Verification is the process by which the FAO compares the information on the financial aid application with source documents provided by the student to verify the accuracy of the application information. These policies are to be used in conjunction with the Department of Education and the California Student Aid Commission (CSAC) verification guidelines. Mt. San Jacinto College will verify the information on the Student Aid Report (SAR) or ISIR for all students who complete the application process for federal & state financial aid and who are selected for verification by the Department of Education or the California Student Aid Commission edits. In addition, MSJC may select files for verification to resolve conflicting information or institutional edits.
At Mt. San Jacinto College, financial aid will not be awarded to those selected for verification until all documents required are submitted and the verification has been completed.
Verification Deadlines for 2014-2015
The key application deadline, regulated by the U.S. Department of Education, will be followed at MSJC and can be located in the Department of Education Verification Guide.
Deadline for 2014-2015: Students who fail to turn in all documents required to complete verification by the appropriate deadline at MSJC (2014-2015 final verification deadline at MSJC is May 20, 2015) will be ineligible for financial aid for 2014-2015. MSJC reserves the right to cut off applications earlier based on workload.
If discrepancies are found between the documents submitted for verification and the information on the SAR or ISIR, the following procedures will be used for making the corrections:
· SAR – corrections to income or asset figures, household size, and dependency must be made in Colleague and a new need analysis performed. If the corrections result in a changed EFC, the data must be transmitted to the Central Processor to produce an electronic student aid report.
· Award changes – If corrections to the SAR due to verification result in a change in the student’s award, the student will be sent a revised award letter notification by email. Financial aid notifications are produced weekly for new awards and changes to awards made during the previous week.
A random selection of the financial aid population may be selected for verification by the Department of Education or California Student Aid Commission. The FAO at MSJC will perform additional verifications on all students who have conflicting data in the file documents.
Notification of Verification Requirements
Students will be notified of the documents that must be submitted to the FAO in order to complete verification by a FA acknowledgement and missing information letter (email). The FA acknowledgement and missing information letter (email) will list the required verification items, any other actions required to complete verification, and other items required by the FAO. FA acknowledgement and missing information letters (email) are generated to the students MSJC student email account.
Students who fail to bring in the documents may lose their priority standing for campus-based awards.
Items to be Verified
Students who are selected for verification will be placed in one of the five following groups. The groups determine which FAFSA information must be verified for the student.
Verification Tracking Groups
1. Standard Verification Group. Tracking flag V1.
Students in this group must verify if they are tax filers:
· Adjusted gross income
· US tax paid
· Untaxed portions of IRA distributions
· Untaxed portions of pensions
· IRA deductions and payments
· Tax-exempt interest income
· Education credits
· Household size
· Number in college
· Supplemental Nutrition Assistance Program (SNAP) benefits
· Child support paid
Students who are not tax filers must verify the following:
· Income earned from work
· Household size
· Number in college
· SNAP benefits
· Child support paid.
Verification is not required if the –
· Applicant is dependent and the applicant’s parent’s marital status is single, separated, divorced, or widowed, and the family size reported on the FAFSA is two.
· Applicant is dependent and applicant’s parents’ marital status is married, and the family size reported on the FAFSA is three.
· Applicant is independent and the applicant’s marital status is single, separated, divorced, or widowed, and the family size reported on the FAFSA is one.
· Applicant is independent and the applicant’s marital status is married, and the family size reported on the FAFSA is two.
· Number of household members enrolled at least half-time in eligible postsecondary institutions (the number in college) reported on the FAFSA is one
2. SNAP Verification Groups. N/A
3. Child Support Paid Verification Group. Tracking flag V3.
Student must verify child support paid by them or their spouse, their parents, or both. Child support will be verified by self certification on the Child Support Verification Form unless there is a discrepancy in the information submitted. In such a case, the student (or the student’s parent, in the case of a dependent student) will be required to provide the FAO with a copy of the divorce decree, or other appropriate documents. Unless there is evidence to the contrary, it will be assumed that anyone on AFDC is not receiving child support.
4. Custom Verification Group. Tracking flagV4.
Students must verify high school completions status and identity/statement of education purpose in addition to receipt of SNAP benefits and payment of child support.
5. Aggregate Verification Group. Tracking flag V5.
Students must verify all items in Custom Verification Group and Standard Verification Group.
6. Household Resources Verification Group. Tracking flag V6.
In addition to items in the Standard Verification Group, students must verify other untaxed income on the 14-15 FAFSA:
o Payments to tax-deferred pension & savings (Questions 45a & 94a)
o Child support received (Questions 45c & 94c)
o Housing, food, & other living allowances paid to members of the military, clergy, & others (Questions 45g & 94g)
o Veterans non-education benefits (Questions 45h & 94h)
o Other untaxed income (Questions 45i & 94i)
o Money received or paid on the applicant’s behalf (Question 45j)
Federal regulations consider you a dependent student for financial aid purposes unless you meet one of the following criteria An independent student may be required to verify his/her status by filling out specific documents related to the specific application item that makes the student independent:
· Birthdate –Successful process of FAFSA through Social Security Administration
· Marital Status- Self certification at the time of FAFSA submission
· Bachelor Degree- Self certification on FAFSA that student is working beyond a bachelors degree.
