Quality Assurance Program

Transcription

1 Preconference Quality Assurance Program November 30, 2015 U.S. Department of Education 2015 FSA Training Conference for Financial Aid Professionals

2 Preconference Objectives Conclusion of QA Program Transition Activities Action Plan Overview of Federal Verification and Discretionary Verification Recognition and Celebration 2

3 What was going on in 1985? Music History and Politics TV Verification of Applicant Data Reported on FAF 3

4 Evolution of the Program Killed thousands of trees all manual measured error/readings Pilot 1985 Authorized in HEA Continuous Improvement automated/web-based 4

5 Original Pioneers Ball State University 1985 Cuyahoga Community College 1985 Purdue University 1985 Stanford University 1985 University of Southern California 1985 Virginia Polytechnic Institute & State University 1985 Massachusetts Institute of Technology 1986 Oklahoma State University 1986 Pennsylvania State University (The) 1986 SUNY College at Brockport 1986 SUNY College at Buffalo 1986 University of California, Berkeley 1986 University of Colorado Boulder 1986 University of Minnesota - Twin Cities 1986 University of Missouri - Columbia 1986 University of Notre Dame 1986 University of Utah

6 QA and Federal Verification Random 1970 s Validation 1980 s/iqc Methods to reduce error in awarding Title IV aid Risk Model 2009 present/qap Targeted, IRS DRT, Prior/Prior Verification 2000/IQAP The Future 6

7 Transition Activities Using the QA Program Action Plan

8 QA Action Plan Project Lead: Current exemptions through the award year: As an authorized participant of the QA Program, the Institution has been exempted from the following selected reporting or verification regulations: 34 CFR (a)(1); (2); (3) and (4); (a)(1); (2); and (4); ; ; and (a). At the beginning of the award year, the institution will have the responsibility to comply with all verification regulations outlined in Part 668 Student Assistance General Provisions _ Subpart E Verification and Updating of Student Aid Application Information. 8

9 Requirements QA verification regulatory exemptions remain in place Verify applicants according to the institution s verification criteria Upload the records that met its criteria into the ISIR Analysis Tool so the Department can complete the program-wide analysis Complete two FSA Assessments or Activities 9

10 Requirements QA verification regulatory exemptions remain in place Verify applicants according to the institution s verification criteria or schools may choose to begin verifying applicants according to federal verification If the school chooses to begin verifying applicants according to federal verification, it must do so at the beginning of the award year Completion of two FSA Assessments or Activities is optional 10

11 Requirements Must fully comply with all Verification regulations as outlined in Part 668 Student Assistance General Provisions - Subpart E Verification and Updating of Student Aid Application Information 11

12 QA Exemptions vs. Requirements after Transition Period 12

13 Chart to Assist with Transition Use this chart to assist you to transition out of the QA program: 13

14 Verification Resources Refer to the Verification Assessment for links to these helpful resources: Application and Verification Guide Program Integrity Verification FSA Assessments Verification 14

15 QUESTIONS? 15

16 VERIFICATION for QA Schools

17 Agenda Selecting students for verification Notification requirements Verification selection groups Required documentation V4/V5 tracking results IRS data retrieval tool IRS tax return transcripts Making adjustments Resources 17

18 How are Students Selected? CPS selection (ED) Data-based statistical analysis focusing on applicants with highest probability of error Verification flag provided on ISIR/SAR Asterisk (*) next to EFC School MUST verify all applicants selected by CPS School selection - based on school criteria Items may be same as ED verifiable item; or Items may be different from those required to be verified by ED 18

19 Selected by CPS After Disbursement Must verify before making more disbursements If verification doesn t support disbursements already made, student must repay Except may keep Stafford Loan funds 19

20 Communicating with Schools Y V3 Auto Zero EFC Flag XXX Rejected Status Change Flag X Duplicate SSN Flag XXX EFC Change Flag XXXXXXXX Verification Selection Change Flag y Address Only Correction X Y SNT Flag XXX Special Circumstance Flag X SAR C Change Flag X Transaction is now selected for verification when the transaction being corrected was not selected Selected for Verification Child Support Paid Verification Group 20

21 Notice to Student School must provide a written statement to students selected for verification that includes Clear explanation of the documentation requirements Student s responsibilities with regard to the verification process including deadlines and consequences School s responsibilities for notifying student of changes in aid resulting from verification 21

