Common use of VERIFICATION PROCEDURES Clause in Contracts

VERIFICATION PROCEDURES. ED may not suspend, terminate, reduce, or make a final denial of any financial assistance or payment under Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications for Title IV, HEA Program assistance. ED will only send the records of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran status, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak months. The applicant is determined to be the best source of information on the validity of notice results. Consequently, ED’s notification process is highly automated and requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) is issued and challenged by the student. Individual applicants are required personally to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program assistance or take other adverse action against an individual as a result of the information produced by this matching program until, in pertinent part: (1) the individual receives a notice from ED containing a statement of ED’s findings and informing the individual of the opportunity to contest such findings, and (2) the subsequent expiration of the 30-day notice period. To ensure that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) provide a SAR to the student (and will issue an ISIR to the institution, which subsequently also may choose to provide notice to the student of the results of the match) and will provide the student with a minimum of 30 days after the presentation of the SAR to contest the match, and (2) not take any adverse action against an individual as a result of the information produced by this matching program until the expiration of at least 30 days from the presentation of the SAR. The SAR will instruct the student to submit additional verifying information to document his or her Veteran status to the institution. The results of this match do not preclude the applicant from receiving Title IV, HEA Program assistance. The applicant must correct his or her FAFSA information, provide parental data, or document that he or she is a Veteran as defined in the HEA. The institution will assist the applicant in making any necessary corrections to receive financial assistance at the postsecondary educational institution that he or she is attending. The applicant is the person who is best able to produce documents to verify Veteran status, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran for purposes of Title IV, HEA Program assistance after considering any additional information provided by the student.

VERIFICATION PROCEDURES. ED may not suspend, terminate, reduce, or make a final denial of any financial assistance or payment under the Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications for Title IV, HEA Program assistance. ED will only send the records of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran status, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak months. The applicant is determined to be the best source of information on the validity of notice results. Consequently, ED’s notification process is highly automated and requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) is issued and challenged by the student. Individual applicants are required personally to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program assistance Financial Assistance Programs or take other adverse action against an individual as a result of the information produced by this matching program untilprogram, in pertinent part: unless (1) ED independently verifies the individual receives a notice from ED containing a statement of information, or ED’s findings and informing 's Data Integrity Board determines, in accordance with guidance issued by the individual Director of the opportunity OMB, that: (a) the information is limited to contest such findings, identification and amount of benefits paid by ED under a Federal benefit program; and (b) there is a high degree of confidence that the information provided to ED is accurate; (2) such individual has received a notice stating the subsequent expiration results of the 30-day notice period. To ensure match and stating that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) the individual has at least 30 days to provide a SAR documentation to the student (and will issue an ISIR institution to the institution, which subsequently also may choose to provide notice to the student of contest the results of the match; and (3) and will provide the student with a minimum of 30 days after the presentation of the SAR individual expressly declined to contest the matchresults of the match or the subsequent 30-day notice period has expired. The notice will state that DHS-USCIS has not verified the applicant’s immigration status commensurate with the requirements of eligibility for Federal student aid and that the applicant must provide appropriate documentation to the institution in order to verify the applicant’s immigration status. Applicants for, and (2) or recipients of, assistance under the Title IV Student Financial Assistance Programs may not take any adverse action against an individual have their benefits suspended, terminated, reduced, denied, or otherwise adversely affected as a result of information produced by this matching program until: • The applicant is provided written notice of an initial or second-step additional verification immigration status response from SAVE and an opportunity to state any disagreement with the SAVE response, and either declines to contest the results of the match or does not state disagreement within the 30 day period provided above; or • Third-step additional verification procedures as specified by ED have been used to independently verify the information produced by this matching program until program. These third-step additional verification procedures are described as follows: • Under 34 CFR 668.33(a)(2), applicants for assistance under the expiration Title IV Student Financial Assistance Programs must document their immigration status to prove their eligibility. Under current policy guidelines, if DHS-USCIS is unable to verify the applicant’s immigration status through automated initial or second level verification, institutions may not determine that the applicant is in an eligible immigration status for purposes of at least 30 days from the presentation receiving Federal financial aid unless they independently verify this eligibility, by visual inspection and identification of the SARimmigration documents representing the applicant’s current immigration status and submission of an electronic third level verification request along with copies of the DHS-USCIS provided documentation for manual review by DHS-USCIS of an applicant’s immigration records before disbursing Title IV Student Financial Assistance. The SAR will instruct • If an institution's independent verification of immigration status described above determines a noncitizen applicant to be ineligible for the Title IV Student Financial Assistance Programs, the institution of higher education must, under 34 CFR 668.42(b)(2), make available to such applicant any information describing the student eligibility requirements that it used to submit additional verifying information to document make its determination. If the applicant disagrees with the institution's independent determination of his or her Veteran status immigration status, the institution of higher education should refer the applicant to the institution. The results of this match do not preclude DHS-USCIS website: xxxxx://xxx.xxxxx.xxx/sites/default/files/SAVE/Publications/Records-Fast-Facts- for-Benefi-Applicants.pdf, which provides the applicant from receiving Title IV, HEA Program assistance. The applicant must correct information about correcting his or her FAFSA information, provide parental data, or document immigration records so that he or she is a Veteran as defined in the HEA. The institution will assist the applicant in making any necessary corrections to receive financial assistance at the postsecondary educational institution that he or she is attending. The applicant is the person who is best able to produce documents to verify Veteran status, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to can obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran an accurate match for purposes of determining eligibility for Title IV, HEA Program assistance after considering any additional information provided by the studentIV Student Financial Assistance Programs.

