The U.S. Department of Education (the Department) appreciates the support from institutions to safeguard the integrity of the Title IV, Higher Education Act (HEA) programs. The Department is committed to being a good partner to schools and to minimizing administrative burden while protecting taxpayers, states, and institutions from bad actors seeking to misuse federal funds.
For more information on the real-time Free Application for Federal Student Aid (FAFSA®) fraud detection process, please see Electronic Announcement APP-26-03.
Question 1.1. When student applicants are presented with the identity confirmation process within the FAFSA form, can they use a laptop or desktop with an enabled camera to complete the process?
A: No. At this time, the student applicant is required to complete the process on a mobile device. However, the applicant can use any mobile device available to them at the time they are completing the FAFSA form, such as a parent’s mobile phone or a counselor’s tablet. The applicant does not need to personally own the mobile device used to complete the process.
Question 1.2. Does an institution have to require in‑person identity confirmation to clear fraud rejects?
A: No. Federal Student Aid (FSA) has provided a variety of options to complete identity confirmation using the methods available under V4/V5 identity verification guidance. If a student is unable to appear in person, you must provide the student with these options. Electronic Announcement APP-25-16, posted on June 6, 2025, provides additional information on the options available to complete identity confirmation.
Question 1.3. When are students evaluated for fraud within the FAFSA process?
Students are evaluated for fraud upon initial submission of their FAFSA form. Any student who has not been previously evaluated will be evaluated when they submit a new correction online. Students filling out a subsequent FAFSA form in a new award year cycle may be evaluated again depending on fraud signals and time since they completed a previous year's form. Corrections submitted by financial aid administrators via the FAFSA Partner Portal or via EDE batch correction are not evaluated for fraud.
Finally, as described in Electronic Announcements APP-26-03, 2026-27 FAFSA applications submitted before the launch of real-time fraud detection went through a one-time fraud detection screening. These applications are considered evaluated for fraud to avoid duplicate screening and will contain both the V5 Verification flag and the 353 comment code.
Question 2.1. The Department has indicated that applicants with a fraud-related reject code have a high risk of fraud. Can a school choose not to provide the student with the option to complete identity verification and instead simply decline to process federal aid for the student?
A: If a student is not enrolled and not admitted for enrollment in a school, then the school is under no obligation to perform identity verification or respond to requests from the potential student. Schools can make decisions about enrollment and offers of admission accordingly.
However, schools cannot maintain a policy to not process aid for enrolled or admitted students identified as moderate-, high-, or highest-risk on their Institutional Student Information Record. If an enrolled or admitted student with a fraud-related reject or comment code contacts your school for resolution, you must work with that student to confirm their identity using one of the in-person or video call options outlined in Electronic Announcement APP-25-16 for V4/V5 identity verification. If the student successfully completes the identity confirmation process to your school’s satisfaction, you must continue to process their federal student aid.
Question 2.2. Why are some high‑risk cases being selected for V5 rather than V4 if the underlying issue is identity?
A: This is a technical limitation of FSA’s systems. Institutions are required to verify only financial information provided by the applicant. When financial data is transferred from the Internal Revenue Service (IRS) via the FUTURE Act Direct Data Exchange (FA-DDX), it does not need to be verified by the school.
Question 2.3. For applicants flagged as “moderate risk” (e.g., code 353), the action needed says “encouraged to conduct verification.” Does this mean the school should select these students for V4/V5?
A: FSA is providing this flag for informational purposes only. Since FSA’s fraud detection system determined abnormal activity, schools may want to complete additional identity confirmation and/or verification for these applicants. You do not need to use the “FAA Fraud Override Field” for these applicants as they will not be in a rejected status in the FAFSA Processing System (FPS).
Question 2.4. What actions are required for Comment Code 360 (e.g., Risk Evaluation Could not be Performed)? Will those records be reevaluated automatically?
A: FSA does not anticipate using this code often. However, if we are unable to perform the real-time fraud detection and identity confirmation process at any time due to system issues, we will use this comment code so as not to delay or block an applicant from submitting a FAFSA form. Institutions are not required to take additional action as a result of Comment Code 360. A student who receives this flag will be reevaluated if they complete a correction.
Question 3.1. Where is the FAA Fraud Override field in the FAFSA Partner Portal?
