Verification Policy and Procedures

Verification procedures are governed by the Higher Education Act of 1965, as amended, and subpart E of 34 CFR part 668. The following is a description of Buena Vista University’s procedures based on our interpretation of the regulations.

As indicated in the regulations, verification procedures apply to applicants for the following programs offered at BV:

• The Federal Pell Grant Program
• The Federal Stafford (Direct) Loan Program
• The Campus-Based Programs

Verification is not required for:

• The Federal Unsubsidized Stafford  (Direct) Loan Program
• Iraq and Afghanistan Service Grant
• TEACH Grant
• The Federal PLUS Loan program
• The Robert C. Byrd Program
• The National Science Scholars Program (if ever funded)

All students who request to be considered for funds from any of the programs listed in the first category above are required to complete a federally approved needs analysis application (FAFSA).

It will be BVU’s policy to verify all applications selected through the central processor and flagged on the ISIR/SAR, regardless of the percentage of the federal student aid applicant pool that might represent. Also, since we require all applications from students requesting Title IV or state funds to go through the central processor, we would have no applications processed without a review of the data.

BVU will send all selected student applicants a link to the specific verification forms needed and a request for tax documents/IRS DR, along with a copy of the documentation receipt policy. If a tax return will not be filed, earned income will be reported and verified on the appropriate verification worksheet.  We will require verification materials from ALL selected students, even if the student’s application was previously verified at another institution or if the student has only accepted unsubsidized aid. Returning and OSG students will normally not receive an award letter from BVU until the verification process is completed and all discrepancies are resolved. If discretion is used (as with all new students) and an award is sent, it will indicate that the offer is estimated. A new award notification will be sent if verification results in a different award, with an indication of the reason for the revision.

We may select applications other than those selected through the central processor to be verified. These applicants will be required to submit all requested verification materials. In other cases, we may only need answers to certain questions, so we may select only those pieces of documentation needed to rectify the discrepancy or conflicting information.

In addition, regardless of verification status (selected or not), all conflicting information will be resolved before federal funds are disbursed, unless the student applicant dies during the award year. Conflicting information could include, but is not limited to, cases where:

• Student and/or parent/spouse reported non-filing status but income is above the minimum required to file
• Married student/parent filed separate tax returns, both claiming “Head of Household”
• Student and parent both claimed student as an exemption

If conflicting information is discovered after federal aid is disbursed, the student must repay aid received in excess of eligibility unless the student is no longer enrolled, in which case, over payment regulations would need to be followed. In some cases, the over payment can be resolved through adjustments in a subsequent semester in the same award year.

The following are examples of cases where selected applicants will be exempt from verification:

• Death of student (no further aid disbursements will be made nor will loan applications be processed)
• Incarceration if the student is in jail or prison at the time verification is being performed
• Immigration status if the student is an immigrant who arrived in the US during either of the years in the current award year
• parent/spouse information and/or signatures if:
• parent/spouse is deceased
• parent/spouse is mentally or physically incapacitated
• the parent/spouse is residing in another country and cannot be contacted by normal means of communication
• parent/spouse cannot be located

It should be noted that documentation of any of the above should be noted in file. These exclusions do not affect any other aspect of required verification. If only one parent meets any of the above, the other parent is still subject to all verification requirements.

• students with Pacific Island Residency status
• Applications that result in no federal funds being awarded; including:
  • students ineligible for federal or state funds
  • students who withdraw without receiving federal funds
• students, who for any other reason, do not receive aid

Additional Comments

The amount of college work-study the student earned in the calendar year in question should be reported in exclusion area on FAFSA. For those students employed by BVU, we will have knowledge of amounts earned and this information will be verified using internal sources, if an amount is provided on FAFSA and is selected for verification. If the student was employed at another institution (CWS) the prior year, he/she must complete the correct question on the FAFSA indicating the CWS amount (exclusion). If in question, we may request a copy of all W-2 forms.  We will not automatically correct this exclusion item as we are not always sure that a student has included work study earned in their AGI.  We will correct when we have knowledge that the amount should be included as an exception.

All applicable W-2s will be requested in death, separation, or divorce situations. It should be noted that if divorce, separation, or death occurs after the original application filed, a Special Condition Form should be completed to correct only remaining/supporting parent/student income and asset information. If the situation occurred prior to FAFSA filing, information reported should reflect only relevant information.

