Can We Waive Verification For a FPS-Selected Applicant?

Although the applicant may be selected for verification by the FAFSA Processing System (FPS), certain applicants and FAFSA information can be excluded from verification as long as the institution does not have conflicting information or reason to believe information is inaccurate. If the institution has conflicting information or reason to believe the information is inaccurate, the verification exclusion does not apply and the institution must verify the application. The reason for the verification exclusion should be documented in the student’s file. If you do not see the exclusion below, it does not exist, and the entire application must be verified.

Exclusion of Entire Application—Student and Parent Data: The entire application (student and parent data) can be excluded from verification, if the applicant:

• Is eligible only for unsubsidized federal student assistance—that is, Direct Unsubsidized Loan, PLUS, and Teacher Education Assistance for College and Higher Education (TEACH) Grant funds—and is not selected for verification identity and Statement of Educational Purpose;
• Transfers from another institution and completed the verification process at the previous institution, if a letter is obtained from the previous institution stating the application was verified and giving the transaction number of the verified Institutional Student Information Record (ISIR);
• Will not receive Title IV aid for some reason other than failing to complete verification (e.g., being ineligible for Title IV aid and withdrawing without receiving it);
• Is selected for verification or changes verification tracking groups after ceasing to be enrolled at the institution for the award year with no plans to re-enroll during that same award year, and all Title IV disbursements (including late disbursements) have already been made; or
• Dies during the award year.

A student may not circumvent the verification process by opting not to apply for a subsidized loan and applying only for an unsubsidized loan. If the student is eligible for a subsidized loan, the student must complete the verification process even if he is interested in borrowing only the unsubsidized portion of the loan. In other words, if a student is eligible for both subsidized and unsubsidized Title IV aid, he must complete verification in order to be eligible for any Title IV aid.

While applicants generally are excluded from verification if they are only receiving unsubsidized Title IV aid, verification of identity and Statement of Educational Purpose is required because these are potential student eligibility issues, which always must be resolved if the applicant is selected for verification of these items while still enrolled for the award year. If an individual is eligible for only unsubsidized aid and is selected for verification tracking group V5, he needs to verify only identity and Statement of Educational Purpose; he does not need to verify any other FAFSA information, such as income, household size, or number in college.

If a student is selected for verification after she is no longer enrolled for the award year, and if there is pending aid to be disbursed, the school must offer the student the choice to receive any late disbursement for which she is eligible—that is, if she meets the conditions for a late disbursement under 34 CFR 668.164(j). This means a student with pending disbursements must complete verification even if selected for verification after she is no longer enrolled. If verification is not completed in this case, the student loses the undisbursed aid, but keeps the disbursed aid, and no late disbursement can be made.

Finally, if the applicant dies during the award year, verification is terminated and no further Title IV disbursements may be made. The student may retain any Title IV aid disbursements already made and any Federal Work-Study (FWS) funds already earned; these are not considered or reported as overpayments.

Exclusion of Applicant’s Parental Data Only: Only the parental data of a dependent applicant can be excluded from verification, if:

• Both parents die, or the only parent on the FAFSA dies;
• Both parents are mentally incapacitated, or the only parent on the FAFSA is mentally incapacitated;
• Both parents’ contact information is unknown and cannot be obtained by the applicant; or
• Both parents reside in a country other than the U.S. and cannot be contacted by normal means of communication.

Given technological advances in communications, the concept of “normal means of communication” varies based on the country in which the individuals reside; however, it is rare that parents cannot be reached by normal means of communications. If one parent can be reached, parental information must be verified.

Exclusion of Applicant’s Spousal Data Only: Only the independent applicant’s spousal data can be excluded from verification, if the applicant’s spouse:

• Is deceased or mentally incapacitated;
• Cannot be located because his contact information is unknown and cannot be obtained by the applicant; or
• Is residing in a country other than the U.S. and cannot be contacted by normal means of communication.

Exclusion of Certain Data Elements Only: Certain data elements can be excluded from verification, under certain circumstances. They are as follows:

• The number in the family size of a dependent student, if the parents are married, remarried, or unmarried and living together, and the family size is equal to three, or if the parent is single, separated, divorced, or widowed, and the family size is equal to two; or
• The number in the family size of an independent student, if the student is married or remarried and the household size is equal to two, or if the student is single, separated, divorced, or widowed and the family size is equal to one.

Exemption of the Institution: Foreign institutions participating in the Federal Direct Student Loan (Direct Loan) Program and not located in a state are exempt from all of the verification requirements.

Note: Incarcerated parents and spouses are not exempt from verification. Military servicemembers serving overseas are not exempt from verification. See AskRegs Knowledgebase Q&A, Is an Incarcerated Student, Spouse, Or Parent Required To Complete Verification and Submit Documents? (Award Year: 2023-24)

Reference 34 CFR 668.54(b) and Chapter 4 of the FSA Handbook Application and Verification Guide.