Verification

Presentation College has established the following FAO policy and procedure to define and administer verification and correction of data that applicants submit on the Free Application for Federal Student Aid (FAFSA) and other documents used to apply for Title IV (or federal) funding, as well as several other types of financial assistance administered by the College. All recipients of Title IV funding (and other sources of funding as determined by the College) are governed by this policy as specified below. The verification policy is in accordance with and references the language from regulations, CFR 34, Section 668.51–61, promulgated under the Higher Education Act of 1965 (HEA), as amended. The College adheres to federal policy, as set forth in HEA in the administration of verification for Title IV recipients, in all respects.

The verification policy applies to the following types of Title IV aid administered by the College:

• Federal Pell Grant
• Federal Iraq and Afghanistan Service Grant
• Federal Supplemental Educational Opportunity Grant (FSEOG)
• Federal Work Study (FWS)
• Federal Direct Loan (Subsidized and Unsubsidized)
• Federal Parent Loan for Undergraduate Students (PLUS)

The verification policy may also be applied to other types of financial aid that are administered by the College that are need-based.

The U.S. Department of Education (ED) sets forth both the framing regulations as well as significant detail governing the process of verification. ED requires that institutions document certain verification guidelines over which they have discretion. Those policies are described below:

• selection for institutional verification,
• the deadlines by which students must submit verification documentation,
• the consequences for failing to submit verification documents by applicable deadlines,
• the method the FAO will use to notify students if their EFC and/or Title IV aid amount changes,
• the procedures the FAO or students will follow to correct FAFSA data,
• the procedure the FAO will follow to refer a student to the Office of Inspector General.

Other policies and procedures are copied from and closely based upon the federal Application and Verification Guide (AVG) from the Federal Student Aid Handbook, Chapter 4.

Verification, Updates and Corrections

Because students sometimes make errors on their application, there is a process for verifying applications and making corrections. The Central Processing System (CPS) selects which applications are to be verified, but the FAO has the authority to verify additional students.

The FAO must verify applications selected by the CPS of students who will receive (or have received) subsidized student financial assistance. Verification is not required if the student will only receive unsubsidized student financial assistance (see verification exclusions later in this policy), though a student cannot avoid verification by accepting only unsubsidized aid. If the student tries to do this, the FAO must continue with verification.

Institutional Notification Policies

ED selects, through edits at the Central Processing System (CPS), certain financial aid applicants nationwide for review in a process called verification. When an applicant has been selected for verification the FAO is required to review the student's FAFSA for accuracy and completeness. Students and parents of dependent students are prompted via email to sign up for an account through the College's third-party servicer for verification services, Inceptia. Once an account is created, the student and parent (if required) will each have a task list, which may include providing an IRS tax return transcript (available from the IRS and may be required if the Data Retrieval Tool was not used). Depending upon the sources of income reported on the FAFSA, the student (and parent or spouse, as applicable) may be required to submit additional documents.

All students who have been selected for verification must submit all required documentation and any other requested information prior to being issued an award offer. Students and parents are reminded that by signing the FAFSA they have agreed that "If you are the parent or the student, by signing this application you certify that all of the information you provided is true and complete to the best of your knowledge and you agree, if asked, to provide information that will verify the accuracy of your completed form. This information may include U.S. or state income tax forms that you filed or are required to file. Also, you certify that you understand that the Secretary of Education has the authority to verify information reported on this application with the Internal Revenue Service and other federal agencies."

Typical Documentation

When a student is selected for verification, the following documentation, at minimum, is required:

1. Verification Account Worksheet (Dependent or Independent) available through Inceptia Verification Gateway
2. Tax Return Transcript or a signed photocopy of the actual IRS tax return form (1040, 1040A, 1040EZ)
   1. student's tax return transcript (can be obtained from the IRS)
   2. parent's (for dependent students) or spouse's (for married independent students) tax return transcript (can be obtained from the IRS)
   3. if the student (and parent or spouse) used the IRS Data Retrieval when submitting the FAFSA, a tax return transcript is not required unless changes are subsequently made

Additional documentation may be required to substantiate data on the FAFSA or to resolve conflicting information, as follows:

• child support received
• child support paid
• payments to tax-deferred pensions
• •value of real estate investment properties
• wages earned
• current valuation of assets

When students are selected for verification, the College's third-party servicer, Inceptia, generates an email informing them as to the process and the documentation required to review their file and applicable deadlines. Students who fail to respond to requests for documentation are repeatedly contacted by both Inceptia and the FAO on an established schedule with information about the importance of complying and the consequences of failure to do so.

