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Regulatory Bulletin — DHS 3-Step Electronic Verification of Eligibility – May 1, 2018

April 12, 2018
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Dancing the New Three-Step
(The Three-Step DHS Verification)

Well, let’s face it.  Some are just better than others at doing a two-step on the old dance floor.  What makes the difference?  Perhaps it is due to more training or experience, and for some, perhaps there is just more natural ability.  But, along with, hopefully, some natural ability, it does take some basic understanding of the steps appropriate for the dance.

Likewise, in determining certain noncitizens’ eligibility for Federal Student Aid requires knowing and accomplishing the appropriate steps.  Failure to know and appropriately follow those steps could cause the music of the Federal Student Aid dance to stop for some students.

The Department of Homeland Security’s New Three-Step

There have been three steps to the U.S. Department of Homeland Security’s (DHS) confirmation dance for years.  But, very soon, the DHS’ three-step dance is changing.  Effective May 1, 2018, the third step of the DHS confirmation process is going paperless.

Historically, DHS, via the U.S. Citizenship and Immigration Services (USCIS), has required the “three-step” process for confirming noncitizens’ potential eligibility for Federal Student Aid through the Systematic Alien Verification for Entitlements (SAVE) Program.  The first step in the process, or the “primary match,” has indicated the results in the DHS Match Flag field on the Institutional Student Information Record (ISIR) after a match with the Social Security Administration (SSA).  The automated second step confirmation has occurred when the SSA match was not positive, and the record was simultaneously submitted to DHS, if there was an Alien Registration Number (ARN) provided.  If the SSA match was negative, the DHS match has been the one that determined whether the student had an eligible immigration status.

If the student did not successfully pass the automated secondary confirmation process, the institution was required to pursue the third-step confirmation.  Up to this point, the third-step confirmation method involved a paper process that required submitting appropriate documentation with the completed “paper” USCIS Form G-845.  But, very soon the steps are changing!   Again, on May 1, 2018, DHS-USCIS will be paperless.

“Third-Step Verification”

The U.S. Department of Education (ED) announced this future change in a couple of different ways.  First, the financial aid community received information about this upcoming modification to the process in the 2017-2018 Federal Student Aid Handbook, Volume 1, Chapter 2, page 1-32.[1]  In this source, ED stated that “USCIS/SAVE will only accept paper G-845s until approximately April 30, 2018.”  The FSA Handbook also indicated that the third-step of confirmation is being renamed; it is changing from being called the “Paper Secondary Confirmation” to “Third-Step Verification.”

More recently, ED reminded the public of the upcoming change in its Electronic Announcement dated February 26, 2018.[2]

Transitioning to Electronic Confirmation Process for Eligible Noncitizen Status

ED specified in that February 26, 2018, Electronic Announcement that as of May 1, 2018, DHS will reject and return to the sender any paper Forms G-845 it receives.  Therefore, the guidance provided warns that institutions should stop mailing paper Forms G-845 by April 24, 2018, to allow time for them to be received prior to the May 1, 2018, date when paper forms will be rejected and returned to the institution.  Any third step verification requests not submitted by paper by the last mailing date should be held until the institution’s SAVE system access is activated.

In order to make the transition effective, ED will provide each Title IV-eligible institution log-on credentials.  These will be assigned to the institution’s Primary Destination Point Administrator (PDPA) as a SAVE user ID and temporary password.  The institution’s PDPA will need to access their SAVE system log-on credentials through the Student Aid Internet Gateway (SAIG).  More specifically, they will be accessed via the SAIG Enrollment Website at https://FSAWebenroll.ed.gov.  Once the access information is retrieved, the PDPA will need to select the box indicating “Primary Destination Point Administrator Access” in order to manage your SAIG mailboxes.   Through that access point, the PDPA will be able to establish his or her SAVE account on the SAVE Website.

The PDPA will, as is common for other SAIG access purposes, be able to assign additional subordinate Financial Aid Administrator (FAA) user IDs at the institution.  The PDPA is also, likewise responsible to serve as the custodian of SAVE system user IDs for staff at their institution.

SAVE System Operations

Once the PDPA has received his or her log-on credentials and actually logged in, third-step DHS verification requests may be made for eligible noncitizens.  The FAA will upload the student-provided immigration document(s) to the student’s record and then submit the verification request.  The response will be received from the SAVE system within about three to five business days.

The status response received will be clear, such as “Lawful Permanent Resident” or “Refugee,” etc.  Using the status response received, the FAA will compare it with those possible responses provided in the Federal Student Aid Handbook, Volume 1, and Chapter 2.  This aspect of determining eligibility is the same as has been in place prior to the transition to the electronic third-step verification through SAVE.

For additional information related to the transition to the electronic “third-step verification” of the status of eligible noncitizens, see the new link ED has established on the Information for Financial Aid Professionals (IFAP) Website at https://ifap.ed.gov.  Once on the IFAP page, select the option for the “DHS-SAVE, Eligible Noncitizen” tab/link under the “Information Pages” section in the right-hand sidebar of the page.

Taking the time to learn the steps in this new three-step verification process for determining the appropriate status of eligible noncitizens will allow for a much easier go of it when it comes time to leave the Form G-845 in the shreds of the carpet as you “cut up the rug” in the new DHS “three-step.” Utilizing the information above, you should be able to look like a natural when the music of this new “three-step” begins on May 1, 2018!

Should you have any additional questions regarding this topic, please feel free to contact Customer Service through the Client Solution Center.

 

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[1] 2017-2018 Federal Student Aid Handbook, Volume 1, Chapter 2, page 1-32.

[2] Electronic Announcement; U.S. Department of Education, Office of Federal Student Aid, February 26, 2018.

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This article is presented for informational and educational purposes only and should not be considered to be giving legal advice.

 

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