ED Publishes Verification Requirements for 2022-23, Excludes Existing Waivers

By NASFAA Policy & Federal Relations Staff 

The waiver of verification of most Free Application for Federal Student Aid/Institutional Student Information Record (FAFSA/ISIR) information will be repealed for the 2022-23 award year, according to the Federal Register notice announcing 2022-23 verification items and acceptable documentation.

For the 2022-23 application year, ED’s requirements will revert to the 2021-22 requirements that were in place prior to ED’s announcement of the waiver in July, except that verification of high school completion is no longer required in any verification tracking group. This means that all 2022-23 FAFSA applicants who are selected for verification in the V1 tracking group must complete the verification process, and applicants in the V5 tracking group must again verify all data elements within that group (including income data). 

The 2021-22 waiver will continue to be in effect for the remainder of the 2021-22 application year. Separate from the waiver, COVID-related verification flexibilities on identity, statement of educational purpose, and high school completion status remain in effect through the end of the first payment period that begins after the date that the COVID-19 national emergency is rescinded, which has not yet occurred.

NASFAA President Justin Draeger issued the following statement

“Not extending these waivers for 2022-23 will have serious negative consequences for both students and schools. Low-income and vulnerable students have borne the brunt of this pandemic, and it shows in lower FAFSA completions and lower college enrollments. Adding back this burdensome verification process - which results in very few actual changes to aid offers - will make the college going process that much more difficult.

All of the reasons that ED cited for offering these waivers previously will continue to exist next year.  While more nimble and agile than ever, financial aid offices cannot simply pivot every few months to operationalize new and different federal requirements.  We call on the Department of Education to extend these waivers for the 2022-23 year before the 2022-23 FAFSA is made available in October.” 


Publication Date: 8/31/2021

Jared B | 9/3/2021 3:44:05 PM

Is there anymore information about the high school completion being waived from verification. We are still required to have HS completion in order to receive aid correct? The wording has thrown me off.

Kimberly L | 9/1/2021 7:10:58 PM

I work at a community college. While I understand the pitfalls of verification, there needs to be checks and balances. Often times we have siblings who report different income for the parents. One sibling is selected for verification, where the truth is revealed and the other sibling who was not selected for verification, entered no income or assets on the FAFSA. In addition, there are some students who fail to disclose both parent incomes, however, verification reveals that both parents have income. These scenarios are not anomalies. Yes, Uncle Sam has data on anyone with a SSN. There has to be a better way to weed out the incorrect information.

David J | 9/1/2021 5:20:47 PM

I too agree with David S. Verification targets and disadvantages the disadvantaged. Poor people do not disproportionally defraud the system. Yet, they disproportionally pay the price for those who do. Why do policy makers have such a high tolerance for collateral damage when it hurts the poor when we all know there would be no tolerance if it were the affluent who were forced to jump through hoops in the name of accountability.

Kelvin H | 9/1/2021 2:20:08 PM

I've seen a lot of valid comments on this subject and it could go either way. I've come across numerous files where student's parents make over $100K and then claim to have paid more than $50K or more in taxes and this gives them a zero EFC. The verification process roots out the students that want to manipulate the system and a large number of people have been doing that. There are businesses helping people beat the system. I've had people ask how much do they need to make or how many people do they need in my household to get the Pell. The verification process is needed. I'm not sure any other way to hold people accountable. I'm not a fan of having race brought into the equation. I am black, so I know about the burden of completing the FAFSA application, but how do we stop the privilege from abusing the system. Again, I believe verification levels the playing field for all.

Jesse H | 9/1/2021 12:0:14 PM

I (and I suspect others) am hoping that ED will use the 2021-2022 year as an experiment to gather data to determine whether FAFSA verification actually saves taxpayers any significant amount of money vis-a-vis the trouble it causes financial aid offices and the barrier it poses to students. However, we *know* already what the "with verification" numbers look like. That would be all the more reason to continue the experiment for another consecutive aid year to get more data on what a future with minimal verification could look like. I am hoping ED is announcing the documents (just like they did in 21-22) to keep the framework in place, but could waive them once established. I guess time will tell.

Carrie S | 9/1/2021 11:26:30 AM

Well said, David S.

Ben R | 9/1/2021 11:22:09 AM

I would think once the IRS/ED data sharing is fully enabled by the Future act, it will significantly reduce the verification burden on students and schools. So hopefully that is accelerated for some relief on that front.

With that said, one might say we ironically face the opposite problem on the borrowing side. To borrow an uncapped amount of PLUS loans or over $100k in graduate loans, the borrower, nor the school have to prove anything at all.

Ruben R | 9/1/2021 10:40:24 AM

I agree with David. The government already knows everything about us, more than most people know. It would makes sense to use a zero EFC for those in the low income/poverty level. Thanks David for your insight – well said.

Aesha E | 9/1/2021 10:40:16 AM

Equity and equality are not the same thing. And the equitable thing would be to not require students who are poor, who we know are poor, and much research indicates that verification is one (amongst many) barriers that keep these students from postsecondary education.

If something disproportionately affects people from a minoritized background--in David's example, it is racist, because it sustains inequitable structures that disproportionately affect people of color. If a policy disproportionately and inequitably affects women, it is sexist; disabled people, it is ableist; and so on. In order to correct such inequitable structures, we have to see them, name them, and actively dismantle them. To say the FAFSA is not anti-racist if it and/or the aid that it gatekeeps disproportionately affects students of color is not a bad thing, it just allows us to see the problems and correct them.

Eric P | 9/1/2021 10:23:55 AM

It's a loan. Nothing racist about it. Everyone goes through the same process if selected. Pretty sure everything can be done via electronically so there goes "just to get as far as our campuses" out the window. And don't say if they have a cell phone because I have never come across a student without a smart phone, regardless of income. Many companies are providing these and free internet to those with lower incomes. I know this won't be a popular view, but, these are applications for student loans that are born of taxpayer money. Again, I stress taxpayer money. Let's not forget the amount of fraudulent applications this process saves.

Rachelle F | 9/1/2021 9:52:40 AM

Well said David as usual!

Mindy S | 9/1/2021 9:48:45 AM

David S's comments are right on. Thank you for so eloquently stating the obvious bias in the current verification policy. It's sad when we practice Nice Racism.

David S | 9/1/2021 9:13:19 AM

What a missed opportunity to make substantive and permanent improvements to the delivery of financial aid; a conscious decision to return to the universally criticized practice of making poor people keep proving that they're poor, throwing the biggest obstacles in the paths of those who need aid the most and have been forced to overcome more just to get as far as our campuses.

If we wanted to fix this system so that "access" isn't just a buzzword but a real policy, we would just assign a zero EFC to those who the government already knows are poor. There would be minimal application procedures, because poor people don't have investments that include trust funds, UGMA and UTMA accounts, money market funds, etc. It wouldn't have to be repeated annually, because after a year, low income freshmen become low income sophomores. And no low income student should subsequently be told "OK, gather up this paperwork or you can't have your aid."

We have universal agreement on what populations are underrepresented on our campuses; all are low income, and disproportionately students of color. If we want a financial aid system that is just and anti-racist and truly helps those it is supposedly designed to help, we would move forward with reducing the application burden. This moves backwards.

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