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Did You Know? The Program Integrity Q & A website was recently updated?

June 24, 2016
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One of the Q & A’s is new, DOC 28 Q & A, while others have been revised.  It is important to check the website from time to time to ensure accurate and timely processing of financial aid.

Documenting High School Completion Status (DHC)

DHC-Q2. Can a student who does not have a high school diploma, or its recognized equivalent, or who has not completed a secondary school education in a homeschool setting, be admitted as a regular student to a postsecondary educational institution?

DHC-A2. Yes, only if the student is beyond the age of compulsory school attendance in the State in which the institution is physically located, or is dually or concurrently enrolled in the institution and a secondary school. However the student must have a high school diploma or its recognized equivalent, or have completed a secondary school education in a homeschool setting in order to be eligible to receive Title IV aid. Note one exception: students may qualify for Title IV aid under one of the ATB alternatives, either because the student is “grandfathered,” as described in Dear Colleague Letter GEN-12-09, or because the student is enrolled in an eligible career pathway program as described in Dear Colleague Letter GEN-16-09. [Guidance issued 1/24/2014; revised 6/7/2016]

General Questions (VER)

VER-Q7. Must an institution complete verification for a selected applicant who is eligible for both subsidized and unsubsidized Title IV student aid when the applicant chooses not to accept the subsidized aid?

VER-A7. An applicant who is eligible for subsidized and unsubsidized Title IV student aid may not avoid completing verification by accepting only the unsubsidized Title IV student aid. In such a case, the institution must complete verification for the applicant to be eligible for any Title IV student aid.

However, an institution may, on a case by case documented basis, disburse unsubsidized Title IV aid to only those applicants who are in Verification Tracking Group V1, V3 or V6 if the institution has determined that there will be a delay in the completion of verification. See Q&A VER-Q11/A11 for further information. [Sections 668.51(a), 668.54(b)(1)(ii) and (iii)] [Guidance issued 03/13/2012; revised 6/7/2016]

VER-Q11. May an institution disburse unsubsidized Title IV student aid, i.e., Direct Unsubsidized Loans and PLUS Loans, prior to completing verification for a selected applicant who is eligible for both subsidized and unsubsidized Title IV student aid?

VER-A11. An institution may, on a case by case documented basis, disburse unsubsidized Title IV aid to only those applicants who are in Verification Tracking Group V1, V3 or V6 if the institution has determined that there will be a delay in the completion of verification. When determining the amount of the unsubsidized aid to be disbursed, the institution must ensure that the subsidized aid the applicant is estimated to receive is considered. After verification is completed, the institution must ensure that both the subsidized assistance and the unsubsidized assistance are adjusted, if necessary. An institution may not disburse unsubsidized Title IV student aid to applicants who are in Verification Tracking Group V4 or V5.

Even if the applicant does not complete verification, the applicant may retain all of the unsubsidized Title IV aid that was disbursed and remains eligible for any additional unsubsidized Title IV aid. [Sections 668.51(a)] [Guidance issued 10/10/2012; revised 6/7/2016 ]

Acceptable Documentation for FAFSA Information Selected for Verification (DOC)

DOC-Q16. May an institution require an individual who has been granted a tax filing extension by the IRS to use the IRS Data Retrieval Tool (IRS DRT) or obtain an IRS Tax Return Transcript before completing verification? Must the tax return information be submitted to the institution after the income tax return has been filed?

DOC-A16. An institution may not delay completing verification for an applicant when a tax filing extension has been granted by the IRS. The income and tax verification regulatory requirements are met if a tax filer who has been granted a filing extension by the IRS provides the institution with a copy of IRS Form 4868 and a copy of IRS Form W–2 for each source of employment income received for the tax year; and, if self-employed, a signed statement certifying the amount of the AGI and the U.S. income tax paid for the tax year. This provision provides extension filers with a timely alternative to complete the verification process to avoid delaying the applicant’s receipt of aid because of the IRS granted extension. For an individual who was called up for active duty or for qualifying National Guard duty during a war or other military operation or national emergency, in lieu of IRS Form 4868, an institution must accept a signed statement from the individual certifying that he or she has not filed an income tax return or a request for a filing extension because of that service (see final regulations published on September 27, 2012 [PDF]).

While submission of the documentation mentioned above meets the verification requirements and allows Title IV aid to be disbursed, an institution may require an individual granted an IRS tax filing extension to submit, after the tax return is filed, tax return information using the IRS DRT, or by submitting an IRS Tax Return Transcript within the deadline it established that is consistent with the deadline to submit verification documents published in the annual Federal Register notice. If the required documentation is not submitted by the institution’s established deadline, the student must return all Title IV aid (Federal Pell Grant, FSEOG, IASG, TEACH Grant, or Perkins Loan) disbursed before the student was selected, except for Direct Subsidized Loans, Direct Unsubsidized Loans, Direct PLUS Loans, and Federal Work Study (FWS) wages earned. No further disbursements of Title IV aid can be disbursed, except for Direct Unsubsidized Loans and Direct PLUS Loans, and no further Federal Work Study (FWS) employment may occur for that award year. However, an institution may not apply this provision to individuals granted a filing extension beyond the institution’s established deadline because the individual was called up for active duty or for qualifying National Guard duty during a war or other military operation or national emergency. [Section 668.57 and 668.60] [Guidance issued 04/25/2013; revised 6/7/2016]

DOC-Q28. Institutions may only accept a signed copy of a non IRS income tax return for tax filers who are unable to obtain a free copy of their tax account information. Which tax authorities charge a fee to obtain this information?

DOC-A28. The tax authorities for Guam, the Commonwealth of the Northern Mariana Islands, the Commonwealth of Puerto Rico and the U.S. Virgin Islands charge a fee to obtain tax account information. Therefore, a tax filer who filed an income tax return with these tax authorities may provide institutions with a signed copy of his or her income tax return that was filed with the relevant tax authority. However, if the institution questions the accuracy of the information on the signed copy of the income tax return, the tax filer must provide the institution with a copy of the tax account information issued by the relevant tax authority before verification can be completed.

A tax filer who filed an income tax return with the Internal Revenue Service or the tax authority for American Samoa must provide institutions with a copy of his or her tax account information if selected for verification since these tax authorities do not charge a fee to obtain this information.

A tax filer who filed an income tax return with tax authorities not mentioned above, i.e. a foreign tax authority, and who indicates that he or she is unable to obtain the tax account information free of charge, must provide the institution with documentation that the tax authority charges a fee to obtain that information, along with a signed copy of his or her income tax return that was filed with the relevant tax authority. [Guidance issued 6/7/2016] New

To access all of the Program Integrity Q&As, please visit:http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/integrity-qa.html.

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