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

KA-34816 Helpfulness Rating 4,891 page views

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 flexibilities now apply through the end of the payment period that begins after the date on which the COVID-19 federally declared national emergency is rescinded.

Yes. The verification flexibilities (waivers) apply through the end of the payment period described above.

As a reminder, the April 3, 2020 Electronic Announcement extends verification flexibilities 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 15, 2020 Electronic 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...."

The July 9, 2020 Electronic Announcement extends flexibility to accepting alternatives when a W-2 is unavailable:

"During this period of national emergency, the Department is permitting institutions to accept a copy of a paystub, an employment offer letter, evidence of direct deposit from an employer, or other similar information for verification purposes. In the case of foster care youth, given the unlikelihood that such students would have earned enough to require them to file taxes, we will permit the institution to accept a signed statement from the foster care youth that he or she earned less than the amount that triggers the requirement for taxpayers to file tax returns."

The December 11, 2020 Federal Register extends flexibility for accepting verification documents, allowing schools to "...accept a document signed and photographed and sent by email or text message attachment, on any verification documentation required to validate a student’s Title IV eligibility."

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.