, the immigrant submits a petition (Form I-360, Petition for Amerasian, Widow(er), or Special Immigrant) to USCIS, who will then either deny the petition, approve it, or make a finding that a prima facie case has been established. If USCIS determines that a self-petitioner has demonstrated prima facie eligibility, USCIS issues a Notice of Prima Facie Case (NPFC) to the self-petitioner. Either a Form I-360 approval or a prima facie finding potentially makes a student eligible for Title IV aid. In some cases, USCIS will acknowledge receipt of a petition, which does not establish eligibility for Title IV aid.

With an approval of a petition, USCIS will provide a Form I-797, which will indicate it is an approval notice (with “Notice Type: Approval Notice”) for a self-petitioning spouse of a U.S. citizen or LPR (with Section: Self-Petitioning Spouse of USC or LPR), and that the petition has been approved. A separate Form I-797 will be issued with the names and dates of birth of children listed by the applicant, and it will indicate that they are named on the approved petition. These children are potentially eligible for Title IV aid, and because their USCIS status continues after reaching the age of majority, their eligibility for aid continues as well. In some cases, a dependent child can petition for battered immigrant status; the Form I-797 would then indicate a self-petitioning child of a U.S. citizens or LPR.

If you submit prima facie documentation for third-step verification, SAVE may return the “VAWA Self-Petitioner” response. SAVE may provide a different response so you must also check the “Victim of Abuse” section. If you see an indication of an approved self-petition or prima facie VAWA status anywhere in the SAVE response, the applicant is eligible. If you have questions about the response, contact applicationsystemsdivision@ed.gov.

Self-petitioners may use the NPFC as evidence to establish their eligibility for certain public benefits and are eligible to renew their NPFC, as needed, until USCIS completes adjudication of the self-petition. NPFCs are initially valid for one year. If USCIS has not made a decision on the self-petition by the time the NPFC expires, USCIS automatically sends a renewed NPFC within 60 days of the expiration date. The NPFC is renewed for 180 days and continues to be renewed for 180-day periods until USCIS adjudicates the self-petition. If the Form I-360 is denied, USCIS does not re-issue or extend the NPFC.

If the student’s documentation for the applicable award year is unexpired when you receive it, the student can be considered eligible for the entire award year. The student will remain eligible even if their documentation expires during the award year. Note that the student would be ineligible for a subsequent award year if the student’s documentation is still expired. Also, if the documentation is expired when you receive it, the student is ineligible unless they provide you with documentation showing that their determination has been extended.

Children may be included on the Form I-797, though their eligibility is subject to the same expiration date. If a spouse is ultimately denied approval, their children on the Form I-797 would also be denied and be ineligible for aid.

If you submit prima facie documentation for third-step verification, SAVE may return the “VAWA Self-Petitioner” response. SAVE may provide a different response so you must also check the “Victim of Abuse” section. If you see an indication of an approved self-petition or prima facie VAWA status anywhere in the SAVE response, the applicant is eligible. If you have questions about the response, contact applicationsystemsdivision@ed.gov.

An immigration judge may issue a suspension of deportation or cancellation of removal of the abused person under VAWA. For a suspension of deportation, the applicant will receive a copy of the court order. If it clearly indicates suspension of deportation by the judge, and there is no finalized appeal overturning the order, an otherwise eligible person can receive Title IV funds. For a cancellation of removal, the applicant will receive a copy of the court order. If it clearly indicates cancellation of removal by the judge, an otherwise eligible person can receive Title IV funds. Suspension of deportation or cancellation of removal documentation alone does not make a student eligible for Title IV funds. The documentation must reference a self-petition or prima facie determination for the student to be considered potentially eligible.

You must carefully examine the USCIS or immigration court document and keep a copy in the student’s file. If it indicates that the student is an approved self-petitioner or has an unexpired prima facie determination, you may award aid if the student is otherwise eligible. If a self-petitioner applies for Title IV funds in a subsequent year, you may rely on their original document. For a student with a prima facie determination, you may rely on their document if it is still unexpired. If the documentation has expired, the student is ineligible unless they provide you with documentation showing that their determination has been extended. You must select the "VAWA button" in SAVE before submitting a student's documentation, or SAVE may not confirm VAWA status.

Section 289 of the Immigration and Nationality Act (INA) gives persons with at least 50% American Indian blood who were born in Canada the legal right to live and work indefinitely in the U.S. They must obtain an SSN for purposes of applying for Title IV aid.

These students must enter their valid A-Number on the FAFSA form and indicate they are eligible noncitizens. If they fail the DHS match, you must submit a third-step verification with the student's documentation. If they fail third-step verification, they can still be considered eligible if they meet the documentation requirements below for students without an A-Number.

Students who do not have an A-Number should enter A999999999 and indicate they are eligible noncitizens. Students who enter all 9’s for their A-Number will receive comment 289 on the output document indicating that the A-Number provided is invalid. A DHS case number will not be generated in this instance, so you will not be able to submit a third-step verification request. Instead, if an American Indian born in Canada claiming Title IV eligibility under the Jay Treaty received Title IV aid in the 2023-24 award year (or any prior award year), then the institution may elect under 34 CFR 668.133(b) to not require such a student to submit additional immigration documentation to establish their title IV eligibility where the documents used to establish that eligibility have not expired, and where the institution does not have reason to believe that the student’s claim of citizenship or immigration status is incorrect.

