To provide relief to millions of students and colleges facing challenges and barriers resulting from the ongoing national emergency, we are focusing this award year’s effort strictly on identity and fraud. This means we are waiving verification of most Free Application for Federal Student Aid/Institutional Student Information Record (FAFSA®/ISIR) information, except for Identity/Statement of Educational Purpose and High School Completion Status under Verification Tracking Groups V4 and V5. This waiver may apply no matter where institutions are in the verification process, e.g., if documents have been collected or requested, but verification has not been completed, or if an institution has not started the verification process. However, this does not exempt institutions from reviewing all documents for conflicting information concerning a student’s eligibility. Please see the section below, “Reviewing Subsequent ISIR Transactions and Resolving Conflicting Information,” for more information. This waiver begins July 13, 2021, and applies for the remainder of the 2021-2022 FAFSA processing and verification cycle.
Institutions maintain the discretion to select students for verification according to consistently applied institutional policies. However, the Department encourages institutions to consider amending such policies to limit selection in a manner that offers relief to students and families during the ongoing national emergency.
Verification of Identity/Statement of Educational Purpose
Institutions are reminded that we have suspended the in-person submission and notary requirements for verification of Identity/Statement of Educational Purpose, and provided other flexibilities, as described below, through the end of the payment period that begins after the date on which the Federally declared national emergency related to COVID-19 is rescinded.
In completing the verification requirements for the Identity/Statement of Educational Purpose, as described in this DCL, and outlined in the “FAFSA® Information To Be Verified for the 2021–2022 Award Year” Federal Register notice, institutions may accept—
copies of the required verification documents electronically. This may occur by uploading a photo of the documents (including from a smartphone), PDF, or other similar electronic document through a secure portal at the institution, by email, etc.
an electronic signature using a stylus or finger to sign the statement, or an image of the individual’s signature affixed to the statement in lieu of obtaining a wet signature.
Verification of High School (or Equivalent) Completion Status
Official documentation of high school completion or the equivalent of high school completion may be difficult for students to obtain during this national emergency. For students in verification groups V4 or V5, institutions should use documentation of the student’s high school completion status that they may already have obtained for other purposes (e.g., documentation maintained in the admissions office). The list of acceptable documentation to verify high school completion can be found in the FAFSA® Information To Be Verified for the 2021–2022 Award Year” Federal Register notice.
Reviewing Subsequent ISIR Transactions and Resolving Conflicting Information
Although verification is waived for certain information as explained earlier, institutions are still required to review all subsequent ISIR transactions for the entire processing year, even if an earlier transaction was verified, except if a student is no longer enrolled at the institution.
If an institution has conflicting information concerning a student’s eligibility, including documentation obtained during the verification process, the institution must resolve the discrepancies before disbursing Title IV funds. More information about resolving conflicting information can be found in Chapter 5 of the 2021-2022 Application and Verification Guide.
System Reporting Requirements
Because this change to verification policy is occurring mid-year, many 2021-2022 Central Processing System (CPS) transactions will continue to be selected for verification.
Even if verification is no longer required, institutions must report a valid Verification Status Code for every student selected for verification by the CPS. Institutions should report a “V” (if verification was completed) or an “S”; "blank" is not an acceptable verification status code, except in the case when a student is selected after he or she is no longer enrolled at your institution.
When Verification Is Still Required
Institutions still must verify all students selected for verification of Identity/Statement of Educational Purpose and High School Completion Status under Verification Tracking Flag “V4” and “V5,” unless a student is excluded from verification as provided under 34 CFR 668.54(b). These exclusions are outlined in Chapter 4 of the 2021-2022 Application and Verification Guide.
When Verification Is No Longer Required
Institutions are not required to verify students selected under Verification Tracking Flag “V1” as of the date of this letter. We are expanding the applicability of Verification Status Code “S- Selected not verified” to not only students excluded under 34 CFR 668.54(b), but also to all students selected under V1 who are exempt from standard verification under this guidance.
Changes for the 2022-2023 Award Year and Beyond
The Department will consider what adjustments need to be made to verification long-term to ensure that it is robust and equitable.
These changes will provide some much-needed relief to students and families affected by this ongoing national emergency. We thank institutions for their cooperation and continued role in safeguarding the integrity of the Title IV programs and in preventing improper payments.
Deputy Assistant Secretary for
Policy, Planning, and Innovation