Update: On Sept. 7, NCAN partnered with the National Association of Student Financial Aid Administrators (NASFAA) to send a joint letter to U.S. Secretary of Education Miguel Cardona calling on the Department of Education to extend the current verification relief before the new FAFSA cycle opens Oct. 1.
After providing crucial relief to students earlier this summer by suspending the majority of FAFSA verifications, the U.S. Department of Education (ED) released guidance this week that reinstates the category of verification that is paused for the current (2021-22) cycle. In a companion Dear Colleague Letter,
ED said it will “continue to consider additional flexibilities” for the upcoming 2022-23 FAFSA filing cycle.
Upon hearing the news, NCAN CEO Kim Cook offered the following response:
“NCAN is deeply disappointed that current verification relief has not yet been included in plans for the 2022-23 FAFSA cycle.
The changes the Department of Education made to help students during the end of the pandemic-impacted 2021-22 cycle are also smart policies to continue to reduce barriers to college access for underserved students.
Extending the current relief would help our advisers and school counselors spend more time on student support and postsecondary planning and less time on paperwork. This is especially important as we seek to build back from historic college enrollment
drops of over 10% for students from low-income backgrounds.”
NCAN calls on the U.S. Department of Education to extend the current verification relief before the new FAFSA opens on Oct. 1.
Challenges Ahead If Relief Is Not Extended
The changes ED issued in July instructed institutions of higher education to no longer require students flagged for the V1 verification group to complete the process, or those
flagged for the V5 group to verify financial information. This guidance is in addition to waivers that allow the use of alternative documents for the verification process, such as using tax returns instead of tax transcripts, which was granted in
January 2019.
ED has not yet decided if the requirement for institutions to process financial verification selections for the V1 and V5 categories will be waived for the upcoming FAFSA cycle (2022-23 award year). If no action is taken, the process will revert to including
the financial verification categories. However, the waivers regarding document types remain in place.
The possibility of financial verification (V1) returning for the 2022-23 cycle means the process could be different for the two FAFSAs open simultaneously from October 2021 to June 2022. The message students have been receiving for the last several weeks
regarding the 2021-22 award year is that the verification notifications on their Student Aid Report (SAR) can be ignored.
College access advisers, school counselors, and financial aid administrators may now have the difficult job of communicating that the notifications on the SAR matter once again. A student who completes the 2021-22 FAFSA this fall for a January start and
shortly thereafter completes the 2022-23 FAFSA for next fall would receive two different sets of instructions if ED does not choose to extend this verification relief.
The FAFSA used for the 2022-23 cycle is based on 2020 taxes. This means the FAFSA that opens in October will request financial information from the year the COVID-19 pandemic and its devastating economic consequences began. Students will be asked to complete
verification for a tax year where many families had significant changes in income.
Feedback From the College Access and Success Field
Ninfa Murillo, director of scholarship and financial wellness at NCAN member Achieve Atlanta, explains why reducing verification’s burden on students is important beyond the current circumstances of the pandemic:
"The impact of verification relief extends beyond securing financial aid. The verification process often stalled our support window with our students and increased their uncertainty about college enrollment. Verification relief has given our student
support team the opportunity to focus on the very real summer melt issues like securing housing, deciphering financial aid packages, and providing social-emotional support; all of which increase the likelihood of seamless enrollment for our students."
Without the continuation of this relief for students and families, at least 18% of FAFSA filers will once again be selected for verification. This is based on a target rate announced by FSA at
its annual conference in December 2020.
The challenge of verification is not only a struggle for college access programs; it also places a burden on school counselors.
"For School Counselors who continuously fight for spending time in direct counseling-related tasks with students this is a huge burden taken off our plate,” said Dr. Yuri Nava, school counselor with Riverside Polytechnic High School. Dr. Nava expressed
a similar opinion that “[t]his change is monumental in allowing school counselors to spend time advising rather than performing administrative tasks!"
Financial aid administrators are also in agreement that they can better serve students without the burden of verification clogging up the process. Justin Chase Brown, director of financial aid and scholarships at the University of Nebraska tweeted about
this on the first day of class last week:
Today was BEST 1st day of classes in my FA career. Phones never hit limit,
<100 emails in inbox, virtual/in-person manageable=students getting remarkable service. Many reasons, but lots can be said for federal verification not hanging over students ' heads. #fachat@nasfaa@FSACOO
National Association of Student Financial Aid Administrators (NASFAA) President and CEO Justin Draeger echoed this sentiment in his statement about the change, also calling for action before Oct. 1: “While more nimble and agile than ever, financial aid
offices cannot simply pivot every few months to operationalize new and different federal requirements.”
What is FAFSA Verification?
FAFSA verification is an audit-like process intended to reduce improper financial aid payments and fraud by the federal government. Students selected for verification are asked to prove that the information provided on their FAFSA is accurate by submitting
additional financial forms (e.g., tax transcripts) and/or other documents.
Students can be selected for financial verification (V1) to confirm that they accurately answered all questions on the form or identity/educational purpose (V4) which targets fraud from individuals. Some students are selected for both (V5). The current
relief in discussion is the waiver for V1 for the 2021-22 FAFSA cycle. The V4 category targeting fraud remains in effect.
How is Verification Inequitable?
Students of color and students from low-income backgrounds rely on Pell Grants to attend college and are disproportionately represented in the pool of financial aid applicants selected for verification. The changes ED made to the verification process in July were meant to provide relief during COVID, yet the economic effects of the pandemic on students have not decreased. But more crucially, the root causes of inequitable access to financial aid run deeper than
the current health crisis. The Washington Post found that students from predominantly Black and Latino neighborhoods are more likely to be selected for
verification.
Further, an NCAN analysis shows that most students selected see little to no change in the size of the Pell Grant
after completing verification. For the two award years examined, 70% of students who completed verification experienced no change in their Pell Grant award. The same analysis found that approximately 95% of students who received an automatic-zero-dollar
Expected Family Contribution (EFC) saw no change in their Pell Grant award.
While verification has a role in ensuring the proper distribution of taxpayer dollars, a more equitable balance is needed to ensure the burden on students does not outweigh the benefit to the taxpayer. NCAN made this argument in July to the White House Office of Management and Budget (OMB) in response to their request for practices to advance equity to underserved communities through government. Reversing course on verification relief seems to move in the opposite direction of
the goals stated by OMB.
NCAN will continue to keep our members updated about any developments regarding verification for the 2022-23 FAFSA cycle. We will also continue urging the Department of Education to extend the current verification relief.
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