VERIFICATION PROCEDURES. ED may not suspend, terminate, reduce, or make a final denial of any financial assistance or payment under the Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications for Title IV, HEA Program assistance. ED will only send the records of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran status, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak months. The applicant is determined to be the best source of information on the validity of notice results. Consequently, ED’s notification process is highly automated and requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) is issued and challenged by the student. Individual applicants are required personally to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program assistance Financial Assistance Programs or take other adverse action against an individual as a result of the information produced by this matching program untilprogram, in pertinent part: unless (1) ED independently verifies the individual receives a notice from ED containing a statement of information, or ED’s findings and informing 's Data Integrity Board determines, in accordance with guidance issued by the individual Director of the opportunity OMB, that: (a) the information is limited to contest such findings, identification and amount of benefits paid by ED under a Federal benefit program; and (b) there is a high degree of confidence that the information provided to ED is accurate; (2) such individual has received a notice stating the subsequent expiration results of the 30-day notice period. To ensure match and stating that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) the individual has at least 30 days to provide a SAR documentation to the student (and will issue an ISIR institution to the institution, which subsequently also may choose to provide notice to the student of contest the results of the match) and will provide the student with a minimum of 30 days after the presentation of the SAR to contest the match, ; and (23) the subsequent 30-day notice period has expired. The notice will state that DHS-USCIS has not take any adverse action against an individual verified the applicant’s immigration status commensurate with the requirements of eligibility for Federal student aid and that the applicant must provide appropriate documentation to the institution in order to verify the applicant’s immigration status. Applicants for, or recipients of, assistance under the Title IV Student Financial Assistance Programs may not have their benefits suspended, terminated, reduced, denied, or otherwise adversely affected as a result of the information produced by this matching program until third level procedures as specified by ED have been used to independently verify such information. These third level verification procedures are described as follows:  Under 34 CFR 668.33(a)(2), applicants for assistance under the expiration Title IV Student Financial Assistance Programs must document their immigration status to prove their eligibility. Under current policy guidelines, if DHS-USCIS is unable to verify the applicant’s immigration status through automated initial or second level verification, institutions may not determine that the applicant is in an eligible immigration status for purposes of at least 30 days from the presentation receiving Federal financial aid unless they independently verify this eligibility, by visual inspection and identification of the SARimmigration documents representing the applicant’s current immigration status and submission of an electronic third level verification request along with copies of the DHS-USCIS provided documentation for manual review by DHS-USCIS of an applicant’s immigration records before disbursing Title IV Student Financial Assistance. The SAR will instruct  If an institution's independent verification of immigration status described above determines an alien applicant to be ineligible for the Title IV Student Financial Assistance Programs, the institution of higher education must, under 34 CFR 668.42(b)(2), make available to such applicant any information describing the student eligibility requirements that it used to submit additional verifying information to document make its determination. If the applicant disagrees with the institution's independent determination of his or her Veteran status immigration status, the institution of higher education should refer the applicant to the institution. The results of this match do not preclude DHS-USCIS website: xxxxx://xxx.xxxxx.xxx/sites/default/files/SAVE/Publications/Records-Fast-Facts- for-Benefi-Applicants.pdf, which provides the applicant from receiving Title IV, HEA Program assistance. The applicant must correct information about correcting his or her FAFSA information, provide parental data, or document immigration records so that he or she is a Veteran as defined in the HEA. The institution will assist the applicant in making any necessary corrections to receive financial assistance at the postsecondary educational institution that he or she is attending. The applicant is the person who is best able to produce documents to verify Veteran status, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to can obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran an accurate match for purposes of determining eligibility for Title IV, HEA Program assistance after considering any additional information provided by the studentIV Student Financial Assistance Programs.

