In a moment of bipartisan cooperation, Sens. Lamar Alexander (R-TN) and Michael Bennet (D-CO) wrote a letter last week, urging the Department of Education (ED) to reinstate alternative documentation options for independent students and parents of dependent students selected for verification of nonfiling (VONF) status.
In the letter, which was sent to Education Secretary Betsy DeVos on Wednesday, the senators argued that ED should reinstate for the 2018-19 FAFSA application cycle the documentation options outlined in Dear Colleague Letter GEN-17-04, which applied to both the 2016-17 and 2017-18 FAFSA processing and verification cycles.
"We know that this overall verification process can pose a significant barrier to students and their families," the letter said. "When students are unable to meet FAFSA verification requirements, they cannot receive Federal Pell Grants or Direct Loans."
The senators acknowledged that last year, financial aid administrators reported increased verification selection rates, and that the trend has continued this year. ED first introduced the VONF documentation requirement in the 2017-18 award year after the IRS reported that 14.46 percent of parents and 16.51 percent of students who reported on the FAFSA that they had not completed a tax return had, in fact, filed taxes.
However, the senators noted in their letter, the IRS data used in the analysis was based on FAFSA applications from the 2014-15 award year, when applicants were still required to use tax information from the immediate prior year.
"Since students and families use the immediate prior year tax information, many applicants had to file their FAFSA before filing or determining if they had to file Federal taxes for 2013," the senators wrote.
NASFAA similarly wrote to ED in July 2017 on the same issue, asking ED to keep the alternative documentation requirements in place "until additional data and a cost-benefit analysis can be conducted to determine the utility of the VONF requirement."
The senators went on to highlight the difficulty some students and parents have in obtaining the VONF documentation in the first place. In order to obtain the documentation, applicants must go through the IRS Get Transcript service online, and provide authentication information that may include a bank account number or a cell phone account. If the applicants are unable to provide that information — as is the case for many low-income individuals — then the only other option is to retrieve the documentation through through the mail, which can take five to 10 business days.
"We fear that the VONF requirement may be deterring students from enrolling or continuing their higher education, especially low-income students," the senators wrote. "In addition, institutions are reporting that a majority of students who completed verification with a VONF documentation saw no change to their Expected Family Contribution or Pell Grant eligibility. This would suggest that the requirement is doing little to prevent improper payments."
The senators requested that ED not only reinstate the alternative documentation options, but also provide data on improper payments from the VONF population from the 2017-18 FAFSA cycle and part of the 2018-19 cycle to examine "the costs and benefits of solely accepting the VONF document for verification purposes."
Publication Date: 5/21/2018