Policy 03:15:00 Federal Verification and Conflicting Data Policy

Revision Responsibility: Director of Financial Aid

Responsible Executive Office: Vice President of Academic Affairs

Purpose: To explain Platt College's process mandated by the Federal government in which schools are required to and have the authority to collect documentation to verify data provided on a student's Free Application for Federal Student Aid (FAFSA), in accordance with Federal Guidelines 668.16 (f) and 668.54 (a) (3).

Policy:

Verification is a process mandated by the Federal government in which schools are required to and have the authority to collect documentation to verify data provided on a student's Free Application for Federal Student Aid (FAFSA). Students are selected for verification by the United States Department of Education's Central Processing System (CPS) at the time the student completes the FAFSA. Platt College reserves the right to select any student not already selected by the CPS if it believes that any application information is incorrect or if there is evidence of conflicting information.

About 30% of all FAFSA filers are selected for the verification process, which requires the school to collect documentation to check the accuracy of the FAFSA information.

At Platt College, students are notified of needed verifications via College email and/or the College portal.  If verifications are not completed by students within 30 calendar adays from the first notification, then the only aid students will be allowed to receive will revert to non-need base as an unsubsidized loan. 

The best action a student can take to help finish verification is to use the IRS data retrieval process to automatically populate tax information (either from student and/or student's parents) directly from the IRS into your FAFSA.

Once the IRS tax filing deadline has passed, the student and his/her parents (if a dependent student) should log into your FAFSA at www.fafsa.ed.gov and make a correction to use the IRS data retrieval.  This step allows a student to link to the IRS from the FAFSA and retrieve the tax information to populate the FAFSA tax questions.  When using the IRS data retrieval, the tax information is considered to be already verified so a student may not have to submit any documentation, like tax transcripts, to the Financial Aid Office at Platt College. 

There may be other documents that we are requesting (like a Verification Worksheet) that you will still need to complete and submit.  

Some students and/or parents will be ineligible or will choose not to use the IRS data retrieval.  In these cases, only the signed tax return transcript will be accepted as documentation to verify tax information.  The tax return transcript must be requested directly from the IRS by calling 1-800-908-9946 or visiting the IRS Website. Be sure to request the tax return transcript, and not the tax account transcript. Platt College cannot accept 1040s to verify tax information.

Applicants Selected for Verification: If Platt College has reason to believe that any information on the application used to calculate the expected family contribution (EFC) is discrepant or inaccurate, the financial aid department will require the applicant to provide adequate documentation to resolve conflict.

Applicants Not Selected for Verification: Platt College will resolve conflicting infomraiton regardless of whether or not the applicant was selected for verification.  The financial aid office will review all tax returns provided to teh school even if they were not requested.  All C Codes on the ISIR will be reviewed and resolved by the financial aid office.

Verification Exclusions

All students selected for verification are reviewed upon submission of the required documents.  Student may not skip the verificaiton process and obtain financial aid.  If a student's FAFSA is selected for verification after the student  has been awarded, the student has 45 days to complete verification.

The following list identifies all applicants who are excluded from Verification:

  • Applicants who die during the award year (regardless of conflicting informaiton)
  • Applicants who will not receive Title IV aid for reasons other than failure to complete verification
  • Dependent students whose parents reside outside the US and cannot be contracted by normal means of communication (exclusion is applicable to parental information only)
  • Applicants whose parents cannot be located because their contact information is unknown (exclusion is applicable to parental information only)
  • Dependent applicants when both parents are mentally incapacitated (exclusion is applicable to parental information only)
  • Transfer students who completed verification at the previous school and the current school obtains the correct information/data from the previous school
  • Applicant spousal information when the spouse is deceased, mentally incapacitated, residing in a country other than the US and cannot be contacted by normal means, or the spouse' contact information is unknown

Eligible applicants for whom modification and waiving of some statutory and regulatory provisions apply under the Higher Education Relief Opportunities for Students Act:

  • Service on active duty during a war or other military operation or national emergency
  • Performing qualifying National Guard duty during war or other military operation or national emergency
  • Residing or employed in an area declared a disaster area by any federal, state, or local official in connection with a national emergency
  • Who have suffered direct economic hardship as a direct result of a war, other military operation, or national emergency

Students who are not selected for Verification, who are awarded and then make a subsequent ISIR change are subjected to Verification on subsequent transactions.