· Orphan or ward of the court – Court documents to show ward of the court status and self certification on FAFSA for orphan. Parent’s death certificate (s) if applicable
· Foster Care - anytime since age 13 and documentation
· Veteran Status – copy of the student’s DD214 member 4 or official letter from Commanding Officer
· Dependent child(ren) – Self certification on worksheet and reasonable income
· Legal dependents other than a spouse – Self certification on worksheet. If adult dependents, income information showing that the student has the resources to provide more than 50% of the dependent’s support may be requested
· Emancipated Minor - Court’s documentation verifying status according to your legal state of residence at the time of court’s decision
· Legal Guardianship- Court’s documentation verifying status according to your legal state of residence at the time of court’s decision
· Homeless/ runaway - Letter from the school district homeless liaison; Director of Housing and Urban Development; Director of a runaway or homeless youth basic center or transitional living program
Verification of Income
All students selected for verification must submit a copy of his/her tax transcripts and/or parents’ tax transcripts (if the IRS Data Retrieval was not used). If the student or parent did not file taxes and was not required to file taxes, copies of the student’s or parent’s W-2 forms will be requested. If a student or parent was required to file taxes and did not, verification cannot proceed until the student or parent submit a tax transcript or use the IRS Data Retrieval on the FAFSA.
— If the student and his/her spouse or parents of a dependent student are separated or divorced, but filed a joint tax return, W-2 forms are required so as to determine the amount of income and taxes paid for the student or the custodial parent of a dependent student. (Custodial parent refers to the parent who had custody of the student or who the student last lived with.) In the case of stepparents, both incomes will be used in the calculation..
— If the student’s parent(s) filed an amended 2013 IRS tax return, the parents must provide both a 2013 IRS Tax Transcript and a signed copy of the 2013 IRS Form 1040X “Amended US Individual Tax Return that was filed with the IRS.
— If an individual has been granted a filing extension by the IRS, provide the following documents: A copy of the IRS Form 4868 “Application for automatic Extension of Time to file US Individual Tax Return and copy of IRS Form W-2 for each source of employment received for tax year 2013 and if self employed, a signed statement certifying the amount of the individuals AGI and US Income tax paid for tax year 2013.
— A victim of IRS identity theft who has been unable to obtain a 2013 IRS Tax Return Transcript or use the IRS DRT must provide a signed copy of the 2013 paper IRS income tax return that was filed with the IRS and a signed copy of IRS Form 14039 “Identity Theft Affidavit” if one was submitted to the IRS. If a copy of Form 14039 was not retained or the IRS did not require you to submit one, the student or parent (if dependent) may provide one of the following:
o A statement signed and dated explaining he/she was a victim of IRS identity theft and that IRS is investigating the matter. The statement must also indicate that the individual submitted a Form 14039 to the IRS but did not keep a copy or that he/she was not required to file the form: or
o A copy of a police report if it was filed related to the IRS identity theft.
2013 Tax filing requirements
IF your filing status is...
AND at the end of 2013 you
THEN file a return if
your gross income
was at least...**
65 or older
married filing jointly***
under 65 (both spouses)
65 or older (one spouse)
65 or older (both spouses)
married filing separately
head of household
65 or older
qualifying widow(er) with dependent child
65 or older
If you were born on January 1, 1949, you are considered to be age 65 at the end of 2013.
Self-employed individuals generally must file a tax return if their net income from self employment was at least $400.
Other Untaxed Income
The following will be verified from the student’s or the student’s parents tax transcript –
Untaxed payments to IRA/SEP/KEOGH
Untaxed portions of IRAs/Pensions
Tax-exempt Interest Income
If taxes were not filed, there is no need to verify these items. A 4506T may apply.
Discretionary Verification Items
The following sources of untaxed income will not be verified unless there is evidence of a discrepancy:
General Relief / other welfare grant
SSI / Social Security
State Disability Benefits
Other untaxed income
In the case of AFDC, General Relief, other welfare grant, and SSI, because the amounts of these benefits are standard amounts, if the financial aid technicians wishes to verify the amount that the student is receiving, the specialist may do so with a chart of benefits published by the appropriate agency.
Assets will not be verified unless there is evidence of a discrepancy.
The Financial Aid Technician in the process of verification has the discretion to verify any additional application items and to ask the student to supply any documentation that may be needed to substantiate the student’s financial aid application.
If there is legitimate discrepancy between the application information and the verification document, the specialist will note the reason for the discrepancy in the student’s file.
Business Value Guidelines
Any tax return that does not demonstrate sufficient income (AGI) to support “write-offs” a Income and Expense form will be mailed to the parent/student whichever applies.
Business below would pertain to 100 employees or more.
