This assessment provides you with an opportunity to review procedures regarding verification. If you also completed the student eligibility file review and identified issues regarding verification, it is recommended that you complete the appropriate activities provided in this assessment. Additional links are provided to assist you in the evaluation of your Verification Process. Click on the following Verification Guide at a Glance as it will assist you in developing the components of verification.

Why start with policies and procedures?

Reviewing and developing policies and procedures is a good place to begin when evaluating your financial aid operations. It is difficult to assess your compliance on an individual student level if your policies and procedures aren’t fully developed, are inaccurate or are not being consistently followed. Completing the policies and procedures prior to any other activities will help you identify additional areas to evaluate and will assist you in making the most of your compliance efforts.

For verification we recommend that you start with the following activities from the policies and procedures Design Process Chart: Activity 1 (conflicting data section) and Activity 3. In addition, you may find it helpful to select a topic related to verification (Verification, Documentation, Conflicting Data, Professional Judgment, and Misrepresentation ) to provide you with a policy and procedure template. Use this template to either assist you in creating a new policy and procedure or to test your current policies and procedures.

If you identify areas requiring a corrective action, we recommend that you complete the Management Enhancement Worksheet.

Activity Bar:
Verification Activity 1: Verification CPS Selection Criteria File Review Worksheet
Verification Activity 2: Discretionary Verification File Review Worksheet
Verification Activity 3: Applicants For CPS Verification 30% Selection Process
Verification Activity 4: Resolving Conflicting Data
Verification Activity 5: Dependency Overrides & Professional Judgment

Additional Links: 2008-09 FSA Handbook (AVG), Chapter 4

FSA Verification Subpart E-Verification of Student Aid Application Information (668.51 through 668.61)	Activity
General 668.51
Definitions 668.52
Notification and Student Deadlines 34 CFR 668.53
Selection of Applications for Verification 34 CFR 668.54	Verification Activity 3: Applicants For CPS Verification 30% Selection Process
Resolving Conflicting Data 668.54(a)(3)	Verification Activity 4: Resolving Conflicting Data
Exclusion from Verification, (34 CFR 668.54 (b)(1)), (34 CFR 668.54(b)(2)(i), (34 CFR 668.54(b)(2)(viii), 34 CFR 668.59, (34 CFR 668.54(b)(3) and (HEA 487A)
Updating Information: 34 CFR 668.55
Items to be Verified and Acceptable Documentation: 34 CFR 668.56 and 34 CFR 668.57. Some helpful sites to assist with Verification include: www.federalreserve.gov/releases/h10/update (the preferred site for foreign income conversion to US dollars); Who should file a 1040? (Provides helpful information about the income requirements to determine if an applicant should file a 1040 - see page 12 of the document); items to be verified and acceptable documentation (provides information on what type of documentation is acceptable to verify required items); Health & Human Services Poverty Guidelines (provides the Poverty Guidelines as gathered by the U.S. Department of Health & Human Services); U.S. Census Bureau Poverty Thresholds (provides poverty thresholds as gathered by the U.S. Census Bureau). 2008-09 IRS FORMS: IRS 1040, IRS 1040A, IRS 1040EZ, IRS Form 2555 (Foreign Earned Income), IRS Form 2555EZ, IRS Form 4136 (Credit For Federal Tax Paid on Fuels) and 2006 W-2 (For Informational Purposes Only) Verification ISIR/1040 Comparison charts: 2006-07, 2007-08 and 2008-09 (English) OR 2008-09 (en Espanol)	Verification Activity 1: Verification Federal Edits File Review Worksheet Verification Activity 2: Discretionary Verification File Review Worksheet
Interim Disbursements 34 CFR 668.58
Consequences of Change in Applicant Information 668.59
Deadlines for Submitting Documentation and the Consequences of Failing to Provide Documentation, 34 CFR 668.60, 668.60(b)(1)(i), 668.58(a)(2) and 668.57
Recovery of Funds 34 CFR 668.61, 34 CFR 668.9(a)(2); DCL GEN 98-14 July 1998 and 34 CFR 668.58(a)(2)(ii)(A)
Professional Judgment and Dependency Overrides Statute: 479A(a); 480(d)(7) and DCL GEN-03-07	Verification Activity 5: Dependency Overrides & Professional Judgment
Policies and Procedures Chart