FAFSA® Simplification and the FUTURE Act: How These Will Change Verification for 2024-25

Melissa Maichle .

The Only Constant in Life Is Change. — Heraclitus

The only constant in Financial Aid is change too! Just as we’re getting back to our familiar verification rules thanks to the sunsetting of COVID waivers and flexibilities, change is on the horizon. Both the FAFSA® Simplification and the Fostering Undergraduate Talent by Unlocking Resources for Education (FUTURE) Acts contain changes to verification requirements for the 2024-2025 award year.

The Federal Register 88 FR 64421 notice published on Sept. 19, 2023, contains all verification requirements for 2024-2025. DCL GEN-23-12 issued the same day contains supplemental information highlighting the changes from previous award years.

You may recall from our June blog that the way families will provide income and tax information is changing. FAFSA® filers will be required to authorize the transfer of IRS data to the Department of Education (ED) to be shared with higher education institutions and other agencies providing financial assistance. As such, any income or tax information tagged as coming directly from the IRS is considered verified. However, there are certain situations when the filer will need to manually provide this information: filers (or their parents) who are not currently married to the spouse with whom they filed a joint tax return for the base year; filers that claim a foreign income exclusion; and filers who only had earnings in and filed an income tax form in another country.

Another meaningful change is how the members of the student’s (or their parent’s) household are treated. The number in household question has been replaced with number in family and the response should correspond to the number of dependents on the filer’s or the filer’s parents’ federal tax return. Additionally, the number of household members in college is no longer a factor in the calculation of the new Student Aid Index (SAI). However, administrators may use professional judgment to change a component of the cost of attendance or a component of the SAI to recognize the higher education expenses incurred by other family members.

Lastly, financial aid administrators will no longer be able to require documentation beyond the FAFSA® before awarding and disbursing federal financial aid except under the following conditions:

  • To complete verification for students selected by the FPS (formerly CPS)
  • To complete a professional judgment review
  • To determine an applicant’s independence

Previously, administrators were required to resolve any instance of conflicting data before disbursing funds and that typically requires collecting additional documentation. It is not clear yet whether this requirement remains and should be done independent of the disbursement process, so stay tuned for clarification from Federal Student Aid (FSA).

One thing that will remain the same is treatment of incarcerated or confined applicants. For the current award year, these students are only required to verify identity and complete the Statement of Educational purpose when selected as part of tracking groups V4 or V5. If selected as part of V1, verification is not required.

The DCL’s Appendix A contains suggested language for the internal forms used for verification, including instructions for obtaining a tax transcript. Included is language for:

  • Student and parent tax filers
  • Student and parent non-filers
  • Individuals granted extensions beyond six months
  • Victims of IRS related identity fraud
  • Family size verification for dependent and independent students
  • Identity and Statement of Educational Purpose (English and Spanish with sample notary statement when applicable)
  • Certification and signatures for dependent and independent students

Stay up-to-date with all the changes for the 2024-2025 award year by visiting the FSA FAFSA® Simplification Resource page and follow the Higher Education Assistance Group Blog for additional support and information. If you need additional support or training, contact us at info@heag.us.