Pop Quiz Update – Must a School Have a Signed Statement to Update Degree Level on the FAFSA?

Scenario: 

The school has a number of students who complete their undergraduate program in December, the end of the fall term, and then go on to their graduate program in the spring. The school runs a report to update the student’s ISIR on their behalf. Should the school be collecting a signed statement to update a student’s status from seeking an undergraduate degree to seeking a graduate degree?

Answer:

No. While a correction to the student's degree/credential level that is used to determine the student's Title IV eligibility must be sent to the Central Processing System (CPS) for reprocessing, the school does not need to collect the student's signature to do so. According to updated guidance NASFAA has received from the U.S. Department of Education (ED), the student's signature is not required when submitting such corrections to the CPS, as long as the institution has and maintains proper documentation that supports the changes submitted to CPS. This can include information substantiated and documented by the school's records and maintained in paper or electronic format within the school's system or financial aid management system (FAMS), such as degree/credential level. All other corrections that are not substantiated by the school's records and that are sent to the CPS require documentation signed by the student or parent, as applicable.

Note: This answer reflects a February 2020 change in ED guidance as a result of NASFAA's efforts to obtain leniency for schools on this issue. ED has indicated that it will be clarifying the FSA Handbook language regarding signature requirements for changes submitted to the CPS.

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Publication Date: 2/27/2020


Tiffany G | 2/27/2020 3:8:02 PM

No, a signature would not be required in this case. Your school has and should maintain records about the appropriate credential level. However, the change must be sent to CPS if it causes a change in Title IV eligibility. For example, if a student indicated graduate student, but they have not yet earned their undergraduate degree and the student is Pell eligible. You know from your records this student is still an undergraduate and correcting the ISIR would affect the student's eligibility for Title IV aid, so it must be sent to CPS. I hope this is helpful!

Christopher D | 2/27/2020 10:1:12 AM

Thank you for asking this question Byron T. Kathryn W, I am also hoping of a notification when his question is answered. Thank you too.

Kathryn W | 2/27/2020 9:43:38 AM

I am wondering the same as Byron T. (Commenting so hopefully I can be notified of the answer!)

Byron T | 2/27/2020 9:40:13 AM

Does this also apply to students who incorrectly indicated receipt of a bacchelor degree or enrolled in graduate school? Would campuses be required to collect a signed statement from the student?

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