Do the COVID-19 Verification Flexibilities Apply To the 2020-21 Award Year?

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This AskRegs Knowledgebase Q&A was updated on August 24, 2020 to reflect extended deadlines in the August 21, 2020 Electronic Announcement. Per the announcement, the following guidance now applies through the end of the payment period that includes December 31, 2020 or the end of the payment period that includes the end date for the federally declared qualifying emergency related to COVID-19, whichever occurs later.

Yes. The verification flexibilities (waivers) in the April 3, 2020 Electronic Announcement and May 15, 2020 Electronic Announcement apply through the end of the payment period described above.

As a reminder, the April 3rd announcement extends verification flexibilities only to identity and Statement of Educational Purpose, as well as to parent signature requirements for household size and number in college and reads as follows:

"For those borrowers 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.

Further, the Department waives the requirements under § 668.57(b) and (c) that a dependent student submit a statement signed by one of the student’s parents when no responsible parent can provide the required signature. In such a situation, the institution must note and retain an explanation of why neither of the student’s parents was available to provide such a statement."

The May 15th announcement extends flexibility to documenting high school completion as follows:

"Official documentation of high school completion or documentation of the equivalent of high school completion may be difficult for FAFSA applicants to obtain during this national emergency. For applicants in verification groups V4 or V5, institutions should use documentation of an applicant’s high school completion status that it may already have obtained for other purposes (e.g., documentation maintained in its admissions office). Where an applicant is unable to obtain such documentation and an institution does not already have such documentation, it may accept a signed and dated statement from the applicant in which he or she truthfully attests to his or her secondary school completion or the equivalent. The statement must indicate whether a high school diploma or the equivalent was obtained and date of completion (or approximate date). ...

In addition, institutions that require (as a result of their own policies) an official transcript to verify a student’s eligibility for Title IV participation that are unable to obtain a transcript after making a reasonable effort to do so institutions may accept a signed and dated statement from the applicant in which he or she truthfully attests to his or her secondary school completion. While this attestation does not obviate institutional requirements to meet applicable state authorizing agency or accrediting agency requirements regarding proof of high school or equivalent completion status, the Department is granting authority to accrediting agencies to implement temporary changes to its policies regarding verification of high school completion for the time period covered by this guidance...."

Note: This AskRegs Q&A was previously updated on June 9, 2020 and June 15, 2020 to reflect the U.S. Department of Education's (ED's) interpretation of the verification flexibility timeframes provided in the April 3, 2020 Electronic Announcement. 


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