Consistent with the USDE regulations, the 2015–2016 FASFA data items that may require verification for an applicant selected for verification and the acceptable documentation for those items were announced in the federal register released June 25, 2014. This Federal Register notice did not include any changes to the FAFSA items that may need to be verified. However, based on suggestions from the financial aid community, USDE provided clarification and additional guidance for some of the verification items and acceptable documentation for the 2015–2016 award year.
Obtaining a Duplicate Internal Revenue Service (IRS) Form W-2
In instances where an applicant or parent is required to provide copies of IRS Form W-2, and the applicant or parent did not save their copy, the applicant or parent should request a replacement copy from the employer who issued the original W-2.
Determining Adequacy of Income – Verification Tracking Group V6
Institutions should use reasonable judgment when evaluating the validity of the income information provided by students and parents who are placed in Verification Tracking Group V6, and are therefore asked to provide information on how they financially supported themselves or their families. The term “reasonable” may differ among institutions, and may depend on student demographics and experiences. Just as institutions are given the option to accept a statement from students and parents as acceptable documentation for household size, number in college, untaxed income, etc., institutions may choose to accept a signed low-income statement, an income-to-expenses comparison, or other documentation as determined by the institution. Such documentation will allow students or parents to clarify how they supported themselves and, if applicable, their families. This support may include: receipt of public assistance, veteran’s educational benefits, or other income that is not included on the FAFSA; shared-living arrangements that drastically reduce living costs; instances of poverty or homelessness; or documentation of low-living costs.
Other Untaxed Income and W-2s
All applicants placed in Verification Tracking Group V6 must provide a copy of their IRS Form W-2 for each source of employment income received for tax year 2014 to verify other untaxed income that was not transferred using the IRS Data Retrieval Tool or that did not appear on an IRS Tax Return Transcript. The IRS Form W-2 is used to verify whether there was any such income that should have been reported on the FAFSA or if it was reported correctly.
If an institution questions a claim that an applicant or parent has not, will not, and is not required to file a 2014 IRS income tax return, the institution must require the applicant to submit a “Verification of Nonfiling Letter” from the IRS indicating that the tax filer did not file a 2014 IRS income tax return. A request to the IRS for a Verification of Nonfiling Letter can be made using the IRS “Get Transcript Online” tool at www.irs.gov/Individuals/Get-Transcript or by submitting IRS Form 4506-T and checking box 7.
IMPORTANT NOTE: A response to a request for a Verification of Nonfiling Letter for the 2014 tax year generally will not be issued until after June 15, 2015. However, because there are limited circumstances when the IRS will provide a Verification of Nonfiling Letter before June 15, 2015, for purposes of verification, the Verification of Nonfiling Letter for the 2014 tax year must be dated on or after June 15, 2015. Finally, receipt of a Verification of Nonfiling Letter does not address whether or not the tax filer was required to have filed a tax return.
Dependency Status and Number of Household Members
Institutions are reminded that the FAFSA reported household size may need to be coordinated with one of the dependency questions on the FAFSA and any necessary corrections should be reported to the CPS. An example is when an applicant who answers “yes” to the dependency question about having “dependents other than a spouse” reported a household size of one. Should such an applicant verify that the household size is actually one, the answer to the “dependents other than a spouse” question on the FAFSA should be changed to “no.” It is important that these elements be accurate and corrected with the CPS since they have a direct effect on dependency status and the Expected Family Contribution (EFC) calculation.
FAFSA Parental Information
As with the 2014–2015 FAFSA, parental information for the unmarried parents of a dependent student must include both of the student’s legal (biological or adoptive) parents if those parents live together, regardless of the gender of the parents (see Dear Colleague Letter GEN-13-12). This includes not only the reporting of income and other financial information, but also nonfinancial information such as number of household members.
The Defense of Marriage Act
In Dear Colleague Letter GEN-13-25 USDE provided guidance on the implications of the Supreme Court’s decision on the Defense of Marriage Act (DOMA), as it applies to completion of a FAFSA and the calculation of a student’s EFC. As noted in Dear Colleague Letter GEN-13-25, for purposes of the Title IV Higher Education Act programs, a student or parent is considered married if the student or parent was legally married in any domestic or foreign jurisdiction that recognizes the relationship as a valid marriage. This applies to all parents or students, regardless of the couple’s gender, where the couple resides, or where the student will be attending school.
High School Completion Status
Applicants placed in Verification Tracking Groups V4 and V5 must provide documentation verifying their reported high school completion status. Institutions have asked USDE for additional guidance for applicants who have taken State-authorized examinations (e.g., the GED test, HiSET, TASC, or other State-authorized high school equivalency examinations). Test transcripts submitted by an applicant are acceptable documentation of high school completion only if:
– The official test transcript specifically indicates that a State has determined that the test results are considered by the State to meet its requirements of high school equivalency; or
– The official test transcript includes language that the final score is a passing score.