Common use of Justification and Expected Results Clause in Contracts

Justification and Expected Results. ED and DHS-USCIS have determined that a computer matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to verify the immigration status of applicants for the Title IV Student Financial Assistance Programs. The alternative to using a computer matching program for verifying immigration status would be for each school to submit a verification request through SAVE to verify each student attending the school who identified themselves as an “Eligible noncitizen” on their Free Application for Federal Student Aid (FAFSA). This would impose a greater administrative burden and delayed response times. Using the computer matching program, SAVE can usually provide responses within seconds of when ED inquiries. Applicants who require second-step additional verification are provided a response in as little as 72 hours from ED’s second-step additional verification request. ED expects that this computer matching program will enable it to quickly and efficiently verify the status of applicants for the purpose of determining their eligibility for Title IV Student Financial Assistance Programs. The matching program will also quickly identify those applicants who require third level verification before the institution of higher education can independently determine whether the applicant meets the eligibility requirements of the Title IV Student Financial Assistance Programs. ED estimates that this computer matching program costs $1,885,741 per 21-month processing period to operate. Given an estimated processing time of 15 minutes per applicant, an average cost per record to process a DHS verification of $7.58 per application, and approximately 690,193 applicants, verification of immigration status in the absence of computer matching (i.e., each school completing their students’ verifications) would cost institutions approximately $5,231,663 per processing year. Computer matching reduces the number of applicants requiring manual verification by approximately 96.7% since the administrative cost to institutions is reduced from $5,231,663 to $172,892 for a total savings of $5,058,771for the processing year. (Attached is a detailed cost/benefit analysis). In addition to the savings in administrative costs, the computer matching program provides identification of categories of immigration statuses allowing ED to deny eligibility to non-citizens who are not Title IV eligible under the law (and who, without the match, might receive aid). The notice to applicants informing them that their application information is subject to computer matching is expected to have a deterrent effect on applicants seeking to fraudulently receive assistance under the Title IV Student Financial Assistance Programs.

Justification and Expected Results. ED and DHS-USCIS have determined that a computer matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to verify the immigration status of applicants for the Title IV Student Financial Assistance Programs. The principal alternative to using a computer matching program for verifying immigration status would be to institute a mail-in procedure using Form G-845 for each school to submit a verification request through SAVE to verify each student attending the school who identified themselves as an “Eligible noncitizen” on their Free Application for Federal Student Aid (FAFSA). This all eligible noncitizen verifications, which would impose a greater administrative burden and delayed delay response times. Using the computer matching program, SAVE responses can usually provide responses be provided within seconds 24 hours of when ED inquiries. Applicants who require second-step automated additional verification are provided a response in as little as 72 hours from ED’s second-step additional verification request. ED expects that this computer matching program will enable it to quickly and efficiently verify the status of applicants for the purpose of determining their eligibility for Title IV Student Financial Assistance Programs. The matching program will also quickly identify those applicants who require third level manual additional verification before the institution of higher education can independently determine whether the applicant meets the eligibility requirements of the Title IV Student Financial Assistance Programs. ED estimates that this computer matching program costs $1,885,741 487,386 per 2118-month processing award period to operate. Given an estimated processing time of 15 minutes per applicant, and an average cost per record to process a DHS verification of $7.58 6.80 per application, and approximately 690,193 applicants967,036 applicants per 18-month award period, verification of immigration status in the absence of computer matching (i.e., each school completing their students’ verificationsusing mail-in procedures) would cost institutions approximately $5,231,663 6,575,845 per processing year. Computer Because computer matching reduces the number of applicants requiring manual verification by approximately 96.7% since the 95.85%, this administrative cost to institutions is reduced from $5,231,663 6,575,845 to $172,892 272,646 for a total savings of $5,058,771for the processing year6,303,199. (Attached is a detailed cost/benefit analysis). In addition to the savings in administrative costs, the computer matching program provides identification of categories of immigration statuses allowing ED to deny eligibility to non-citizens who are not Title IV eligible under the law (and who, without the match, might receive aid). The notice to applicants informing them that their application information is subject to computer matching is expected to have a deterrent effect on applicants seeking to fraudulently receive assistance under the Title IV Student Financial Assistance Programs.

Justification and Expected Results. ED has determined and DHS-USCIS have determined agrees that an electronic verification process (identified by ED as a computer matching program program) is the most efficient, expeditious, and effective means of obtaining and processing the information needed by that ED needs to verify the immigration status of applicants for the Title IV Student Financial Assistance Programs. The alternative to using a computer matching program for verifying immigration status would be for each school to submit a verification request through SAVE to verify each student attending the school who identified themselves as an “Eligible eligible noncitizen” on their Free Application for Federal Student Aid (FAFSA). This would impose a greater administrative burden and delayed response times. Using the computer matching program, SAVE can usually provide responses within seconds of when ED inquiriesinquires. Applicants who require second-step additional verification are provided a response in as little as 72 hours from ED’s second-step additional verification request. ED expects that this computer matching program will enable it to quickly and efficiently verify the status of applicants for the purpose of determining their eligibility for Title IV Student Financial Assistance Programs. The matching program will also quickly identify those applicants who require third level verification before the institution of higher education IHE can independently determine whether the applicant meets the eligibility requirements of the Title IV Student Financial Assistance Programs. ED estimates that this computer matching program costs $1,885,741 2,760,112 per 2124-month processing period year to operate. Given an estimated processing time of 15 minutes per applicant, an average cost per record to process a DHS SAVE verification of $7.58 8.16 per application, and approximately 690,193 678,244 applicants, verification of immigration status in the absence of computer this matching (i.e., each school completing their students’ verifications) program would cost institutions approximately $5,231,663 5,534,471 per processing year. Computer matching Because electronic verification reduces the number of applicants requiring manual verification by approximately 96.7% since the 95.4%, this administrative cost to institutions is reduced from $5,231,663 5,534,471 to $172,892 254,429 for a total savings of $5,058,771for 5,280,042 for the processing year. Together with the savings to the government as a result of the matching program ($286,485,908), ED estimates the cost benefit ratio is 0.0095. (Attached is a detailed cost/benefit analysis). In addition to the savings in administrative costs, the computer matching program provides assistance with identification of categories of immigration statuses allowing ED to deny eligibility to non-citizens noncitizens who are not Title IV eligible under the law (and who, without the match, might receive aid). The notice to applicants informing them that their application information is subject to computer verification through this matching program is expected to have a deterrent effect on applicants seeking to fraudulently receive assistance under the Title IV Student Financial Assistance Programs.

