Information for Financial Aid Administrators: 2019-20 Verification Requirements

Melissa Maichle California, Community Colleges, Compliance, Federal Student Aid Programs, File Review and Verification, Financial Aid Industry News, FL, General Issues in Financial Aid, MA, NY, PA


The Federal Register notice released on March 28th, 2018, begins to outline the 2019-20 verification guidelines for higher education financial aid administrators with very few surprises or changes.  Prior-prior income is here to stay and will be requested from the 2017 tax year.  The same verification tracking groups are still in place and the required data element review will not change from the 2018-19 award year, which many schools are beginning to collect on now and process. The IRS Data Retrieval, barring any setbacks until the award year begins, can also be utilized once again by families when filling out the FAFSA, so they will not be required to hand in a tax return to the school if selected.

Be on the lookout for a Dear Colleague Letter (DCL) in the near future outlining in detail the verification requirements for 2019-20.  Since we know that there will be no changes from one year to the next, we wanted to review some of the important current guidelines from the 2018-19 DCL.

Verification Guidelines for College and University Financial Aid Administrators


Dependent Students Who Are Non-tax Filers

A dependent student who is a non-tax filer is excluded from the verification requirement to provide confirmation of the dependent student’s non-filing status from the IRS or other relevant tax authority.

Unexpired Valid Government-issued Photo Identification

One of the requirements for applicants placed in Verification Tracking Groups V4 or V5 is to verify their identity by providing the institution with an unexpired valid government-issued photo identification. For this purpose, an unexpired valid government-issued photo identification is one that is issued by the U.S. government, any of the 50 States, the District of Columbia, the Commonwealth of Puerto Rico, a federally recognized American Indian and Alaska Native Tribe, American Samoa, Guam, the Virgin Islands, the Commonwealth of the Northern Mariana Islands, the Republic of the Marshall Islands, the Federated States of Micronesia, or the Republic of Palau

Verification Requirements for Individuals Who Are Eligible for an Auto Zero Expected Family Contribution (EFC)

For Auto Zero EFC-eligible applicants placed in Verification Tracking Group V1 or V5, the FAFSA information that must be verified varies slightly between dependent and independent students. Only the following FAFSA/ISIR information must be verified:

For dependent students—

  • The parents’ adjusted gross income (AGI) if the parents were tax filers;
  • The parents’ income earned from work if the parents were nontax filers; and
  • The student’s high school completion status and identity/statement of educational purpose, if placed in Verification Tracking Group V5.

For independent students—

  • The student’s and spouse’s AGI if they were tax filers;
  • The student’s and spouse’s income earned from work if they were nontax filers;
  • The student’s high school completion status and identity/statement of educational purpose, if placed in Verification Tracking Group V5; and
  • The number of household members to determine if the independent student has one or more dependents other than a spouse.

Contact HEAG

HEAG’s financial aid consultants are available to assist your financial aid office with the application, awarding and verification process. Our team of financial aid consultants can step in and quickly make a huge difference in the financial aid processing work load. HEAG’s consultants have spent decades in the higher education financial aid field. Our consultants are compliance experts and approach every assignment with an eye on helpings schools remain in compliance with complex regulations. Please contact us if you need on-site or remote assistance.