Guidance on the 2021-22 Verification Process for ISAC Programs
This message provides guidance regarding verification requirements for ISAC programs following the U.S. Department of Education's’s (ED) July 13th announcement that changes were made to the verification process for the 2021-22 award year to provide relief to students challenged by the pandemic and reduce barriers to enrollment.
According to ED's DCL GEN-21-05, effective July 13, 2021 and for the remainder of the 2021-22 FAFSA processing and verification cycle, ED is waiving verification requirements for most Free Application for Federal Student Aid (FAFSA®) information, except for the identity/statement of educational purpose and high school completion status under verification tracking groups V4 and V5. Institutions may apply the waiver to any applicant selected for verification for whom verification is not yet completed or has not been started. However, the waiver does not exempt institutions from reviewing all documents for conflicting information concerning a student's eligibility, nor does it exempt institutions from resolving student eligibility-related C-codes.
Consistent with ED's action, and effective July 13, 2021, ISAC is not requiring colleges to complete federal verification for students receiving ISAC program benefits for the 2021-22 award year, and advises schools to follow ED guidance in regard to when verification must be completed. However, colleges are still required to confirm Illinois residency for all students receiving ISAC program benefits for which Illinois residency is a requirement.
As a reminder, ISAC rules explain the two components to verification for ISAC programs – one confirms state residency and the other relates to verifying financial need and student eligibility.
From ISAC's General Provisions, Section 2700.50, Determining Applicant Eligibility:
- a) The evaluation of applicant eligibility is the responsibility of both ISAC and the institution.
- e) The institution is required to verify the residency of all applicants to ISAC gift assistance programs for which Illinois residency is a requirement.
- f) For all other eligibility criteria, if the institution has any information that indicates that the applicant does not meet the eligibility requirements of ISAC-administered programs or if an applicant is selected for verification in conjunction with federal student assistance, that applicant shall be verified for ISAC-administered programs. A selected applicant must be verified for ISAC programs even if the applicant is ineligible for federal student assistance.
While it is the college's responsibility to ensure that all ISAC program recipients meet the residency requirement, this does not necessarily mean that additional documentation must be collected from every student, and colleges are encouraged to minimize the burden of requesting additional documentation whenever possible. Colleges can rely on the address information in GAP Access to confirm Illinois residency. Address data in GAP Access is provided by an applicant in online ISAC applications and is certified by the student signature. This is considered sufficient as long as there is no known conflicting information. Keep in mind, however, that in all cases, if the financial aid office is aware of or has conflicting information which suggests that a student applicant and/or a dependent student's parent(s) may not be meeting ISAC residency requirements, the financial aid office would want to request additional documentation to confirm residency status.
Guidance for verifying Illinois residency, including examples of situations in which verification is not necessary, is contained in the Illinois Residency and Verification FAQ. A list of acceptable documentation is also available on the site.
In summary, in regard to ISAC programs and the verification process for 2021-22, colleges administering ISAC programs:
- Are not expected to complete the verification process for students who have been selected by ED, with the same exceptions outlined by ED – those for whom you must confirm identity/statement of educational purpose and high school completion status under verification tracking groups V4 and V5;
- Are expected to confirm Illinois residency for ISAC programs that require it;
- Are expected to review documents when there is conflicting information concerning a student's eligibility and resolve student eligibility-related C-codes;
- May continue to accept expired government-issued documentation to confirm Illinois residency until further notice.
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