Mid-Year Verification Changes for 2015–16

By NASFAA Training and Regulatory Assistance Staff

In recent updates to the U.S. Department of Education (ED) Program Integrity Q&A website, ED made mid-year changes to the verification documentation requirements for IRS victims of identity theft and amended tax return filers. These changes became effective for verifications completed on or after July 7, 2015, for the 2015–16 award year, and carry forward to the 2016–17 award year.

Victims of IRS Identity Theft

In addition to collecting a copy of the Tax Return DataBase View (TRDBV) transcript, the school must also collect a statement signed and dated by the tax filer indicating that he or she was a victim of IRS tax-related identity theft and that the IRS has been made aware of the tax-related identity theft. Schools that completed 2015–16 verification prior to July 7, 2015, based on the guidance in GEN-14-05 are not required to reverify those individuals by now collecting the signed statement. However, schools completing verification on or after July 7, 2015 must collect both the TRDBV and signed statement from the tax filer.

Amended Tax Returns

When the school is aware that in individual has filed an amended tax return, the school will also need to collect a copy of the IRS Tax Return Transcript (which does not have to be signed), or the alternative documentation specified under DOC-Q10/DOC-A10 on the ED Program Integrity Q&A website, in order to complete verification. For any verifications completed on or after July 7, 2015, the school must collect all of the following for individuals who filed an amended tax return:

  • A signed copy of the original tax return that was filed with the IRS;
  • An IRS Tax Return Transcript (which does not have to be signed), or acceptable IRS alternative, such as a Record of Account Transcript, a Return Transcript for Taxpayer (RTFTP), or an Information Returns Processing Transcript Request—Wages (IRPTR-W); and
  • A signed copy of the IRS Form 1040X that was filed with the IRS.

Here again, the school is not required to reverify those students for whom verification was completed prior to July 7, 2015.

NASFAA is in the process of updating the appropriate Q&As in the AskRegs Knowledgebase to reflect this new guidance. See also GEN-15-11 for guidance on the 2016–17 verification requirements.


Publication Date: 7/15/2015

Ashley S | 8/13/2015 4:58:24 PM

Goodness - ANOTHER adjustment was made today by the DOE to the Amended Tax Return requirements on the Program Integrity site. Training staff and keeping students informed is so challenging when multiple changes like this take place in an AY.

Jodie S | 7/16/2015 12:26:48 PM

I was wondering that myself...I thought maybe they meant they wanted us to collect the Tax Account Transcript because that shows that an amendment was filed, and that was my thinking of why they would want us to collect this additional documentation. But what is the Tax Return Transcript going to show that is going to be different from a signed copy of their original tax return?

David F | 7/15/2015 9:39:19 AM

DOC-Q2 and DOC-A2 on the Program Integrity website clarifies what is meant by the tax transcript--it can be any IRS tax transcript, including the Tax Return Transcript or any of those transcripts listed in the article above.

Jamee H | 7/15/2015 9:15:56 AM

GEN 15-11 for amended return filers indicates the tax ACCOUNT information is needed - not the tax RETURN. Tax ACCOUNT transcript will show if the amended return was actually filed with the IRS. The Tax RETURN transcript will just show the originally filed tax return information

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