VERIFICATION PROCEDURES. ED may not suspendThe OMB Final Guidelines for the Privacy Act (Final Guidance Interpreting the Provisions of Public Law 100-503, terminatethe Computer Matching and Privacy Protection Act of 1988, reduce54 FR 25818, or make June 19, 1989) state that the type of verification procedures used for a final particular matching program depends upon the purpose of that program. This match will identify the Title IV, HEA applicants who are subject to denial of any financial assistance Federal benefits and will ensure that reasonable verification procedures have been developed that yield confirmatory data and provide ED with a reasonable basis for taking action. When a match is made, the individual in question already will have had a court hearing in connection with the underlying criminal conviction and sentence, and his or payment under Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications her eligibility for Title IV, HEA Program assistancebenefits will have been determined by a Federal or State judge. ED will only send Because the records individual’s denial of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA benefits sanction has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran statusalready been determined, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified verification procedures for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are focus on verifying the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the individual’s identity for Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak monthspurposes. The basic verification procedures are as follows: A. ED Issues to Applicant Section 5301 Comment of Ineligibility on SAR An individual will have at least thirty (30) calendar days from the date of the output document (the date on the applicant’s Student Aid Report (SAR) to contest a proposed adverse action before his or her eligibility for Title IV, HEA student financial assistance is denied. The individual applicant is determined to be the best source of information on the validity of notice resultsresults in which a computer match occurs pertaining to his or her application. Consequently, ED’s notification process is The highly automated and process used under the Title IV, HEA program requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) SAR is issued and challenged reviewed by the student. Individual applicants are required personally With regard to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that each individual for whom a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Actoccurs, ED may will inform him or her that ED cannot suspend, terminate, reduce, continue to process his or make her application because a final denial computer match has occurred with regard to his or her identity. ED will inform the individual of this information by providing a section 5301 comment on his or her SAR stating that ED cannot process the application for Title IV, HEA Program program assistance or take other adverse action against an individual as a result further because of issues raised by the Anti-Drug Abuse Act of 1988. Further, the applicant will be instructed to contact ED within 30 days from the date of the information produced letter at the phone number provided by this matching program until, in pertinent part: (1) the individual receives a notice from ED containing a statement of ED’s findings and informing the individual of the opportunity to contest such findings, and (2) the subsequent expiration of the 30-day notice period. To ensure that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) provide a SAR to the student (and will issue an ISIR to the institution, which subsequently also may choose to provide notice to the student of the results of the match) and will provide the student with a minimum of 30 days after the presentation of on the SAR to contest the matchadverse action. B. Applicant May Inquire Regarding Section 5301 Comment If the applicant makes an inquiry within the specified time (30 days) regarding a section 5301 comment on the applicant’s SAR, ED headquarters will obtain additional information from the DFB/DPFD database and (2) not take any adverse action against an individual as a result receive staff assistance to independently verify and confirm the accuracy of the information produced DFB/DPFD. With regard to an applicant’s inquiry based upon section 5301, ED personnel will have direct and immediate access, through Federal Student Aid’s Central Processing System (CPS), to the applicant’s FAFSA record including section 5301 file data provided by this matching program until DOJ. Consequently, when the expiration of at least 30 days from the presentation of the SAR. The SAR will instruct the student to submit additional verifying information to document applicant contacts ED with questions regarding his or her Veteran status section 5301 comment, ED personnel will be able to quickly confirm the institution. The results student’s ineligibility for one or more of this match do not preclude the applicant from receiving Title IV, HEA Program assistanceprogram(s). The A new 5301 file is retrieved from DOJ every four to six weeks, loaded into the CPS, and matched against the Title IV, HEA application file, which also contains the individual’s name and SSN. For a match to occur, the individual’s name, SSN, and date of birth must match. If the applicant must correct his or her FAFSA information, provide parental data, or document does not make an inquiry to ED within the specified time regarding a section 5301 comment that he or she receives, ED’s initial finding will be upheld as final, and Title IV, HEA program eligibility will be denied. C. ED Verifies Eligibility Should verification with DOJ, as noted in section VI. B. above, indicate that eligibility is restored, ED personnel will be able to override standard CPS system procedures to produce and forward a Veteran as defined in valid SAR. This will enable the HEA. The institution will assist the applicant in making any necessary corrections student applicant, if otherwise eligible, to receive financial assistance at the postsecondary educational institution that he or she is attending. The However, should the outcome of such verification with DOJ confirm the initial finding, the applicant is will be so notified and provided with at least 30 additional calendar days, from the person who is best able date ED provides its finding to produce documents to verify Veteran statusthe applicant, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran for purposes of Title IV, HEA Program assistance after considering any additional information provided by applicant may contest the studentinitial finding.

