What Forms Of Identification Can Be Provided By an Incarcerated Student To Complete Verification?

To complete verification of identity, the student must appear in-person to a school-designated official or a notary public and provide an unexpired valid government-issued photo identification (ID) such as, but not limited to, a driver’s license, non-driver’s identification card, other state-issued identification, or U.S. passport. See AskRegs Knowledgebase Q&A, Which Documents Are Acceptable and Unacceptable When Verifying Identity? This includes confined or incarcerated students. According to the verification Dear Colleague Letter (cited below), an official inmate ID issued by a correctional facility (government owned or privately run) is acceptable, even if it does not have an expiration date.

Electronic Announcement APP-25-16 allows the following alternatives for presenting the ID:

• The student has the option of appearing on a video call with a school-designated official to present the ID to an institutionally authorized individual who will review the identification. The video call option will require the institution to maintain a scanned copy (electronic or hardcopy) of the ID that includes the date it was presented and the name of the authorized representative who reviewed the documentation. This can be accomplished through a screenshot of the video call that has legible details of the ID.
• The student’s ID can be verified by a responsible official at the correctional facility (i.e., an authorized official who works for the correctional facility or oversight entity) where the individual is confined or incarcerated. In this instance, the institution must retain as documentation an electronic or paper confirmation of the student’s identity verification, the responsible individual at the facility, and the name of the institutionally authorized representative who performed the verification.

Note: The above guidance does not apply to schools in the Second Chance Pell Experiment (SCPE). ED's prior guidance for SCPE schools is different and does not apply to schools awarding Federal Pell Grants under a Prison Education Program (PEP) effective July 1, 2023. The difference in guidance relates to the ID. Per ED, at a SCPE school, the designated school official can place a signed, dated statement in the student's file indicating they saw and verified the student’s correctional facility ID (without needing a copy of the ID in the student's file). ED is aware of this difference but has not yet reconciled it. Any questions related to the SCPE should be directed to the school's SCPE coordinator.

For verification requirements, reference the September 4, 2024, Federal Register and Dear Colleague Letter GEN-24-10 (for 2025-26) or the September 19, 2023, Federal Register and GEN-23-12 (for 2024-25). See the verification Federal Register and Dear Colleague Letter for each subsequent award year.

P&P Builder: NASFAA’s Policies & Procedures (P&P) Builder guides you step-by-step through the creation of a centralized, accessible policies and procedures manual. This is included in the cost of NASFAA Value Plus membership. There is an additional cost for other membership levels.