This announcement provides an update to Electronic Announcement GENERAL-24-53 and describes a temporary change to the Department of Homeland Security’s (DHS) Systematic Alien Verification for Entitlements (SAVE). The temporary change to DHS’ SAVE allows institutions to complete third-step verification for applicants who indicate they are an eligible noncitizen on the FAFSA form but fail the DHS primary match process and have a secondary match status of “pending.”
Background
As previously announced, the secondary match process with the DHS is not currently available. Students who fail the primary DHS match are indicated as pending in the “DHS Secondary Match Status” field of the Institutional Student Information Record (ISIR). Historically, institutions have been unable to view or resolve cases that are pending review under the secondary match process. Institutions that attempt to resolve DHS match flags related to an applicant’s eligible noncitizen status on the ISIR by searching for the applicant’s case in the SAVE system receive a “No Cases Found” message, preventing institutions from submitting a third-step verification request to DHS. This effectively prevents institutions from being able to make Title IV eligibility determinations for a portion of noncitizen students who may meet the eligible noncitizen criteria.
Interim Solution
To mitigate this issue, the Department has collaborated with the DHS to implement a temporary change that will allow institutions to access pending DHS secondary match cases. DHS has updated SAVE permission levels for third-step users and third-step supervisors, making these cases viewable when you search for them in the SAVE system.
As a result, if the DHS Primary Match Status (Field 557) is “N” (Not confirmed eligible noncitizen) and the DHS Secondary Match Status (Field 558) is “P” (Pending), institutions should search for the case in the SAVE system and proceed with the third-step verification process as outlined in the FSA Handbook, Volume 1, Chapter 2. Please be aware that you will not receive an updated ISIR for the student and the DHS Secondary Match Status will remain in the pending status. However, if (in addition to the outcomes of the third-step verification process outlined in the FSA Handbook) the institution determines that the student meets all other eligibility requirements for federal student aid, the institution may proceed with awarding and disbursing aid to the student.
Because of the backlog of cases caused by the delay in the DHS secondary matches, the Department and DHS acknowledge possible delays in institutions receiving responses from DHS after documentation is submitted via SAVE. The Department reminds institutions that if a response is not received from the U.S. Citizenship and Immigration Services (USCIS) after at least 15 business days from the date the third-step verification request was sent, the institution may award and disbursed eligible title IV aid if the institution has sufficient documentation to make a decision, and the institution has no information that conflicts with the student’s documents or claimed status/category. The institution must also document in the student’s file that the 15-day timeframe has elapsed and that the institution is making a determination based upon the immigration documentation presented (which should also be kept in the student's file). Institutions should note, as previously stated, that the student must continue to meet all other student eligibility criteria as well.
If the formal third-step verification response from USCIS later indicates a discrepancy, the institution must ask the student to correct the discrepancy with the USCIS. As long as the institution has followed the Department’s third-step verification procedures as outlined in the FSA Handbook, including notifying the student of the discrepancy and withholding further payments and loan certifications as soon as a discrepancy is found, an institution will not be liable for aid disbursed prior to third-step verification. If the discrepancy is not reconciled, the student must repay all aid except wages earned under FWS.
We are also aware of an issue which resulted in some cases ending up in a closed status, even though the student received an “N” for the DHS Primary Match Status. If you find an applicant in this situation, please navigate to FAFSA Partner Portal (FPP) to use the “Resend to Matches” functionality and submit a correction. The field is located at the top of the form in the “FAA Information” section of the correction form in FPP. Select “Yes” from the dropdown next to the “Resend to Matches” field; you do not need to change any other fields.
As a reminder, this workaround is based on a temporary change to DHS’ SAVE system. Once the appropriate FAFSA Processing System (FPS) updates are in place, the Department will notify institutions when to resume following normal system procedures.
Contact Information
For additional guidance on the DHS-SAVE system and the DHS Match Statuses, see the SAVE Instructions for U.S. Department of Education (School) Users 4.0 document located on the DHS-SAVE Electronic Third Step Verification page of the Knowledge Center website.
For assistance with interpreting a SAVE response or any other questions you might have, please email the student’s DHS Case Number to applicationsystemsdivision@ed.gov.