The following is a guideline to reviewing and requesting the business value from students/parents. A 1040 that lists business income on line 12 should be viewed in the following manner:
Self-employed: The student or parents have inventory or equipment with no building, ex: swap meet, landscaping, where they rent space only. Acceptable documentation is a Statement of Fact estimating the equipment and inventory utilized for sale or service that has been signed by the student and/or parent.
Self-certified: The parent or student listed a dollar amount on the FAFSA under business value and not further documentation is needed. They have acknowledged that they own a business and have assessed the value of the business.
Sub-contractor: The parent or student works for commission and acceptable documentation is a 1099 only.
Land and Property: The parent of student owns a business which includes land and property. Give the student the Asset Information form, request schedule C and C-EZ. Explain to the student that line 12 shows a dollar amount and on the FAFSA under business value, shows zero or blank. The business request form will further explain how to retrieve and submit the acceptable documentation.
Income Reduction Policy
Income reductions will not normally be considered upon the student’s submission of the required documents. The independent student or parent of a dependent student must wait until January of the award year and provide documentation of actual earnings from the tax year that just ended. This will avoid the pitfalls of trying to project an income.
Students are requested to follow the procedures for completing an Income Reduction request. Keep in mind, that an EFC can only be adjusted with proper documentation.
Income reduction adjustment will be made only one time.
Resolving Comments on the Student Aid Report
The Mt. San Jacinto College Financial Aid Office uses the following criteria for resolution (in conjunction with the guidance stated in NASFAA’s Training guides on resolving ISIR comments):
1. Immigration and Naturalization Services were unable to verify status as eligible non-citizens. We will photocopy the student’s most current immigration document and complete the DHS form G-845. The completed form and the photocopy will be mailed to the DHS.
· The requirement to send form G-845 to DHS may be waived if secondary confirmation was received in the previous year and the documents sent to DHS with the G845 have not expired. There must be no conflicting information.
2. Selective Service was unable to certify compliance with registration requirements. Self-certification is acceptable for female students and male students born before January 1, 1960.
· Male students will be instructed to contact the Selective Service Agency for confirmation of registration or a letter from Selective Service describing the individual student’s status (www.sss.gov) link available on the MSJC FAO website). Any ambiguous or unfavorable responses will be forwarded to the FAA or designee who has the authority to determine if the student willfully avoided registration with Selective Service. If the FAA determines that the student willfully avoided registration with Selective Service, no Title IV aid will be awarded. No aid will be awarded until a response is received from Selective Service and/or a decision is made. Once this decision has been made it will carry forward to all academic years.
3. Records indicate that default exist.
· Student will be instructed to contact the agency listed on the SAR to resolve the default. It will be the responsibility of the student to secure documentation-proving resolution of the default and to provide a copy of the documentation to the FAO. Acceptable documentation may include a letter from the current or last holder of the loan, a promissory note marked “paid in full”, or any written material clearly indicating the borrower has made at least six consecutive monthly payments on the loan. No Title IV aid will be awarded to the student until the default issue is resolved.
4. Name mismatch with NSLDS indicates that the social security number listed on the SAR matches a record in the National Student Loan Data System, but the name does not match.
· We will access NSLDS and review the data to determine how to resolve the mismatch. Only the provider of the data to NSLDS can change the data, therefore, MSJC FAO will work through that entity.
5. Social security number mismatch indicated will need resolution
· No Title IV aid will be awarded until this situation is resolved.
6. SSN did not match – the social security number reported on the SAR is not a valid number
· If the student is correcting the number, no further resolution is needed. If the student insists that the number is accurate, he or she must get written documentation from the Social Security Administration verifying the number. The student must complete a new FAFSA with his/her correct social security number.
7. SSN and name match, no DOB match
· The birthdate reported on the SAR does not match the Social Security Administration’s records. The student will need to provide an explanation; note the explanation in the student file documentation.
8. SSN match, no name match
· The name reported on the SAR does not match the Social Security Administration’s records. The student must provide an explanation; document this explanation in the student file. If name mis-match is due to a nickname being used (i.e., Bob instead of Robert) no further action is required. If name mis-match is due to marital status or citizenship status the student must complete the name change with the Social Security Administration and provide the FAO with documentation of the name change.
The student will have until the last day of the semester for which aid is requested to resolve the issue prompting the comment on the SAR.
Subsequent ISIR transaction
If the Financial Aid Office receives another ISIR transaction after the student’s file has already been awarded, the new ISIR transaction must be verified. Any changes to data elements that result in a change in EFC must be verified by requesting additional documentation and placing a hold on the financial aid disbursement until resolved.
Updating marital status
A student’s dependency status may be updated based on a change in the student’s marital status if it is determined the updates is necessary to address an inequity or to reflect more accurately the student’s ability to pay. The deadline to appeal for consideration of change in dependency status due to change in marital status is July 31st, 2014.
The Financial Aid Supervisor may make exceptions to the above guidelines for unusual/extenuating circumstance of the student and/or parent. All verification requirements must be met before applying professional judgment. Professional judgment cannot be used to waive general student eligibility requirements or to circumvent the intent of the law or regulations.