Verification Forms

  • Dependent Verification Worksheet (if student is dependent on parents)
  • Independent Verification Worksheet (if student is independent of parents)

Accepted Documentation and Forms

V1 Standard Verification Group

  • Adjusted Gross Income (parent and student, if the student is dependent) (IRS Data Retrieval or tax transcript 24 and 25 SFS Forms)
  • US IncomeTax Paid (parent and student, if the student is dependent) (IRS Data Retrieval or tax transcript 24 and 25 SFS Forms)
  • Untaxed Portions of IRA Distributions (Tax transcript 24 and 25 SFS Forms)
  • Untaxed Portions of Pensions (Tax transcript 24 and 25 SFS Forms)
  • IRA Deductions and Payments (Tax transcript 24 and 25 SFS Forms)
  • Tax-exempt Interest Income (Tax transcript 24 and 25 SFS Forms)
  • Education Credits (Tax transcript 24 and 25 SFS Forms)
  • Household Size (Household Verification 28 or 29 SFS Forms)
  • Number in College (Household Verification 28 or 29 SFS Forms)
  • Income Earned from Work (for non-filers W-2 (24 and 25 SFS Forms))

V4 Custom Verification Group

  • High School Completion Status (High school diploma or transcript, GED certificate or transcript, home school credentials or high school completion status form (BN SFS Form)
  • Identity/Statement of Educational Purpose (Original government-issued ID and signed identity and Statement of Education Purpose form or copy of ID with notarized STatement of Educational Purpose (SI SFS Form)

V5 Aggregate Verification Group

  • Adjusted Gross Income (IRS Data Retrieval or tax transcript (24 and 25 SFS forms)
  • US Income Tax Paid (IRS Data Retrieval or tax transcript (24 and 25 SFS forms)
  • Untaxed Portions of IRA Distributions (Tax transcript (24 and 25 SFS forms)
  • Untaxed Portions of Pensions (Tax transcript (24 and 25 SFS forms)
  • IRA Deductions and Payments (Tax transcript (24 and 25 SFS forms)
  • Tax-Exempt Interest Income (Tax transcript (24 and 25 SFS forms)
  • Education Credits (Tax transcript (24 and 25 SFS forms)
  • Household Size (Verification Worksheet 28 or 29 SFS Forms)
  • Income Earned from Work (Non-Filers) (W-2 (24 and 25 SFS Forms))
  • High School Completion Status (High school diploma or transcript, GED certificate or transcript, home school credentials or high school completion status form (BN SFS Form)
  • Identity/Statement of Educational Purpose (Original government-issued ID and signed identity and Statement of Education Purpose form or copy of ID with notarized Statement of Educational Purpose (SI SFS Form)

Once verification begins, Platt College may need to ask for additional documentation based on the documents submitted by students.

Conflicting Data

Students or parents selected for verification –If the College has reason to believe that any information on the application used to calculate the EFC is discrepant or inaccurate (or if any supporting documentation is discrepant or inaccurate), the College requires the student or parent to provide adequate documentation to resolve the conflict.

Students or parents not selected for verification –the College must resolve conflicting information regardless of whether or not the student or parent was selected for verification. The financial aid office must review all tax returns/transcripts provided to the College even if they were not requested. All C Codes on the ISIR must be reviewed and resolved by the financial aid office.

Other student or parent information received by the College –Platt College must have an adequate internal system to identify conflicting information that it may have regardless of the source. The office lead for each office is required to provide information that could impact the financial aid status of each student or parent e.g. (Admissions Office: High School Diploma, Fiscal Office: Report outside awards, Graduate Aid Office: Report outside awards, Registrar: Report changes in enrollment, Federal Work Study Office: Report FWS earning in a calendar year, National Student Loan Data System (NSLDS): Review financial aid history, (e.g. review aid received from prior colleges attended).

The following list provides examples of conflicting data. Please note: the list is not construed as an all-inclusive list.

  • A student is not selected for verification, the tax return or IRS transcript is on file and information conflicts with items on the FAFSA.
  • Form 1040 shows parent single head of household (HOH) and the FAFSA/ISIR shows the same person as married.
  • Parent or student report on their FAFSA and signed a verification worksheet that they will not file an IRS Form 1040. The College has reason to believe that they would have been required to file a U.S. Income Tax Return, as the amount of reported income is greater than or equal to the minimum amount required to file as indicated in the instructions provided on the Form 1040.
  • Statements or information that suggests that the copy of the Income Tax return/transcripts you received is not the return actually filed with the IRS.
  • The College receives Profile from College Scholarship Service (CSS). Student reports a specific amount in untaxed income; FAFSA reports a different amount (If the College receives the CSS Profile, it must ensure that information contained there does not conflict with other documents received by the College).
  • Veterans Affairs (VA) benefits verified by the certifying official in the Registrar’s Office don’t match the FAFSA. (To resolve conflict, can rely on certifying official).
  • Admissions information received impacts student eligibility (i.e., student accepted into a non-degree program, student received scholarship from high school, etc.)
  • The Student Academic Progress or Enrollment Status on file in the Financial Aid Office doesn’t agree with the information from the Registrar’s Office.

Examples of issues not considered Conflicting Data, but should be reviewed:

  • Assets reported on the FAFSA are $0 or low but significant interest and dividend income or capital gains are reported on the U.S. Income Tax Return/transcripts.
  • $0 income reported with no explanation as to how the student/parent/family can live on $0 income Address reported by student/parent (i.e., if parents are divorced and the address on the student’s tax return/transcripts does not match the address of the custodial parent’s tax return). Or the address doesn’t match the state of residence as listed on the FAFSA.
  • If the student or parents reported business/farm net worth but didn’t file a schedule C or Form 1120 or just didn’t supply it to the College. Request additional documentation from student or parent to verify the information.
  • Box 14 information from W-2. Determine if the dollars represented are untaxed income not previously reported
  • Always have the ability to ask for whatever information you need any time that you think there is a problem.

