How Do We Verify High School Completion If the Student's High School Is Closed Due To Coronavirus?

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This guidance is not award-year-specific and applies across award years.

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 AskRegs Knowledgebase Q&A was updated on January 25, 2021 to reflect extended deadlines in the January 15, 2021 Electronic Announcement and attached chart. Per the announcement, the following 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the end of the payment period that begins after the date on which the COVID-19 federally declared national emergency is rescinded.

Scenario: The student is selected for verification of high school completion in Verification Tracking Groups V4 or V5. The high school is closed at this time due to COVID-19.

Answer: According to the May 15, 2020 Electronic Announcement, since official high school completion documentation may be difficult for students to obtain during the pandemic (qualifying emergency), schools are permitted to verify a student’s high school completion status for V4 or V5 by accepting a signed and dated statement from the student which truthfully attests to his, her, or their secondary school completion. The statement must indicate whether a high school diploma or the equivalent was obtained and the date of completion (or approximate date).

The announcement also reminds schools that verification of high school completion status may also be completed through documentation previously obtained by the admissions or any other campus office. Remember also, even if the student's high school is closed, the student could attempt to get a copy of the diploma or documentation of high school completion from the local school district or the state department of education. Reference the Federal Register containing the verification documentation requirements for the applicable award year for additional alternatives.

This guidance also applies to institutions that require (as a result of their own policies) an official transcript to verify a student’s eligibility for Title IV participation beyond verification requirements noted above, and the student is unable to obtain a transcript after making a reasonable effort to do so. While the U.S. Department of Education (ED) is granting authority to accrediting agencies to implement temporary changes to its policies regarding confirmation of high school completion for non-verification purposes, the school must check with its accrediting agency before exercising this option.

Notes: 

"As outlined in the September 1, 2021, Federal Register notice, the Department removed high school completion status as a verification item under the V4 and V5 tracking groups starting with the 2022-2023 FAFSA processing year. As a result, institutions will no longer be required to obtain high school completion documentation to complete V4 or V5 verification. Further communication will be provided to the community with regards to any additional operational and system updates including any modifications to the V4/V5 verification results reporting process in FAA Access to CPS Online.

We do want to remind institutions that removing the high school completion status requirement from the verification process has not in any way removed or altered an institution’s obligation under 34 CFR 668.16(p) to evaluate the validity of a student’s high school diploma if your institution has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education (For more information please refer to the FSA Handbook, Volume 1, Chapter 1)."

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.