Can We Accept an Emailed, Faxed, Copied, Or Scanned FAFSA Signature Page Due to COVID-19?

Yes. Under normal circumstances, if a school is going to be the repository of a signature related to the completion of a FAFSA, the school would be required to maintain an original signature page with an original (“wet”) signature in the student’s file. However, according to guidance NASFAA has received from the U.S. Department of Education (ED), the school may accept a copy of a signature page for FAFSA completion purposes if both of the following conditions are met:

• A student or parent is unable to create an FSA ID; and
• The student or parent cannot print a signature page or deliver an original wet signature to an institution in a timely manner (e.g., office closures, inability to access a printer, undeliverable international mail, etc.) due to circumstances related to COVID-19.

The signature can be a copy or photograph of an original wet signature that is then sent to the financial aid office through alternate means, such as email, fax, text, scanned document, or upload to a secure portal. The FAFSA signature page can also contain an electronic signature (e.g., by using a stylus, finger, or an image of the individual’s signature affixed to the signature page) that then sent to the financial aid office through alternate means, such as email, fax, text, scanned document, or upload to a secure portal.

Be especially aware that this is a temporary flexibility offered by ED for this limited purpose during the COVID-19 qualifying national emergency, and it is only to be used when an original wet signature page cannot be obtained for reasons specifically related to COVID-19. This guidance expires at the end of the payment period that begins after the date on which the federally declared national emergency related to COVID–19 is rescinded.  For example, if the qualifying emergency ends during the spring payment period, then this flexibility extends through the end of the summer payment period, and so on. 

ED also reminds schools of the following guidance from pages AVG-40 to AVG-41 of the Application and Verification Guide (AVG) volume of the 2020-21 FSA Handbook:

"Substitutes for a parent’s signature. While parent information must be provided for a dependent student, a high school counselor or a college aid administrator may sign the application in place of a parent if

• the parents are not currently in the United States and cannot be contacted by normal means,
• the current address of the parents is not known, or
• the parents have been determined physically or mentally incapable of providing a signature.

The signer must provide her title in parentheses next to her signature and briefly state the reason (only one is needed) why she is signing for the parents; if this is not done, the FAFSA will not be processed. The signer assures a minimum level of credibility in the data submitted; however, she does not assume any responsibility or liability in this process. If the counselor or FAA finds any inaccuracies in the information reported, she should direct the student to send the SAR through the normal correction process or, if she is an FAA, she can submit corrections through FAA Access to CPS Online. Because this proxy signing isn’t possible electronically, it must be done on a paper FAFSA or on the signature page/FAFSA summary used with FAA Access."