VERIFICATION PROCEDURES. ED may not suspend, terminate, reduce, or make a final denial of any financial assistance or payment under the Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications for Title IV, HEA Program assistance. ED will only send the records of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran status, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak months. The applicant is determined to be the best source of information on the validity of notice results. Consequently, ED’s notification process is highly automated and requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) is issued and challenged by the student. Individual applicants are required personally to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program assistance Financial Assistance Programs or take other adverse action against an individual as a result of the information produced by this matching program untilprogram, in pertinent part: unless (1) ED independently verifies the individual receives a notice from ED containing a statement of information, or ED’s findings and informing 's Data Integrity Board determines, in accordance with guidance issued by the individual Director of the opportunity OMB, that: (a) the information is limited to contest such findings, identification and amount of benefits paid by ED under a Federal benefit program; and (b) there is a high degree of confidence that the information provided to ED is accurate; (2) such individual has received a notice stating the subsequent expiration results of the 30-day notice period. To ensure match and stating that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) the individual has at least 30 days to provide a SAR documentation to the student (and will issue an ISIR institution to the institution, which subsequently also may choose to provide notice to the student of contest the results of the match) and will provide the student with a minimum of 30 days after the presentation of the SAR to contest the match, ; and (23) the subsequent 30-day notice period has expired. The notice will state that DHS-USCIS has not take any adverse action against an individual verified the applicant’s immigration status commensurate with the requirements of eligibility for federal student aid and that the applicant must provide appropriate documentation to the institution in order to verify the applicant’s immigration status. Applicants for, or recipients of, assistance under the Title IV Student Financial Assistance Programs may not have their benefits suspended, terminated, reduced, denied, or otherwise adversely affected as a result of the information produced by this matching program until third step procedures as specified by ED have been used to independently verify such information. These third step procedures are described as follows: • Under 34 C.F.R. 668.33(a)(2), applicants for assistance under the expiration Title IV Student Financial Assistance Programs must document their immigration status to prove their eligibility. Under current policy guidelines, if DHS-USCIS is unable to verify the applicant’s immigration status through automated initial or second step verification, institutions may not determine that the applicant is in an eligible immigration status for purposes of at least 30 days from the presentation receiving federal financial aid unless they independently verify this eligibility, by visual inspection and identification of the SARimmigration documents representing the applicant’s current immigration status and submission of a completed paper or electronic Form G-845, along with copies of the DHS-USCIS provided documentation for manual review by DHS-USCIS of an applicant’s immigration records before disbursing Title IV Student Financial Assistance. The SAR will instruct • If an institution's independent verification of immigration status described above determines an alien applicant to be ineligible for the Title IV Student Financial Assistance Programs, the institution of higher education must, under 34 CFR 668.42(b)(2), make available to such applicant any information describing the student eligibility requirements that it used to submit additional verifying information to document make its determination. If the applicant disagrees with the institution's independent determination of his or her Veteran status immigration status, the institution of higher education should refer the applicant to the institution. The results of this match do not preclude DHS-USCIS Website: xxxxx://xxx.xxxxx.xxx/sites/default/files/USCIS/Verification/SAVE/SAVE_Nativ e_Documents/SAVE_FACT_SHEET_for_Benefit_Applicants.pdf, which provides the applicant from receiving Title IV, HEA Program assistance. The applicant must correct information about correcting his or her FAFSA information, provide parental data, or document immigration records so that he or she is a Veteran as defined in the HEA. The institution will assist the applicant in making any necessary corrections to receive financial assistance at the postsecondary educational institution that he or she is attending. The applicant is the person who is best able to produce documents to verify Veteran status, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to can obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran an accurate match for purposes of determining eligibility for Title IV, HEA Program assistance after considering any additional information provided by the studentIV Student Financial Assistance Programs.