If an American Indian born in Canada claiming Title IV eligibility under the Jay Treaty did not previously receive Title IV aid in the 2023-24 award year (or any prior award year) and is seeking to establish their status as an eligible noncitizen for the 2024-25 award year or later, then the student may submit any of the following immigration documentation to establish Title IV eligibility:

If you have questions about students who are American Indians Born in Canada, contact applicationsystemsdivision@ed.gov. See also DCL GEN-25-06.

DHS Customs and Border Protection (CBP) creates admission records electronically. The Form I-94 website allows travelers (and schools, if the traveler grants permission) to access admission records online (the website contains records from April 2011 to present). Unexpired paper Forms I-94 are also still valid.

CBP began issuing Forms I-94 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 SAVE response from the third-step verification. For the purpose of applying for Title IV aid, your school's policy may permit students to legally photocopy, scan, or otherwise image immigration documents (such as Forms I-551 or I-94) and submit either electronic images or paper copies of the same to the school’s financial aid office to facilitate the confirmation of their status/category and to complete the third-step verification process. See Dear Colleague Letter GEN-15-08 for more details.

When an eligible noncitizen student changes their name, the student needs to update it with SSA and DHS. To update their name with DHS, students can contact the USCIS Contact Center at 800-375-5283 or visit the USCIS Immigration Documents and How to Correct, Change, or Replace them page. For the SSA update, the student must bring the appropriate documents to substantiate the change to their local SSA office. Visit https://www.ssa.gov/personal-record/change-name.

There are several types of documentation that do not substantiate a student’s eligibility for Title IV aid. If a student provides multiple documents and some do support eligibility, they may be eligible for Title IV aid. However, if a student only provides documentation that does not substantiate their eligibility for Title IV aid, they are not eligible. Generally, if a student has both an eligible 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 aide (pending other aspects of student eligibility, as discussed in this volume).

There are a variety of forms and their related statuses which are all ineligible:

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 requests you to do so. USCIS will only confirm current immigration status/category based on the document presented; it doesn’t determine whether the student is eligible for Title IV funds (the student must meet all other student eligibility and Title IV program-specific criteria in addition to citizenship/immigration status requirements). Unless the student can submit documentation for an eligible status/category, as described above, or USCIS verifies the student’s immigration status/category, the student can’t receive aid.

If the student’s immigration documentation appears to support an eligible noncitizen status/category, if you have conflicting information after receiving the match result, or if the student disagrees with the SAVE result, you must complete a third-step verification request through SAVE. USCIS will return third-step verification responses via SAVE.

To access SAVE at https://save.uscis.gov/save/app/client/ui/home a unique SAVE user ID and password is issued to the Primary Destination Point Administrator (PDPA) at each school when they update their school’s FTI SAIG Enrollment form. Note that accessing SAVE may soon require logging in using login.gov. More information will be available in the future.

All the instructions you need to access and navigate the SAVE system are available on the DHS-SAVE, Eligible Noncitizen page on the Knowledge Center. Select the “DHS-SAVE Electronic Third-Step Verification” link.

For assistance with issues related to SAVE access, please contact applicationsystemsdivision@ed.gov.

First, request the student’s most current, unexpired immigration document, following the requirements outlined in the Student Rights in Third-Step Verification section later in this chapter. When you receive it, make a copy of it. Next, carefully review the student’s immigration documentation against the status and document descriptions above. Finally, determine whether the student’s immigration documentation supports eligibility for Title IV aid. If it does not support an eligible status, you can tell the student that they are not eligible now but may be eligible if/when they provide evidence of an eligible noncitizen status/category or U.S. citizenship. You should not complete third- step verification for this student. If you are unsure of whether documentation supports eligibility for Title IV aid, submit a request for third-step verification to SAVE if the applicant provides documentary evidence of meeting the U.S. citizen or eligible noncitizen requirement for federal student aid.

If you determine that third-step verification 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 FAFSA Partner Portal system, formerly FAA Access. This replaces the “requesting a new DHS verification number” process. For the full instructions, 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 4.0 document.

SAVE processing times for third-step verification may vary, depending on the complexity of the case. You will receive an email from SAVE when the response is available. More information on SAVE’s processing times is available on the SAVE Verification Response Time page.

If you receive the “No cases found” message in SAVE, do not “Resend Record to Matches” in the FAFSA Partner Portal, to generate a new transaction with a new DHS Case Number. Doing so generates a new SAVE case for the student while the first case is still processing and will result in a slower response.

For additional guidance on SAVE and DHS Match Flags, see the SAVE Instructions for U.S. Department of Education (School) Users 4.0 document on the DHS-SAVE Electronic Third-Step Verification page.

