Are There Exceptions To the In-Person and Signature Requirements For Identity/Statement of Educational Purpose Due To Coronavirus?

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2022-23 Verification Waiver: Beginning May 18, 2022 and for the remainder of the 2022-23 FAFSA processing and verification cycle, the U.S. Department of Education (ED) waives verification of all FAFSA/ISIR information, except for identity/Statement of Educational Purpose in Verification Tracking Groups V4 and V5. See Dear Colleague Letter GEN-22-06 and AskRegs Q&A, How Do We Implement the Verification Waiver For the Remainder Of 2022-23?, for guidance. The following guidance is still relevant depending on context and/or application of the waiver.

This Q&A was updated on May 24, 2022 to provide clarify on the conditions under which the COVID-19 flexibility related to identity and Statement of Educational Purpose continues to apply even though GEN-22-06 does not include the complete language related to the original flexibility.

Yes. The following guidance applies to verification of identity and Statement of Educational Purpose and is from the April 3, 2020 Electronic Announcement (bolded for emphasis):

"For those [students] in verification groups V4 or V5, the flexibilities listed below apply if the institution is unable to receive the required documents in person or by mail (e.g., qualified staff are not on campus to complete this task or students are not able to mail documents). These flexibilities also apply if the applicant or student is unable to provide the required documents in person or cannot provide notarized documents by mail.

We suspend the in-person submission and notary requirements for V4 and V5 verification. The institution may allow an applicant or student to submit copies of the required verification documents electronically to the institution. This may occur by uploading a photo of the documents (including from a smartphone), PDF, or other similar electronic document through a secure school portal, by email, etc.

We also recognize that forms of identification (such as a driver’s license) may expire with no real and reasonable opportunity for renewal due to social distancing requirements. Institutions may accept a copy of an expired document if it expired after March 1, 2020."

According to confirmation NASFAA has received from the U.S. Department of Education (ED), this guidance was never intended to be a wholesale waiver of the in-person requirement for identity/Statement of Educational Purpose in all situations. The financial aid office has to make a determination as to whether the school or the student meets the conditions that are bolded above. If the school or the student meets either of the bolded conditions, students can still submit the identity/Statement of Educational Purpose to the school electronically. This can be done by uploading a photo of the documents, a PDF, or other similar electronic document through a secure school portal, by email, by text, etc.

In other words, if the school is able to receive the required documents in person or by postal mail from a notary, and the student is able to present the documents in-person, the flexibility no longer applies. However, if the student is unable to provide the required documents in person and cannot provide notarized documents by postal mail because of COVID-19, the flexibility still applies. The aid administrator has to make that determination and decide how to document it; how that is done is not prescribed by ED.

If the school or the student does not meet the bolded conditions, the ID and Statement of Educational Purpose must be either:

Of course, the Statement of Educational Purpose still must be signed. According to guidance NASFAA has received from ED, under normal circumstances the hardcopy with the original "wet" signature must be maintained in the student's file. However, due to COVID-19, the school may accept an electronic signature using a stylus or finger to sign the document, or an image of the individual’s signature affixed to the document, to complete the Identity/Statement of Educational Purpose verification requirement, but only for the effective period noted below. 

The Statement of Educational Purpose must accompany a government issued photo ID. And, it still can be sent by postal mail. Unfortunately, ED's guidance does not mention students who did not previously have a government-issued photo ID and are currently unable to get one due to office closures and social distancing.

Video Conferencing: Schools also have asked whether video conferencing (e.g., Zoom, Facetime, Skype, Microsoft Meetings, etc.) can be used to complete the identity and Statement of Educational Purpose requirement during or after COVID-19. According to guidance NASFAA has received from ED, video conferencing is not an acceptable alternative for completing this V4/V5 requirement during or after the COVID-19 qualifying emergency. ED plans to revert back to pre-pandemic guidance at the end of the qualifying emergency, as announced annually in the Federal Register containing the verification documentation requirements for the applicable award year.

Effective Period of COVID-19 Exception: Per the January 15, 2021 Electronic Announcement and attached chart, the above guidance now applies through the end of the payment period that begins after the date on which the COVID-19 federally declared national emergency is rescinded. See AskRegs Q&A, When Do the Various Title IV COVID-19 Flexibilities and Waivers End? 

Reporting: According to the FAA Access to CPS Online Demo System, when exercising the above flexibilities, you report Identity Verification Results code "2--Verification completed remotely, no issues found" when using the above flexibilities and reporting this in FAA Access. According to guidance NASFAA received from ED, the school also uses code "2" for students who were able to complete the verification requirement using a notary public (that counts as "remotely").

Update Notes:

AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.