2018–19 Verification Requirements Reminder

By Jill Desjean, NASFAA Policy and Federal Relations Staff

The Department of Education (ED) published the 2018–19 verification data elements and documentation requirements in the May 5, 2017 Federal Register (FR) and Dear Colleague Letter GEN-17-05, and provided 2018–19 suggested text for verification in an Aug. 16, 2017 Electronic AnnouncementRelaxed verification requirements stemming from the IRS Data Retrieval Tool outage will not be applied to the 2018-19 award year, and financial aid offices will again be expected to require IRS tax transcripts for applicants selected for verification.

Consistent with its stated timeframe to have the Internal Revenue Service (IRS) Data Retrieval Tool (DRT) – which was disabled in early March 2017 following a data breach – operational in time for the start of the 2018-19 FAFSA cycle, ED indicated in its May 5 communications that it will once again require IRS tax transcripts for income tax filers not using the DRT who are selected for verification in the 2018-19 award year. ED had issued guidance in April 2017 permitting the use of signed 2015 tax returns in place of IRS tax transcripts for verifying 2016-17 and 2017-18 applications following the DRT outage.

Verification of nonfiling status (VONF) letters, waived for 2016-17 and 2017-18 in the same April DRT outage guidance, will be required again for the 2018-19 award year as well, but with one major change: dependent students who are not required to file federal tax returns will no longer be required to obtain a verification of nonfiling status letter from the IRS to satisfy verification requirements. NASFAA pressed ED for relief on the VONF requirement in a December, 2016 letter, citing a lack of data to support the requirement and the burden of obtaining the VONF for applicants.  

Finally, although guidance on required verification items for Auto Zero EFC applicants has been in place since the 2012-13 award year on ED’s Program Integrity (PI) Q&A website, they are published in the Federal Register for the first time for the 2018-19 award year. The FR confirms the PI website’s guidance, which limits required verification items for dependent Auto Zero EFC applicants to parent Adjusted Gross Income (for tax filers), or, alternatively, parent income earned from work (for nonfilers). Independent Auto Zero EFC-eligible applicants are required to verify only student and spouse Adjusted Gross Income, or student and spouse income earned from work (depending on tax filing status) and number of household members (if number of dependents other than a spouse is more than one). All Auto Zero EFC-eligible applicants must still provide high school completion status and identity/statement of educational purpose if they are assigned by ED to a verification group requiring confirmation of these statuses.

Revised: 10/18/2017


Publication Date: 5/11/2017

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