How Do We Verify Identity and Statement Of Educational Purpose For Incarcerated Students?

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

When verifying identity and Statement of Educational Purpose for confined or incarcerated students, the school can accept any form of valid, unexpired government-issued photo identification (ID) along with the required Statement of Educational Purpose. NASFAA has confirmed with the U.S. Department of Education (ED) that an inmate ID issued by a correctional facility is considered acceptable documentation, even if it does not have an expiration date. This includes IDs issued by government facilities and privately operated facilities.

The ID must be presented and the Statement of Educational Purpose must be signed at the same time in person with a designated school official or in person with a notary public. NASFAA has learned that many schools serving this population send a financial aid staff member or a school-designated official to collect the ID and Statement of Educational Purpose in person. If the school cannot do this, the incarcerated individual will still have to get this done in person with a notary public. If the prison does not offer notary services, the school will need to take measures to collect the ID and Statement in person.

There are no special exceptions for this population, so, if the school decides to offer educational programs to this population, the school will have to take steps to meet the verification requirements in person. School or prison officials cannot sign the Statement of Educational Purpose on the student's behalf.

Refer to the Federal Register and Dear Colleague Letter containing the verification documentation requirements for the applicable award year—they sometimes vary by award year. See also AskRegs Q&A, Which Documents Are Acceptable and Unacceptable When Verifying Identity? 

Student Aid Reference Desk: For additional information, try the Student Aid Reference Desk. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes.

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.