In a significant step toward increasing accessibility and simplifying the FAFSA® process for applicants and contributors without a Social Security Number (SSN), the U.S. Department of Education (ED) announced a series of updates and changes to the application process. Earlier in December, ED released an Electronic Announcement further outlining their guidance by expanding the flexibilities provided through to the 2025-2026 FAFSA cycle. Here are the key takeaways from that announcement and their implications for institutions, as financial aid representatives.
Background: Changes for Non-SSN Contributors
In April 2024, the ED introduced new systems that allow applicants and contributors without SSNs to access the 2024-25 FAFSA form immediately while still undergoing a manual identity validation process. However, due to system development challenges, contributors with Individual Taxpayer Identification Numbers (ITINs) could not use the FUTURE Act Direct Data Exchange (FA-DDX) to transfer tax information automatically from the IRS. Identity validation and consent became mandatory for contributors starting with the 2024-25 FAFSA cycle.
To address delays and confusion associated with the manual identity validation process, the ED extended these flexibilities for the 2025-26 FAFSA cycle. This extension ensures that applicants and contributors without SSNs can proceed without jeopardizing a student’s eligibility for federal student aid.
New Updates
The ED has announced several enhancements to improve the identity validation process for contributors without SSNs:
- Manual Validation Paused
- The email address used for manual identity verification (IDVerification@ed.gov) has been disabled. Individuals will now receive an on-screen confirmation allowing them to proceed directly to the FAFSA form without additional steps.
- Automated emails containing case numbers and manual validation instructions will no longer be sent. Instead, individuals will receive an automated message indicating the closure of the email inbox.
- Enhanced Online Attestation
- Starting with the 2025-26 FAFSA cycle, contributors without SSNs will need to complete a separate paper attestation form certifying they do not have an SSN. This certification has now been embedded into the online StudentAid.gov account creation process for ease and accuracy.
- Expanded Document Options for Proof of Identity
- The list of acceptable documents for manual identity validation has been expanded from fewer than 10 options to over 30. This change aims to reduce barriers for individuals by providing a broader range of valid documents.
- Secure System Development
- The ED is developing a secure system for collecting and reviewing identity documents. This system, expected to launch with the 2026-27 FAFSA cycle, will minimize reliance on manual reviews and improve processing times.
What This Means for Institutions
Institutions must remain vigilant in verifying the eligibility and identity of students and contributors who lack an SSN. Key points to note include:
- Eligibility Verification
- Schools must verify the citizenship or eligible noncitizen status of students without SSNs before disbursing aid.
- Refer to the 2024-25 FSA Handbook, Volume 1: Student Eligibility, Chapter 2 for detailed guidance.
- Addressing Conflicting Information
- Institutions are required to resolve conflicting information, such as discrepancies in SSN status, before disbursing aid.
- Fraud Mitigation
- Institutions should be alert to potential fraud. Cases involving false financial information or incorrect SSN claims may be referred to federal agencies for action.
- Program Reviews
- During program reviews, the ED may request documentation for students or contributors without SSNs to ensure compliance with eligibility criteria and income accuracy.
Practical Steps for Institutions:
When assisting students and families directly, financial aid administrators should know that a number of supports are now available to assist families with contributors who lack an SSN. These include:
- Support for Students and Families
- Direct students and families with non-SSN contributors to the FAFSA Help Center for assistance.
- Provide guidance on verifying eligible noncitizen status and clarify that parental or spousal citizenship status does not impact a student’s aid eligibility.
- Documentation Practices
- Ensure staff are familiar with the expanded list of acceptable identity documents, including those for manual validation once the secure system is in place.
- Income Verification
- As contributors without SSNs cannot use the FA-DDX, they are more likely to be selected for institutional income verification. Review processes to handle these cases efficiently.
Expanded List of Acceptable Documents
The ED has significantly broadened the range of documents accepted for identity verification. Individuals may submit one document from Group A or two documents from Group B. These include:
Group A
- Driver’s license, temporary license, or ID issued by a U.S. State or Territory (paper documents NOT accepted)
- U.S. passport or passport card
- Foreign passport or passport card
- Consular ID Card/Matricula Consular
- U.S. Border Crossing Card
- U.S. Military ID Card (front and back) or U.S. Military’s dependent ID card
- Native American Tribal ID
- Permanent Resident Card (form I-551) “green card”
- Government-issued Personal Identity Verification (PIV) card
- Common Access Card (CAC)
- Transportation Worker Identification Credential (TWIC)
- U.S. Certificate of Naturalization (Form-550 or Form N-570)
- DHS/ICE Miramar Check-in Paperwork – must have a photo and seal
- U.S. Certificate of Citizenship (form N-560 or Form N-561)
- Prison ID with picture, name, and date of birth
- US Citizenship and Immigration Services Employment Authorization Document (EAD) (I-766)
- US Merchant Mariner Credential
- Veteran Health Identification Card (VHIC)
- Documents reflecting TPS (Temporary Protected Status) eligibility
Group B
- Social Security Card
- Birth certificate or document issued by a foreign country or U.S. state, jurisdiction, or territory
- Foreign driver’s license
- Marriage license or divorce decree
- U.S. Individual Taxpayer Identification Number (ITIN) provided on official letter awarding the ITIN or an official renewal ITIN letter from the U.S. Internal Revenue Service (IRS)
- Municipal identification card (such as those issued by city ID program)
- Community ID
- Voter registration card
- U.S. or foreign passport or passport card that expired within the previous 2 years
- Consular ID from applicant’s country of citizenship that expired within the previous 2 years
- Credit card/debit card statement
- Mortgage statement
- Financial institution account statement
- Utility bill
- Federal or state tax return
- W-2
- Insurance documents, including medical, dental, vision, life, home, rental, or vehicle
- Rental or lease agreement with signature of landowner and tenant
- Property tax bill or statement or deed or title to residential property
- Pay stubs
- Car registration
- Foreign or U.S. school-issued or college ID card
- Employee identification card
- Union or worder center identification card
- Foreign border crossing card (example: ECOWAS is accepted)
- Foreign military ID card (front and back)
- Foreign federal electoral photo card
- Foreign national or federal government-issued ID cards (from individual’s home country)
- Other foreign federal government-issued identification documents
- U.S. Prison ID missing picture, name, or DOB can be accepted with 2nd form of ID or official document (letter or other) from prison
Looking Ahead
The ED’s efforts to streamline the FAFSA process for non-SSN contributors highlight its commitment to accessibility and efficiency. Institutions should remain proactive in adapting to these changes, ensuring compliance while supporting students and their families. As further updates are rolled out, stay informed and adjust institutional practices accordingly to meet federal requirements. For questions or guidance regarding these changes, please reach out to our compliance experts at info@heag.us. Institutions are also encouraged to contact the FSA Partner Connect Help Center. By staying updated on these developments, financial aid professionals can continue to provide equitable and effective support to all students navigating the FAFSA process, regardless of their contributor’s SSN status.