VERIFICATION PROCEDURES. ED may not suspend, terminate, reduce, or make a final denial of any financial assistance or payment under Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications for Title IV, HEA Program assistance. ED will only send the records of applicants who reported that they are Veterans to VA for matching with the BIRLS SystemCompensation, Pension, Education, and Vocational Rehabilitation and Employment Records – VA” (58VA21/22/28). As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies will notify the applicant and the applicant’s educational institution that VA has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran status, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features The level of this match are the volume and speed of the systemsystem are important features of this matching program. The system is designed to yield match results from applicant data in a short time frame so to ensure that applicants have information available to make informed decisions about the Title IV, HEA program Program assistance available at the institutions where they have applied. In fact, during peak processing months, the efficiency of the match is so efficient that yields up to 919 applications per day have been processed in peak monthsday. The applicant is determined to be the best source of information on the validity of notice the matching results. Consequently, ED’s notification process is highly automated and requires compressed verification procedures because it is not possible to intervene until after the output document documents (the Student Aid Report (SAR)/ Institutional SAR)/Institutional Student Information Record - (ISIR)) is are issued and challenged by the student. student is the best source for determining whether the results of the match are accurate Individual applicants are required personally to resolve match discrepanciesdiscrepancies at the institution of higher education for which they plan to attend and receive Title IV, HEA program assistance. Indeed, the The OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility.... ” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program assistance or take other adverse action against an individual as a result of the information produced by this matching program until, in pertinent part: (1) the individual receives a notice from ED containing a statement of ED’s findings and informing the individual of the opportunity to contest such findings, and (2) the subsequent expiration of the 30-day notice period. To ensure that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) provide a SAR to the student (and will issue an ISIR to the institutioninstitution of higher education, which subsequently also may choose to provide notice to the student of the results of the match) and will provide the student with a minimum of 30 days after the presentation of the SAR to contest the match, and (2) not take any adverse action against an individual as a result of the information produced by this matching program until the expiration of at least 30 days from the presentation of the SAR. The SAR will instruct the student to submit additional verifying information to document his or her Veteran status to the institution. The results of this match do not preclude the applicant from receiving Title IV, HEA Program assistance. The applicant must correct his or her FAFSA information, provide parental datadata if otherwise a dependent student, or document that he or she is a Veteran as defined in the HEA, as amended. The institution will assist the applicant in making any necessary corrections to receive Title IV, HEA Program financial assistance at the postsecondary educational institution that he or she is attending. The applicant is the person who is best able to produce documents to verify Veteran status, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to obtain confirmation of Veteran status. The institution of higher education will inform the student whether he or she is considered a Veteran for purposes of Title IV, HEA Program assistance after considering any additional information provided by the student.