Additional Documents (to Resolve Conflicting Information)

  • Copy of W-2 Income Statement
  • Copy of Marriage Certificate
  • Copy of Birth Certificate
  • Copy of Social Security Card
  • Legal Guardianship/Emancipated Minor Form
  • Copy of Legal Guardianship Paperwork
  • Copy of Legal Emanicipated Minor Paperwork
  • Copy of Ward of Court or Foster Care Paperwork
  • Copy of Documentation to Support Homelessness or At-Risk Homelessness
  • Copy of Veteran DD214 Paperwork
  • Asset Information Worksheet (AU/AX)
  • Copy of a 1099/1040 Tax Return to Verify IRS/Pension Rollover

Interim Disbursements and Resolution of Conflicting Information

The College may not disburse aid until you have resolved conflicting information. Even if the conflict concerns a previous award year, the Financial Aid Department must still investigate it. The matter will be resolved when financial aid has determined which data are correct; this might simply be confirming that an earlier determination was the right one. The Financial Aid Department will document the findings and explain why, not simply assert that, the decision is justified.

Correction of Information

Once the requested information is received, Student Financial Services submits the verified corrections to the Central Processing System (CPS) electronically. This will ensure that corrections are made known to all parties and that the needs analysis will be updated accurately and according to federal standards. Once corrections are received back at the school, the student is reviewed and rewarded through Quality Control process. All interactions are communicated with the student via email communication.

Important Note about Verifying Tax Information

Students should use the IRS Data Retrieval Tool which allows them to link to the IRS from the FAFSA and retrieve tax information directly from the IRS to populate the FAFSA tax return questions.  Using the IRS Data Retrieval Tool simplifies the FAFSA filing and may result in quicker processing of a student's verification.  The documents that Platt College can now accept to verify tax information have changed based on policy changes from the U.S. Department of Education.  Either a federal tax transcript from the IRS or the FAFSA filed using the IRS Data Retrieval Tool are the only two ways to verify tax data with the 2018/2019 academic year.  If a student does not, or cannot, use the IRS Data Retrieval Tool, s/he will be required to obtain a federal tax return transcript from the IRS.  If a student has filed his/her taxes with the IRS, log into your FAFSA and make a correction to use the IRS Data Retrieval Tool to update tax information.  If a student does this, s/he will not be required to submit a tax transcript. 

To request a tax return transcript from the IRS, go to http://www.irs.gov/Individuals/Get-Transcript or call 1-800-908-9946.

Submitting your FAFSA and completing verification is required before aid can be awarded.

Failure to meet the verification deadlines may result in certain types of aid not being offered.  In addition, delays in sending documentation may result in the student not having aid by the time their bills are due each quarter.  In this case, the student is obligated to pay the account balance on the student account, or their classes could be canceled.  Once verification has been completed students will be notified by the Financial Aid Department.

Important Tips for Completing the Verification Process

  • Complete all requested forms in full: Do not leave any questions blank. All questions must have an answer even if it is a "0". Be sure all required signatures have been provided.
  • Be sure that you have used the IRS Data Retrieval Tool which allows you to link to the IRS from the FAFSA and retrieve tax information directly from the IRS to populate the FAFSA tax return questions.  If you use the IRS Data Retrieval Tool, you will not have to submit tax transcripts from the IRS. You can log into your FAFSA and make a correction to use the IRS Data Retrieval Tool to update your tax information.
  • If you do not, or cannot, use the IRS Data Retrieval Tool, you must submit the federal tax return transcript from the IRS.  To request a tax return transcript from the IRS, go to http://www.irs.gov/Individuals/Get-Transcript or call 1-800-908-9946.
  • If you will not and are not required to file taxes, be sure to submit all W-2’s to document earnings from work.
  • Those individuals who are considered "non tax filers" are also required to submit proof of non-filing from the IRS.  This can requested by submitting Form 4506-T or by requesting a Tax Return Trascripts (which will show no record).  Both can be done at www.irs.gov.

If you suspect that a student, employee, or other individual has misreported information or altered documentation to fradulently obtain federal funds, you should report your suspicions and provide any evidence to the Office of the Inspector General:

Inspector General’s Hotline

Office of Inspector General

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202-1500

1 -800-MIS-USED

Hours: M, W 9:00–11:00 a.m. T, Th 1:00–3:00 p.m.

To submit a complaint online (http://www2.ed.gov/about/offices/list/oig/hotline.html) and click on the appropriate link.

Policy Appendices: Dependent Verification Worksheet (if student is dependent on parents), Independent Verification Worksheet (if student is independent of parents)

Created in Formalized Policies: June 6, 2014, Revised June 9, 2015 to reflect changes in policy appendices; Revised May 18, 2018 to reflect updates in verification worksheets; Notification date of January 28, 2019 with an effective date of March 15, 2019 regarding a 30 calendar day time period to resolve verifications.

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