Justification and Expected Results. ED and DHS-USCIS have determined that a computer matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to verify the immigration status of applicants for the Title IV Student Financial Assistance Programs. The principal alternative to using a computer matching program for verifying immigration status would be to institute a mail-in procedure using Form G-845 for each school to submit a verification request through SAVE to verify each student attending the school who identified themselves as an “Eligible noncitizen” on their Free Application for Federal Student Aid (FAFSA). This all eligible noncitizen verifications, which would impose a greater administrative burden and delayed delay response times. Using the computer matching program, SAVE responses can usually provide responses be provided within seconds 24 hours of when ED inquiries. Applicants who require second-automated second step additional verification are provided a response in as little as 72 hours from ED’s second-second step additional verification request. ED expects that this computer matching program will enable it to quickly and efficiently verify the status of applicants for the purpose of determining their eligibility for Title IV Student Financial Assistance Programs. The matching program will also quickly identify those applicants who require third level step verification before the institution of higher education can independently determine whether the applicant meets the eligibility requirements of the Title IV Student Financial Assistance Programs. ED estimates that this computer matching program costs $1,885,741 987,592 per 2118-month processing award period to operate. Given an estimated processing time of 15 minutes per applicant, and an average cost per record to process a DHS verification of $7.58 6.87 per application, and approximately 690,193 applicants887,357 applicants per 18-month award period, verification of immigration status in the absence of computer matching (i.e., each school completing their students’ verificationsusing mail-in procedures) would cost institutions approximately $5,231,663 6,096,143 per processing year. Computer Because computer matching reduces the number of applicants requiring manual verification by approximately 96.7% since the 95.85%, this administrative cost to institutions is reduced from $5,231,663 6,096,143 to $172,892 360,469 for a total savings of $5,058,771for the processing year5,735,674. (Attached is a detailed cost/benefit analysis). In addition to the savings in administrative costs, the computer matching program provides identification of categories of immigration statuses allowing ED to deny eligibility to non-citizens who are not Title IV eligible under the law (and who, without the match, might receive aid). The notice to applicants informing them that their application information is subject to computer matching is expected to have a deterrent effect on applicants seeking to fraudulently receive assistance under the Title IV Student Financial Assistance Programs.

Justification and Expected Results. ED and DHS-USCIS have determined that a computer matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to verify the immigration status of applicants for the Title IV Student Financial Assistance Programs. The alternative to using a computer matching program for verifying immigration status would be for each school to submit a verification request through SAVE to verify each student attending the school who identified themselves as an “Eligible noncitizen” on their Free Application for Federal Student Aid (FAFSA). This would impose a greater administrative burden and delayed response times. Using the computer matching program, SAVE responses can usually provide responses be provided within seconds 24 hours of when ED inquiries. Applicants who require second-step additional automated second level verification are provided a response in as little as 72 hours from ED’s second-step additional second level verification request. ED expects that this computer matching program will enable it to quickly and efficiently verify the status of applicants for the purpose of determining their eligibility for Title IV Student Financial Assistance Programs. The matching program will also quickly identify those applicants who require third level verification before the institution of higher education can independently determine whether the applicant meets the eligibility requirements of the Title IV Student Financial Assistance Programs. ED estimates that this computer matching program costs $1,885,741 771,813 per 21-month processing period year to operate. Given an estimated processing time of 15 minutes per applicant, an average cost per record to process a DHS verification of $7.58 7.41 per application, and approximately 690,193 751,158 applicants, verification of immigration status in the absence of computer matching (i.e., each school completing their students’ verifications) would cost institutions approximately $5,231,663 5,566,081 per processing year. Computer Because computer matching reduces the number of applicants requiring manual verification by approximately 96.7% since the 95.85%, this administrative cost to institutions is reduced from $5,231,663 5,566,081 to $172,892 197,817 for a total savings of $5,058,771for 5,368,264 for the processing year. (Attached is a detailed cost/benefit analysis). In addition to the savings in administrative costs, the computer matching program provides identification of categories of immigration statuses allowing ED to deny eligibility to non-citizens who are not Title IV eligible under the law (and who, without the match, might receive aid). The notice to applicants informing them that their application information is subject to computer matching is expected to have a deterrent effect on applicants seeking to fraudulently receive assistance under the Title IV Student Financial Assistance Programs.