VERIFICATION PROCEDURES. ED may not suspendThe OMB Final Guidelines for the Privacy Act (Final Guidance Interpreting the Provisions of Pub. Law 100-503, terminatethe Computer Matching and Privacy Protection Act of 1988, reduce54 FR 25818, or make June 19, 1989) state that the type of verification procedures used for a final particular matching program depends upon the purpose of that program. This match will identify the Title IV, HEA applicants who are subject to denial of any financial assistance Federal benefits and will ensure that reasonable verification procedures have been developed that yield confirmatory data and provide ED with a reasonable basis for taking action. When a match is made, the individual in question already will have had a court hearing in connection with the underlying criminal conviction and sentence, and his or payment under Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications her eligibility for Title IV, HEA Program assistancebenefits will have been determined by a Federal or State judge. ED will only send Because the records individual’s denial of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA benefits sanction has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran statusalready been determined, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified verification procedures for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are focus on verifying the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the individual’s identity for Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak monthspurposes. The basic verification procedures are as follows: A. ED Issues to the Applicant Section 5301 Comment of Ineligibility on SAR An applicant will have at least 30 calendar days from the date of the output document (the date on the applicant’s Student Aid Report (SAR)) to contest a proposed adverse action before his or her eligibility for Title IV, HEA student financial assistance is denied. The individual applicant is determined to be the best source of information on the validity of notice resultsresults in which a computer match occurs pertaining to his or her application. Consequently, ED’s notification process is The highly automated and process used under the Title IV, HEA program requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) SAR is issued and challenged reviewed by the student. Individual applicants are required personally With regard to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that each individual for whom a match occurs, XX will inform him or her that results in an adverse consequence ED cannot continue to process his or her application because a computer match has occurred with regard to his or her identity. XX will inform the individual of this information by providing a section 5301 comment on his or her SAR stating that ED cannot process the loss of, application for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program program assistance or take other adverse action against an individual as a result further because of issues raised by the Anti-Drug Abuse Act of 1988. Further, the applicant will be instructed to contact ED within 30 days from the date of the information produced letter at the phone number provided by this matching program until, in pertinent part: (1) the individual receives a notice from ED containing a statement of ED’s findings and informing the individual of the opportunity to contest such findings, and (2) the subsequent expiration of the 30-day notice period. To ensure that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) provide a SAR to the student (and will issue an ISIR to the institution, which subsequently also may choose to provide notice to the student of the results of the match) and will provide the student with a minimum of 30 days after the presentation of on the SAR to contest the matchadverse action. B. Applicant May Inquire Regarding Section 5301 Comment If the applicant makes an inquiry within the specified time (30 days) regarding a section 5301 comment on the applicant’s SAR, ED headquarters will review the DFB/DPFD database again to independently verify and (2) not take any adverse action against an individual as a result confirm the accuracy of the information produced in the DFB/DPFD. With regard to an applicant’s inquiry based upon section 5301, ED personnel will have direct and immediate access, through Federal Student Aid’s CPS, to the applicant’s FAFSA record, including section 5301 file data provided by this matching program until DOJ. Consequently, when the expiration of at least 30 days from the presentation of the SAR. The SAR will instruct the student to submit additional verifying information to document applicant contacts ED with questions regarding his or her Veteran status section 5301 comment, ED personnel will be able to quickly confirm the institution. The results student’s ineligibility for one or more of this match do not preclude the applicant from receiving Title IV, HEA Program assistanceprogram(s). The A new 5301 file is retrieved from DOJ every 4 to 6 weeks, loaded into the CPS, and matched against the Title IV, HEA application file, which also contains the individual’s name and SSN. For a match to occur, the individual’s name, SSN, and date of birth must match. If the applicant must correct his or her FAFSA information, provide parental data, or document does not make an inquiry to ED within the specified time regarding a section 5301 comment that he or she receives, ED’s initial finding will be upheld as final, and Title IV, HEA program eligibility will be denied. C. ED Verifies Eligibility Should verification with DOJ, as noted in section VI. B. above, indicate that eligibility is restored, ED personnel will be able to override standard CPS system procedures to produce and forward a Veteran as defined in valid SAR. This will enable the HEA. The institution will assist the applicant in making any necessary corrections student applicant, if otherwise eligible, to receive financial assistance at the postsecondary educational institution that he or she is attending. The However, should the outcome of such verification with DOJ confirm the initial finding, the applicant is will be so notified and provided with at least 30 additional calendar days, from the person who is best able date ED provides its finding to produce documents to verify Veteran statusthe applicant, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran for purposes of Title IV, HEA Program assistance after considering any additional information provided by applicant may contest the studentinitial finding.