A: The FAA Fraud Override field is located in the “FAA Information” section of a transaction in the FAFSA Partner Portal (FPP). A screenshot of the field is available in Electronic Announcement APP-26-03.
Question 3.2. Are we required to accept another school’s fraud override, or can we require the student to verify identity with our institution’s process and standards?
A: Schools are not required to use another school’s determination. Electronic Announcement APP-26-03 specifically says, “Schools MAY use the identity confirmation performed by another institution if they have no reason to suspect fraud or conflicting information.” A school may also choose to do their own identity confirmation. From a processing perspective, when a school puts in a fraud override, a new transaction will be generated for all schools. This new transaction will have a comment code noting that a school has performed a fraud override.
Question 3.3. Could there be conflicting override decisions?
A: It is conceivable that School A processes a fraud override and then School B changes the value of that field on a subsequent transaction to indicate that the student failed identity confirmation. This is similar to conflicts in dependency status or other fields that FAAs can impact. We do not anticipate this to be a common occurrence.
Question 4.1. Are students attending foreign schools exempt from the identity confirmation process?
A: No. There are no exemptions from this process based on where the student is located or attending school. While students attending foreign schools are exempt from verification, they will still be expected to complete the identity confirmation process, if they are flagged as potentially fraudulent. The identity confirmation process based on real-time fraud detection is separate from verification requirements.
Question 4.2. Are incarcerated students exempt from the identity confirmation process?
A: No. Incarcerated students will not be exempted from the real-time fraud evaluation or identity confirmation process. An incarcerated student may complete identity confirmation during the FAFSA application process if they have access to a mobile device and an acceptable form of identification. If they are unable to complete identity confirmation at the time of application, they will be able to submit their FAFSA form, but it will be rejected (Reject 74) and will have a comment code (Comment Code 353 or 354). The institution can then work with the student to complete identity confirmation using the flexibilities provided for incarcerated students as outlined in Electronic Announcement APP-25-16 and the Application and Verification Guide of the Federal Student Aid Handbook.
Question 4.3. Are other contributors, such as parents, subject to identity confirmation?
A: No. Only the student applicant is subject to identity confirmation.
Question 4.4. If a student applicant is flagged for identity confirmation and does not successfully complete the process, will they be able to invite other contributors? Will those invited contributors be able to complete their section(s) of the form?
A: Yes. The evaluation for real-time fraud detection occurs at the end of the student’s form (using data and inputs from throughout the form), after the student has invited any contributors.
Question 5.1. When and how should schools report suspected fraud to the Office of the Inspector General (OIG)?
A: If a school, during the course of its review, discovers that an individual knowingly provided false information or engaged in deliberate misconduct, the school must refer any credible information indicating that an applicant for Title IV, HEA funds may have engaged in fraud or other criminal misconduct in connection with their application to the Department’s OIG. They would do this through the OIG Hotline.
Question 5.2. If aid was disbursed in the current or a prior award year and we later determine that the student’s application was fraudulent, are we required to return funds?
A: A school’s fiduciary responsibility extends to ensuring that Title IV funds are disbursed only to students who meet all statutory and regulatory eligibility requirements. Under the Program Participation Agreement (34 CFR 668.14), a school agrees that it will comply with all statutory and regulatory requirements applicable to Title IV, which includes disbursing Title IV funds only to eligible students.
The Department advances Title IV funds in reliance on the school’s certification that each student meets all applicable eligibility requirements under 34 CFR 668.32. If a student is later determined to have been ineligible for Title IV, regardless of whether the school had actual knowledge of the ineligibility at the time of disbursement, the Title IV funds are considered improperly disbursed and must be returned to the appropriate Title IV program.
This applies even in cases involving fraud, where the school did not have verification flags or other indicators at the time of disbursement. The absence of prior knowledge or verification selection does not relieve the school of responsibility if the student was not, in fact, eligible under the statute or regulations. The financial responsibility for improper payments lies with the school. This allocation of risk reflects the structure of the Title IV programs, which places primary responsibility for front-end eligibility determinations and proper disbursements on participating schools.
As part of their fiduciary responsibility, schools must maintain effective internal controls and monitoring procedures to detect and prevent fraud and other improper payments to ensure that Title IV funds are used only for their intended purposes.