ED Announces Changes to V4/V5 Verification Requirements, Effective Immediately
Sarah Austin and Megan Walter, NASFAA Policy Staff
In an electronic announcement (EA) released Friday, the Department of Education (ED) announced its plans to launch a “nationwide effort to eliminate identity theft and fraud in the federal student aid programs for the fall 2025 semester.” In the interim, schools will see higher verification selection rates for the V4 and V5 groups this summer.
ED outlined its plan to combat fraud in the Title IV aid programs in the EA, citing “recent data” that reveals a level of fraud so severe it “imperils” the Title IV programs. The EA mentions that the Pell Grant program is a prime target for “technologically advanced fraud rings,” which the department believes “necessitates immediate and significant action to protect taxpayer funds.”
ED plans to create a new internal screening process that will subject every FAFSA submission to an additional layer of scrutiny by ED’s systems during initial FAFSA processing, which ED believes will enhance its “ability to identify potential cases of identity fraud.” The department’s long-term objective with this new screening process is to detect fraudulent identities with enough certainty to significantly reduce, and ideally eliminate, the need for schools to complete V4 verification. The EA cautions that while implementing the new technology this fall, institutions should still expect higher rates for V4 selection compared to the 2024-25 school year.
As mentioned, while the new system is being developed, the department will increase V4 verification selection rates. ED expects this change to impact approximately 125,000 first-time applicants who are expected to receive Title IV aid for the first time this summer. It is unclear from the EA if these new applicants would be from the 2024-25 or 2025-26 FAFSA cycle. ED also said that while it expects V1 selection numbers not to change, there will likely be a slight increase in V5 selections for students previously chosen for V1.
ED also announced several changes to the acceptable documentation required for schools to complete V4 and V5 verification. Most notably, schools no longer need to obtain a Statement of Educational Purpose, and students may now present an unexpired, valid, government-issued photo identification to an institutionally authorized individual via video call if the institution determines the student cannot appear in person. This new video call option is in addition to the already existing option of presenting photo identification to a notary.
The department will also now consider an applicant’s identity verified “if the student’s identity was verified by an entity that is compliant with National Institute of Standards and Technology (NIST) Identity Assurance Level 2 (NIST IAL2).” For confined or incarcerated applicants, the department will now consider their identity verified “if the student’s identity was verified by a responsible official at the facility where the individual is confined or incarcerated.”
These changes to the acceptable documentation are effective as of the date of the EA and also apply to applicants who were selected for verification prior to the announcement.
Finally, the EA reminds schools that conflicting information must be resolved before disbursing aid. If a school suspects that a student, employee, or other individual has misreported information or altered documentation to obtain federal funds fraudulently, it must be reported to the Office of Inspector General (OIG). ED goes on to say, “If a school determines with certainty that an applicant has falsified their identity or is otherwise not eligible for Title IV aid, it should not make any disbursements of Title IV, HEA funds to the student or on the applicant’s behalf.” It is unclear how a school would determine with certainty whether an applicant falsified their identity, as the longstanding guidance has been that schools are not required to make determinations in cases of suspected fraud, but rather, are required to report these suspicions to OIG. The EA refers schools to the overpayment guidance in the FSA Handbook for situations where aid has already been disbursed for these students.
Publication Date: 6/9/2025
Paula K | 6/9/2025 2:15:34 PM
I may have misread something, but I think it is a bad idea to *not* have the student go before a notary if they cannot directly come in-person to the school.
Melynda M | 6/9/2025 1:47:21 PM
Did the change require that we verify the identity of all new summer students receiving Pell for the first time this summer?
David H | 6/9/2025 11:57:49 AM
Fraudsters will still utilize video calls to verify identity. We've seen it many times at our institution and have not found it to be an effective fraud deterrence measure.
Shelley E | 6/9/2025 9:28:52 AM
For the video call option, are we just using an image of the screen shot of the id/student for documentation purposes and the student does not have to sign anything?
Leah W | 6/9/2025 9:15:39 AM
Does this mean we no are no longer required to collect the form?
ED also announced several changes to the acceptable documentation required for schools to complete V4 and V5 verification. Most notably, schools no longer need to obtain a Statement of Educational Purpose, and students may now present an unexpired, valid, government-issued photo identification to an institutionally authorized individual via video call if the institution determines the student cannot appear in person. This new video call option is in addition to the already existing option of presenting photo identification to a notary.
Jason E | 6/9/2025 8:43:54 AM
ED's guidance to treat aid disbursements that occurred prior to the identity-theft suspicion as overpayments needs clarification from ED. That guidance implies that we need to make the student pay back the aid already disbursed. I hope that's not what ED was saying because that doesn't make any sense. This aid was disbursed with a real person's PII. Treating those disbursements as overpayments means the real person...not the identity thief...is being expecting to pay the aid back. That's insane. The student (i.e. - the real student whose identity was stolen) is the VICTIM of a CRIME. They didn't do anything wrong. They didn't apply for aid, admission, or register for classes. A criminal did those things. When you're talking about the crime of identity-theft, all the overpayment guidance should go out the window. Why would the victim of a crime be asked to pay back money they did not steal? And why would the college write-off those overpayments as a loss to the college as a gesture of goodwill toward the victim? That's also illogical because now the college has become the victim of the crime. The only thing that makes sense is for the Department to take that loss. And if that translates to...the taxpayer takes the loss...then that's the way it needs to be. Can NASFAA please get clarification from ED because
David S | 6/9/2025 8:16:33 AM
Just throwing this out there, copied and pasted from the AI results in a quick Google search:
"The National Institute of Standards and Technology (NIST) is experiencing a significant number of layoffs as part of the Trump administration's broader effort to reduce the federal workforce. These layoffs, impacting probationary employees, raise concerns about the agency's ability to continue developing and updating standards and guidelines for emerging technologies like AI and cybersecurity. "
And perhaps if ED hadn't experienced the same massive layoffs, there'd be enough staff there to tell their leadership that summer aid started being disbursed more than a month ago at many schools, meaning that these new requirements are very likely to have to be applied to aid that has already been disbursed and spent.
But, you know, efficiency.
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