VERIFICATION PROCEDURES. ED may not suspend, terminate, reduce, or make a final denial of any financial assistance or payment under the Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications for Title IV, HEA Program assistance. ED will only send the records of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran status, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak months. The applicant is determined to be the best source of information on the validity of notice results. Consequently, ED’s notification process is highly automated and requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) is issued and challenged by the student. Individual applicants are required personally to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program assistance Financial Assistance Programs or take other adverse action against an individual as a result of the information produced by this matching program untilprogram, in pertinent part: unless (1) ED independently verifies the individual receives a notice from ED containing a statement of information, or ED’s findings and informing 's Data Integrity Board determines, in accordance with guidance issued by the individual Director of the opportunity OMB, that: (a) the information is limited to contest such findings, identification and amount of benefits paid by ED under a Federal benefit program; and (b) there is a high degree of confidence that the information provided to ED is accurate; (2) such individual has received a notice stating the subsequent expiration results of the 30-day notice period. To ensure match and stating that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) the individual has at least 30 days to provide a SAR documentation to the student (and will issue an ISIR institution to the institution, which subsequently also may choose to provide notice to the student of contest the results of the match) and will provide the student with a minimum of 30 days after the presentation of the SAR to contest the match, ; and (23) the subsequent 30-day notice period has expired. The notice will state that DHS-USCIS has not take any adverse action against an individual verified the applicant’s immigration status commensurate with the requirements of eligibility for federal student aid and that the applicant must provide appropriate documentation to the institution in order to verify the applicant’s immigration status. Applicants for, or recipients of, assistance under the Title IV Student Financial Assistance Programs may not have their benefits suspended, terminated, reduced, denied, or otherwise adversely affected as a result of the information produced by this matching program until third step procedures as specified by ED have been used to independently verify such information. These third step procedures are described as follows: • Under 34 CFR 668.33(a)(2), applicants for assistance under the expiration Title IV Student Financial Assistance Programs must document their immigration status to prove their eligibility. Under current policy guidelines, if DHS-USCIS is unable to verify the applicant’s immigration status through automated initial or second step verification, institutions may not determine that the applicant is in an eligible immigration status for purposes of at least 30 days from the presentation receiving federal financial aid unless they independently verify this eligibility, by visual inspection and identification of the SARimmigration documents representing the applicant’s current immigration status and submission of a completed paper or electronic Form G-845, along with copies of the DHS-USCIS provided documentation for manual review by DHS-USCIS of an applicant’s immigration records before disbursing Title IV Student Financial Assistance. The SAR will instruct • If an institution's independent verification of immigration status described above determines an alien applicant to be ineligible for the Title IV Student Financial Assistance Programs, the institution of higher education must, under 34 CFR 668.42(b)(2), make available to such applicant any information describing the student eligibility requirements that it used to submit additional verifying information to document make its determination. If the applicant disagrees with the institution's independent determination of his or her Veteran status immigration status, the institution of higher education should refer the applicant to the institution. The results of this match do not preclude DHS-USCIS Website: xxxxx://xxx.xxxxx.xxx/sites/default/files/USCIS/Verification/SAVE/SAVE_Nativ e_Documents/SAVE_FACT_SHEET_for_Benefit_Applicants.pdf, which provides the applicant from receiving Title IV, HEA Program assistance. The applicant must correct information about correcting his or her FAFSA information, provide parental data, or document immigration records so that he or she is a Veteran as defined in the HEA. The institution will assist the applicant in making any necessary corrections to receive financial assistance at the postsecondary educational institution that he or she is attending. The applicant is the person who is best able to produce documents to verify Veteran status, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to can obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran an accurate match for purposes of determining eligibility for Title IV, HEA Program assistance after considering any additional information provided by the studentIV Student Financial Assistance Programs.

VERIFICATION PROCEDURES. ED may not suspend, terminate, reduce, or make a final denial of any financial assistance or payment under the Title IV of the HEA to an individual, or take other adverse action against such individual as a result of information produced by this matching program until an institution participating in a program under Title IV of the HEA has asked the applicant to produce evidence of Veteran status or allows the applicant to file as a dependent student. Under the matching program, individual applicant records are matched at the time ED processes applications for Title IV, HEA Program assistance. ED will only send the records of applicants who reported that they are Veterans to VA for matching with the BIRLS System. As a result of an unsuccessful match (VA values 2, 3, or 4), ED notifies the applicant and the applicant’s educational institution that VA has not confirmed the applicant’s Veteran status via the application output document that is sent both to the institution and the applicant. If VA cannot confirm Veteran status, the applicant must provide proof of Veteran status to the institution if