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?
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