SAVE third-step verification is a manual search of available immigration records. 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/category, you should review the student’s file and determine whether they meet the eligible noncitizen requirements. If the student meets the requirements, make any disbursement for which they are eligible and note in their 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 or category, you must keep a copy of the SAVE response screen. If the third-step verification process indicates a discrepancy, you must ask the student to correct the discrepancy with the appropriate DHS agency. No certification of loans or further disbursement of funds can be made until the record is corrected. If the discrepancy isn’t reconciled, the student must repay all aid except wages earned under FWS. Whenever the student can provide new information, it must be submitted to SAVE 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.

SAVE is responsible for verifying the student’s immigration status/category. The SAVE response does not indicate 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 with the student’s documentation, and supports an eligible status/category, then the student is eligible (assuming they meet all other student and program eligibility requirements). 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.

If the student’s documentation supports an eligible status but the SAVE response shows an ineligible status, read the DHS comments and resolve any issues raised there (for example, provide a legible copy of the student’s documentation if instructed by SAVE). Once resolved, check the bottom of the SAVE response. If you see a “Still not sure? Institute Additional Verification” link, select the link and submit the student’s new documentation on the next page. If you do not see this link or the student’s case is closed, 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 applicationsystemsdivision@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/categories, see the earlier sections on eligible and ineligible statuses and their documentation:

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 Permanent Resident - Employment Authorized), ignore the ineligible status portion of the response. Unless an additional eligible status is also submitted, or the student can provide other documentation that can be confirmed by USCIS, students for whom the SAVE response is solely one of the following are not Title IV eligible:

If you see the “Resubmit Doc” response, this means that this case is available for you to submit the student’s immigration documentation for third-step verification. If you have questions about how to proceed, contact applicationsystemsdivision@ed.gov and provide a brief description of the issue and the student’s DHS Case Number.

You must allow the student at least 30 days from the time you receive the SAVE response indicating an ineligible status/category to provide documentation of an eligible immigration status/category. During this period and until the results of the third-step verification are received, you can’t deny, reduce, or terminate aid to the student. Unless you can determine that the documentation doesn’t support an eligible noncitizen status/category, you must submit the student’s immigration documents to SAVE within ten business days of receipt. After submitting the documentation to SAVE, if at least 15 business days pass without a response, you can disburse aid to an otherwise eligible student pending the SAVE response if the documentation supports the student’s status as an eligible noncitizen and you don’t have any conflicting information.

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

The student (or parent borrower of a Direct PLUS loan) is liable for any Title IV funds received if they are 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 their ineligibility and given an opportunity to contest the decision by submitting to your school any additional documents that support their claim to be an eligible noncitizen. If the documents appear to support the student’s claim, you should submit them to SAVE 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/category in a subsequent award year if that student is not confirmed as an eligible noncitizen on the FAFSA Submission Summary/ISIR. For example, a student who presented a Temporary Form I-551 in a prior award year should have received a permanent Form 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 Form I-551 or an updated endorsement on the previous card.

You must also document the eligible noncitizen status/category each award year for:

Students in any of these categories may have been redesignated to lawful permanent resident status or may have had their status/category end or be revoked or terminated. You will have to send the documents for third-step verification if the student’s status or category isn’t confirmed through the DHS match. Also note that VAWA prima facie status generally expires after 1 year, and that parolees can potentially become Lawful Permanent Residents if their Form 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 their official DHS documentation because it is lost, stolen, or damaged, the student must request that the documents be replaced. Individuals who are not U.S. citizens and who are 18 years and older must always have immigration documentation in their possession while in the United States. Requests for replacement of USCIS documents should be made by the student to USCIS. Instructions for replacing documents can be found on the USCIS page Immigration Documents and How to Correct, Update, or Replace Them or by calling the USCIS Contact Center at 800-375-5283. More information about correcting records and replacing documents with DHS is also available in the SAVE Records Fast Facts for Benefit Applicants.

To replace a Form I-551 (permanent resident card) students may need to complete a Form I-90, Application to Replace Permanent Resident Card. To replace a Form I-94, students may need to complete a Form I-102, Application for Replacement/ Initial Nonimmigrant Arrival-Departure Document if the student is unable to obtain their Form I-94 from the CBP I-94 website. PDF versions of these and other forms can be downloaded from the USCIS website at https://www.uscis.gov/forms/all-forms. A temporary I-94 may be issued while the replacement documents are pending. If the student needs to replace other immigration documentation, including naturalization or citizenship certificates, they should visit the USCIS pages linked to in the paragraph above . Students can also contact the USCIS Contact Center.

In cases of undue hardship, where the student urgently needs documentation of their status/category, the Freedom of Information Act (FOIA) allows them 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 request the records online. A student who lost a Certificate of Naturalization or Certificate of Citizenship for any reason may file Form N-565, Application for Replacement Naturalization/Citizenship Document, to obtain a replacement from USCIS. Alternately, the student could apply for a U.S. Passport as proof of citizenship.

A naturalized U.S. citizen student who lost documents or surrendered them when entering prison is responsible for getting copies of them so you can verify their status. You can request copies of immigration documents directly from penal institutions at the request of the student.

If you can 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 form, 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: https://www2.ed.gov/about/offices/list/oig/index.html.

Some common documents used to demonstrate citizenship and eligible immigration status/categories are shown on the USCIS Commonly Used Immigration Documents page.