that is the sole reason the student qualified for independent status. For an applicant whose Veteran status is questioned, but he or she qualified as an independent student under criteria other than Veteran status, no further action is required of the applicant. Important features of this match are the volume and speed of the system. The system is designed to yield match results from applicant data in a short time frame so that applicants have information available to make informed decisions about the Title IV, HEA program assistance available at the institutions where they applied. In fact, the match is so efficient that up to 919 applications per day have been processed in peak months. The applicant is determined to be the best source of information on the validity of notice results. Consequently, ED’s notification process is highly automated and requires compressed verification procedures because it is not possible to intervene until after the output document (the Student Aid Report (SAR)/ Institutional Student Information Record - (ISIR)) is issued and challenged by the student. Individual applicants are required personally to resolve match discrepancies. Indeed, the OMB guidelines anticipate such a situation when they state: “It would be of dubious utility to apply the verification requirements equally to all matches and argue that a match that results in an adverse consequence of the loss of, for example, a tuition assistance payment should receive the same due process procedures as one that results in the loss of an Aid to Families with Dependent Children (AFDC) payment or Food Stamp eligibility...” (54 FR 25818, 25827 (June 19, 1989)). Furthermore, under the Privacy Act, ED may not suspend, terminate, reduce, or make a final denial of Title IV, HEA Program assistance Financial Assistance Programs or take other adverse action against an individual as a result of the information produced by this matching program untilprogram, in pertinent part: unless (1) ED independently verifies the individual receives a notice from ED containing a statement of information, or ED’s findings and informing 's Data Integrity Board determines, in accordance with guidance issued by the individual Director of the opportunity OMB, that: (a) the information is limited to contest such findings, identification and amount of benefits paid by ED under a Federal benefit program; and (b) there is a high degree of confidence that the information provided to ED is accurate; (2) such individual has received a notice stating the subsequent expiration results of the 30-day notice period. To ensure match and stating that these requirements are met, when Veteran status is not confirmed as a result of this matching program, ED will: (1) the individual has 30 days to provide a SAR documentation to the student (and will issue an ISIR institution to the institution, which subsequently also may choose to provide notice to the student of contest the results of the match) and will provide the student with a minimum of 30 days after the presentation of the SAR to contest the match, ; and (23) the subsequent 30-day notice period has expired. The notice will state that DHS-USCIS has not take any adverse action against an individual verified the applicant’s immigration status commensurate with the requirements of eligibility for federal student aid and that the applicant must provide appropriate documentation to the institution in order to verify the applicant’s immigration status. Applicants for, or recipients of, assistance under the Title IV Student Financial Assistance Programs may not have their benefits suspended, terminated, reduced, denied, or otherwise adversely affected as a result of the information produced by this matching program until additional procedures as specified by ED have been used to independently verify such information. These additional procedures are described as follows: • Under 34 CFR 668.33(a)(2), applicants for assistance under the expiration Title IV Student Financial Assistance Programs must document their immigration status to prove their eligibility. Under current policy guidelines, if DHS-USCIS is unable to verify the applicant’s immigration status through automated initial or additional verification, i.e., second step matching, institutions may not determine that the applicant is in an eligible immigration status for purposes of at least 30 days from the presentation receiving federal financial aid unless they independently verify this eligibility, by visual inspection and identification of the SARimmigration documents representing the applicant’s current immigration status and submission of a completed Form G-845, along with copies of the DHS-USCIS provided documentation for manual review by DHS-USCIS of an applicant’s immigration records before disbursing Title IV Student Financial Assistance. The SAR will instruct • If an institution's independent verification of immigration status described above determines an alien applicant to be ineligible for the Title IV Student Financial Assistance Programs, the institution of higher education must, under 34 CFR 668.42(b)(2), make available to such applicant any information describing the student eligibility requirements that it used to submit additional verifying information to document make its determination. If the applicant disagrees with the institution's independent determination of his or her Veteran status to immigration status, the institution. The results institution of this match do not preclude higher education should refer the applicant from receiving Title IVto DHS-USCIS, HEA Program assistance. The which will provide the applicant must the opportunity to correct his or her FAFSA information, provide parental data, or document that he or she is a Veteran as defined in the HEA. The institution will assist the applicant in making any necessary corrections to receive financial assistance at the postsecondary educational institution that he or she is attending. The applicant is the person who is best able to produce documents to verify Veteran status, by, for example, submitting a copy of the Certificate of Release or Discharge from Active Duty (DD Form 214). He or she may also contact the VA Regional Office, or branch of service in which he or she served, to immigration records and obtain confirmation of Veteran status. The institution will inform the student whether he or she is considered a Veteran an accurate match for purposes of determining eligibility for Title IV, HEA Program assistance after considering any additional information provided by the studentIV Student Financial Assistance Programs.