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Ask a Fed – Verification, Early FAFSA, TPD, and More

May 2, 2016

Federal Training Officer David Bartnicki recently provided these updates. bartnicki


On April 1, we published a federal register notice and on April 5, we published GEN-16-07 which discusses changes and updates to the verification process for the 2017-2018 award year.

In the April 1 federal register we specifically indicate that the DD-214 Form can be used as an alternative source to indicate a person has completed high school as long as the form clearly shows that they have graduated high school.

In addition, the federal register also indicates that for 17-18, applicants selected for verification that are tax filers but filed an extension or applicants selected for verification that are non-tax filers (parents, student, etc.) MUST provide verification of non-filing from the IRS or other taxing authority on or after Oct. 1, 2016, regardless if they have earned income from work. Please note that if a person has never filed a tax return before, they can get a letter of non-filing from the IRS if they use the 4506-T document process (box 7).

In addition, GEN-16-07 outlines that for 17/18 the V6 Verification Tracking Group has been removed and that the individual verification items of SNAP benefits and child support paid have also been removed from all verification tracking groups. GEN-16-07 also points out what income items won’t have to be verified again in 17/18 if previously verified in 16/17 due to the use of the same 2015 tax year information. Please note, however, that some items, like household size and number in college, will have to be updated each year.

Also, ED posted the 16-17 Tax Return Transcript matrix on March 23. We have recently found a couple of issues with the transcript income taxes paid line items and will be updating the matrix shortly. Stay tuned to IFAP.

In addition, schools continue to have questions about what lines items to use on the transcripts when the same line item is repeated several times. As noted in the new matrix and in previous guidance, do not use the lines with the words “recomputed” or “verified.” Most of the time the line item you will use will be the “per computer” line if presented.

Prior-Prior Year

ED  posted an electronic announcement on April 12 indicating that we have now posted several Q&As (and will continue to update) to the early FAFSA website on IFAP – One key Q&A I wanted to share revolves around concerns with conflicting information.

G-Q8: Will institutions have to review all of their students 2016-17 and 2017-2018 ISIRs to determine if there might be conflicting information because the two FAFSAs (2016-2017 and 2017-2018) are supposed to be completed using the same 2015 income and tax information?

G-A8: No. To reduce burden on both institutions and FAFSA applicants, the Department has developed a process where the Central Processing System (CPS) will, when processing an applicant’s 2017-2018 FAFSA, perform an automatic review when there is also a 2016-2017 FAFSA on file for the applicant. This review will determine if there might be conflicting information between the two FAFSAs. The CPS will flag for institutional resolution only those 2017-2018 ISIRs where any potential conflict, once resolved, would have a significant impact on the student’s 2017-2018 EFC. A Dear Colleague Letter is being prepared for release later this spring that will provide additional information on this subject.

Also, as we stated in “Early FAFSA Electronic Announcement #2”, posted to IFAP on February 18, 2016, the most effective ways to prevent conflicting information from occurring is for the FAFSA applicant to use the IRS Data Retrieval Tool (IRS DRT) when completing both their 2016-2017 and 2017-2018 FAFSAs. [April 12, 2016]

Another common question I get is:

G-Q2: Will the Pell Grant award and disbursement schedules be released earlier since the FAFSA will be available earlier?

G-A2: Probably not. Development and release of the Pell Grant schedules are dependent on Congressional action which likely will not occur earlier than what has occurred over the past several years. [April 12, 2016]

Please review all of the Q&As for up-to-date information regarding the early FAFSA process and prior-prior year issues.

Total and Permanent Loan Discharges

On April 12, we posted an electronic announcement announcing a new process to identify and assist disabled federal student loan borrowers who may be eligible for Total and Permanent Disability loan discharge. The process will greatly simplify the steps needed to obtain a TPD discharge by directly leveraging Social Security Administration data to document a borrower’s eligibility. Because of this new process you may see an increase in the number of your borrowers moving through the TPD process.

For more information on this process and how schools and loan holders might be impacted, please see the 4/12/16 EA –

Removal of the ED Clock Hour Definition for Title IV Programs

Under the October 30, 2015 program integrity final federal register, the Department will remove, effective July 1, 2016, the requirement that a school must have a clock hour program if it meets certain federal criteria (reporting clock hours to a state entity, etc.). There will no longer be a federal definition requirement for a clock hour TIV program. With this change a lot of schools have been asking how and when they can change their existing clock hour programs back to a credit hour program due to the removal of the clock hour definition. Policy has recently posted a couple of Q&As on the program integrity Q&A website under the “credit hour” topic that I have listed below –

CH-Q9. The revised regulations streamlining the clock to credit hour conversion will go into effect on July 1, 2016. For affected institutions that wish to transition back to credit hours, what if the payment period doesn’t end at the end of a term? When can an institution transition to credit hours?

CH-A9. An institution may transition to credit hours from clock hours at three different times:

  • Institutions can teach the remainder of the current program to currently enrolled students as a clock hour program;
  • New students (enrolled after July 1, 2016) may be enrolled under the new regulations;
  • An institution may choose to switch from clock hours to credit hours at the end of a payment period (as long as the payment period ends after July 1, 2016).

CH-Q10. When can an institution update its Eligibility and Certification Approval Report (ECAR) to reflect the new status of the program?

CH-A10. An institution can update its ECAR starting July 1, 2016, after the revised regulations take effect.

G5 Security Updates

On April 19, ED posted an electronic announcement reminding all schools that for those employees that access and work with G5, we will be phasing in a new Two Factor Authentication (TFA) security process starting in mid-April through the end of June 2016.

Currently, G5 users are required to enter a password when logging in to G5. The second factor will be a unique code users must enter each time they log into G5. The unique code can be retrieved by a free authenticator application that G5 users download and register to their mobile devices. Note: For G5 users who do not own a smart device, the code can be retrieved via a text message to a mobile phone or via a phone call to a landline.

IMPORTANT: The authenticator application to be used for G5 is not the same soft token/application that some users may already be using to access some Federal Student Aid systems.

For further information on the G5 TFA implementation, you may contact the G5 Hotline at 888.336.8930 or


And finally I just want to remind all of my schools of our new training endeavor being offered by FSAs’ training officers called – Regional Drive-In Workshop Series. I and other training officers will be conducting a series of five instructor-led, in-person training workshops, to be offered in April-September 2016 in each of Federal Student Aid’s regional offices as well as in Washington, DC. These interactive one-day sessions will provide information on five hot topics, including the consumer disclosure requirements, Return of Title IV Funds (R2T4) calculations for clock-hours, for credit hours, and for modules, as well as changes to the verification requirements. We will present one specific workshop topic in the morning, to be followed by a federal update in the afternoon. The one-day workshops will begin at 9:30 A.M. and conclude by 3:00 P.M.

To register for one or more training workshops, log in to with your username and password. After logging in, point your cursor to “Webinars and Workshops” on the main menu bar and select the “Regional Drive-In Workshop Series” option. Select the regional workshop city location of your choice, and follow the instructions to complete your registration. You must complete a separate registration for each workshop that you wish to attend. If you do not have a username and password for Federal Student Aid E-Training, select “Create new account” from the home page and follow the instructions to create a username and password.

Below are the remaining Atlanta Regional Office Workshops:

Workshop Date
R2T4 Clock Hour Basics 5/12/2016
R2T4 Credit Hour Basics 6/30/2016
R2T4 Term-Based Credit Hour with Modules 8/11/2016
Verification 9/1/2016

But don’t forget you may be closer to the Kansas City or Washington D.C. location. For a complete listing of locations and dates, along with registration information, please see ANN-16-03.

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