If using a tax return to separate out income (in divorce, separation, death situations), any personal income and 50% of income on the tax return coming from joint ventures will be used to determine total income. Any adjustments to income that apply to applicant/parent will be acknowledged in reducing AGI. The proportional distribution method or tax calculation tool in the CPS software will be used to determine representative tax.

Spouse/stepparent tax documents are needed if the student/parent is married/remarried at the time of original application if a joint return was not filed. Two natural parent documents may be needed in cases where the parents file separate returns. The same is true for an independent student/spouse who may file separate returns. No aid will be credited to a student’s account until all necessary documentation is received.

Submission Deadlines

Federal aid recipients must submit required/requested documentation no later than 120 days after the last day of enrollment or the last day allowed by law, whichever is earlier.  However, earlier deadlines may apply to specific aid programs, as detailed below.  If student identity or high school completion documentation is requested, it must be submitted within 60 days following the first request made to the student.  Late disbursement rules will be followed when necessary.

If the deadline is met and changes in the information reported are needed, we will send those changes to the Department of Education and the student will receive a revised Student Aid Report (SAR) which will reflect the changes made.  If eligibility for aid should change, a revised award will be sent.  For a student whose application is being verified, if we receive a corrected valid SAR/ISIR after the last day of enrollment, BVU must award and pay Pell Grant on the higher EFC calculated.

A student will not be allowed to begin employment in the federal work study program until requested documents are received nor will credit be given for any aid.  For Federal Direct Loan or Federal PLUS consideration, verification requirements must be met before we can disburse loan funds and the loan must be certified on or before the last day of attendance.

If a student’s application is selected after federal aid has been disbursed and while still enrolled, the student is entitled to keep any work study payments made (but the student will be asked to cease working until requested materials are received) and any Direct Loan funds disbursed.  All other federal and state aid will be removed from the student’s account until the verification process is completed.

For funds from the State of Iowa, verification requirements must be met before final payment rosters are due.  Please contact us if you question a date.

A student will forfeit eligibility for federal and state aid if the verification process isn’t completed by these deadlines.

Verification Process and R2T4

Unless a student subject to verification has provided all of the required documents in time for the R2T4 calculation, the school included as “Aid Disbursed” or “Aid that Could Have Been Disbursed” only those Title IV funds not subject to verification.

If a student provides all docu­ments required for verification after withdrawing but before the verifica­tion submission deadline, and in time for the institution to meet the 30-day Return deadline, the institution performs the Return calculation including all Title IV aid for which the student has established eligibility as a result of verification and for which the conditions of a late disburse­ment had been met prior to the student’s loss of eligibility due to with­drawal.

If, before the verification deadline but after the institution has com­pleted the Return calculation, a student provides all the documentation required for verification, the institution must perform a new Return calculation including as Aid that could have been disbursed all Federal Student Aid for which the student has established eligibility based upon verification and for which the conditions of a late disbursement have been met prior to the student’s loss of eligibility due to withdrawal.

Updating and Correcting

All information a student supplies on a needs analysis form should be accurate as of the day it was completed. There are only three situations where the information reported should be changed (other than when a correction is made):

1. Dependency status should be changed any time during the school year, with the exception of changes due to student’s marriage. (However, once a Direct Loan is certified/originated, the application cannot be changed to reflect a change in dependency status.)
2. Household size should be updated to be correct at the time of verification (if selected) or SAR submission (not selected). Since most students no longer submit a SAR, we will assume that families have made any necessary corrections at the time of receipt of the ISIR/SAR. We will allow families to correct errors made, but we will not allow an update; in limited cases, a previously non-selected application may be selected to allow for an update.
3. Number in college should be updated to be correct at the time of verification (if selected) or SAR submission (not selected-see above).

If, through verification, errors are detected, the information will be recalculated using the CPS software. We will submit all corrections to the CPS and we will require a new ISIR. Also, corrections to resolve any inconsistent data match item will be submitted to the CPS.

Referring Suspected Cases of Fraud

If it is suspected that information has not been reported correctly or if we suspect that altered documents have been received, to fraudulently obtain funds, our suspicions will be reported to the Office of Inspector General.