Do We Have To Verify Pell Special Rule Eligibility If the Student Is Already Eligible For Maximum Pell?

Yes. According to guidance NASFAA has received from the U.S. Department of Education (ED), the school still has to verify the student's eligibility under the Special Rule for Federal Pell Grants (for children of certain deceased military servicemembers or public safety officers) because it is a statutory requirement under Section 401(c) of the Higher Education Act of 1965 (HEA), as amended [20 USC 1070A(c)]: "(B) the financial aid administrator shall verify with the student that the student is eligible for the adjustment and notify the Secretary of the adjustment of the student's eligibility."

Although the school is permitted to pay the Pell amounts based upon the current valid Institutional Student Information Record (ISIR), the financial aid administrator (FAA) must continue to work with the student to determine if they qualify under the Pell Special Rule. If they do qualify, the FAA is then expected to update and document the student’s eligibility for the Special Rule within the FAFSA Partner Portal (FPP; formerly FAA Access).

See AskRegs Knowledgebase Q&A, Are Schools Required To Certify a Student's IASG and Children Of Fallen Heroes Eligibility?