Title IV regulations require that institutions have written policies supporting their administration of several aspects of verification. An overview of each required element is presented below. Title IV regulations require that the institution have the following written policies:

Selection for Institutional Verification

The FAO may at its discretion select students for verification who were not selected by the Central Processing System (CPS). The FAO may also select students for verification of data elements in addition to those required in the student's verification group. For example, the FAO will select students whose files contain conflicting information either within the award year or between award years. The FAO may also select known members of the same household when one member is selected by CPS. The FAO will not select students for verification based upon any discriminatory or unlawful reason.

The FAO may require those students it selects to verify any FAFSA information and to provide any reasonable documentation in accordance with consistently applied FAO policies. In either situation the FAO may, but is not required to, include any of the 2021–2022 CPS verification items not already included. Students who have been institutionally identified are considered to be selected for verification and, as with CPS-selected applications, all other verification requirements, such as notifications, deadlines, allowable tolerances, and interim disbursement rules, apply.

The deadlines by which students must submit verification documentation

The College's third party servicer for verification, Inceptia, notifies selected applicants upon receipt of the Institutional Student Information Record (ISIR) to submit required documents, which are listed in the notification email. On a weekly basis the financial aid counselors review the document tracking report which lists those students who still have incomplete files due to missing documents. The FAO requests that applicants submit their documents within ten days of the date of the notification email or their last day of enrollment, whichever occurs first.

The FAO and Inceptia continue to notify enrolled students throughout the semester to complete their files. Since the College does not disburse financial aid awards until after the verification process has been successfully completed, students must submit all of their verification documents so that they are received by Inceptia or in the FAO during regular business hours prior to the last day of the semester or the by student's last day of attendance, whichever comes first; however, students who delay and do not submit their financial aid forms until the final days of their enrollment may render themselves ineligible for grants and loans by doing so because there may be insufficient processing time. For example, if a student would have been eligible for a Direct loan and the loan was not originated prior to the student's last day of enrollment the student is ineligible to receive those funds.

The consequences for failing to submit verification documents by applicable deadlines

In the initial notification email and in all subsequent communications, the FAO notifies students that failure to submit all required documents will result in ineligibility for all forms of Title IV financial aid as well as some types of institutional aid. If the student has already received a disbursement(s) of Title IV aid for which the student has become ineligible, the notification from the FAO contains the information that the student will also forfeit those funds.

The method the FAO will use to notify students if their EFC and/or Title IV aid amount changes

If a student is selected after having been packaged and prior to all disbursements, the FAO provides notification as above. If the student's EFC and/or Title IV aid amount changes, the FAO notifies the student via email. The notification email contains information to enable the student to access the revised award letter.

The procedures the FAO will follow to correct FAFSA data

When any dollar or non-dollar item changes as a result of the verification process, the FAO or Inceptia submits the updated information correcting the student's FAFSA via the web. The ISIR is the report that is produced after the student files a FAFSA. The ISIR contains all of the student's answers to the questions on the FAFSA. The FAO usually downloads ISIRs twice a week: Monday – Friday. When the corrected ISIR, reflecting the updates, is downloaded into the College's student information system, the FAO confirms that the data is accurate. The FAO packages (or repackages, as necessary) applicants and students whose ISIRs are accurate and their files are otherwise complete.

The procedure the FAO will follow to refer a student or others to the Office of Inspector General (OIG)

If any college employee (or other individual) develops a credible suspicion that a student, parent, employee, or other individual has misrepresented information or altered documentation to fraudulently obtain federal funds, the employee is to report the observation to the Director of Financial Aid (DFA), Vice President for Student Affairs and Enrollment Management, or the Director of Human Resources (DHR). Unless the report is that the DFA's conduct has caused the suspicion, the DFA is to be immediately advised of the evidence. If the DFA is suspected of fraudulent activity the report is to be made to the DHR. Otherwise, the DFA is responsible for assembling any available evidence and providing it along with a statement (usually in writing) of the suspect activity to the OIG. The DFA will also refer the student for institutional disciplinary action. The DFA may also be required to report the suspected fraudulent activity to state agencies (and other entities) from which the student received financial aid funds.