Posted Date:October 31, 2016
|Author:||Jeff Baker, Director, Policy Liaison and Implementation, Federal Student Aid|
Subject: Changes in Verification Tracking Groups (Updated March 3, 2017)
NOTE: The attached chart is updated to clarify that an institution is not required to complete verification if the student is no longer enrolled at the institution when the student was selected for verification.
In Dear Colleague Letter GEN-15-11, posted on June 29, 2015, we announced that, beginning with 2016-2017, some applicants may be moved from a previously assigned Verification Tracking Group of V1, V4, or V6 to Verification Tracking Group V5. Such a change would be based on corrections made to the applicant's CPS record or on other information available to the Department.
The chart attached to this Electronic Announcement expands on the guidance provided in GEN-15-11 by listing the possible changes to an applicant’s Verification Tracking Group. The chart also covers situations where an applicant was selected for verification and filed an income tax return extension. The guidance in this Electronic Announcement and the attached chart applies to both the 2016-2017 FAFSA processing year and to all subsequent years, including the 2017-2018 FAFSA processing year.
The information on the chart shows that, in general, whether a student is initially or subsequently selected for verification, the applicant must complete verification of all the information required for the applicant’s current Verification Tracking Group. Of course information that had previously been verified for the FAFSA year does not need to be re-verified. Failure to complete verification will, in most instances, require the applicant (not the institution) to repay any Title IV aid that had been disbursed. Similarly, if after completing verification, it is determined that the applicant was overpaid Title IV aid, the student (not the institution) is responsible for repaying those funds. The only exception that would place responsibility for repaying Title IV aid on the institution is if the aid was disbursed under the interim disbursement provision of the regulations at 34 CFR 668.58.
We know that prior to this Electronic Announcement, there may have been instances where an institution received a subsequent 2016-2017 ISIR that placed the student into Verification Tracking Group V5 after some 2016-2017 Title IV aid had been disbursed. As provided in attached Chart B, if that student does not satisfactorily complete verification, including verification of identity/statement of educational purpose and high school completion status, the student must return all 2016-2017 Title IV aid that had been disbursed. Again, we remind institutions that under these situations the institution is not liable for the return of any of these funds.