22 Verification Deadline Dates Direct Loans & Campus-Based Aid: School sets deadline for verification completion Pell Grants: Verification must be completed by the earlier of: 120 days after last day of student enrollment Secretary s deadline (Federal Register) Award Year deadline is expected to be sometime in September 2017 Verification is complete when your school has reviewed ALL requested documentation 22

23 School Verification Document Electronic Announcement Pending Contains appendices to assist with crafting school verification documents to gather required verification data To remove unnecessary burden on all parties, ED urges institutions to use a targeted approach to request only required verification information from students and families Schools still allowed to select additional items based on school selection policy 23

24 Verification Selection Groups V1 Standard Verification Group V2 Reserved for Future Use V3 Reserved for Future Use V4 Custom Verification Group V5 Aggregate Verification Group V6 Household Resources Verification Group 24

25 V1 Tax Filers Adjusted Gross Income U.S. Income Tax Paid Untaxed Portions of IRA Distributions Untaxed Portions of Pensions IRA Deductions and Payments Tax Exempt Interest Income Education Credits Documentation: IRS DRT; Tax Return Transcripts; Alternate documentation where allowed (e.g. amended returns, foreign returns, etc.) 25

26 V1 Non-Tax Filers 26 Income earned from work Documentation 1. Signed statement certifying: - Individual has not filed and not required to file 2015 tax return; - Sources of income earned from work and amounts of income from each source for tax year 2015; and 2. Copy of IRS Form W 2 for each source of employment income received for tax year 2015

27 V1 Non-Tax Filers If an institution questions a claim that the tax filer is not required to file, must require applicant to submit a Verification of Nonfiling Letter by completing: Form 4506-T and checking box 7 Verification of Nonfiling Letter for 2015 tax year generally not issued until after June 15,

28 V1 All Applicants Number in Household & Number in College Documentation: Household size signed statement (name, age, relationship) -Not required if: Dependent student household size reported is 2 and parent is unmarried or 3 if the parents are married or unmarried and living together Independent student household reported is one and applicant is unmarried or two if the applicant is married Number in College signed statement (name of household member attending at least half-time and eligible institution name) Not required if reported number is one (student) 28

29 V1 All Applicants SNAP Benefits (If reported on ISIR) Documentation Statement signed by applicant affirming SNAP benefits received by someone in household during 2014 and/or 2015 If school has concerns with accuracy of information, the institution must obtain documentation from the agency that issued the SNAP benefits 29

30 V1 All Applicants Child Support Paid (If reported on ISIR) Documentation Statement signed by applicant/parent certifying: Amount of child support paid Name of the person who paid the child support Name of the person to whom child support was paid, and Names and ages of the children for whom child support was paid If the institution has reason to believe that the information provided in the signed statement is inaccurate, the applicant must provide the institution with supporting documentation, such as checks, signed statements etc. 30

31 V4 Custom High School Completion Status Identity/Statement of Educational Purpose SNAP Benefits (if reported on ISIR) Child Support Paid (if reported on ISIR) 31

32 High School Completion Status High school completion status Documentation High school diploma; or Final official high school transcript showing date diploma awarded, or Secondary leaving certificate (for students who completed secondary education in a foreign country and are unable to get a copy of high school diploma/transcript) Note: If prior to student being selected for verification, an institution already obtained HS completion status records for other purposes, the institution may rely on those records as long as it meets ED HS completion criteria 32

33 High School Completion Status Recognized equivalent of a HS diploma Documentation Copy of student s General Educational Development (GED) certificate, an official GED transcript that indicates the student passed the exam, or a state-authorized HS equivalent certificate, or Academic transcript of a student who has successfully completed at least a two-year program that is acceptable for full credit toward a bachelor s degree, or Student excelled academically in HS and has met all the criteria to be admitted to a 2-year degree program or higher 33

34 High School Completion Status Test transcripts of State-authorized examinations Documentation Official test transcripts of state-authorized examinations (e.g., GED test, HiSET, TASC, or other state-authorized high school equivalency examinations) are acceptable documentation of high school completion only if: -The official test transcript specifically indicates that a State has determined that the test results are considered by the state to meet its requirements of a high school equivalency, or -The official test transcript includes language that the final score is a passing score 34

35 High School Completion Status Homeschooled Documentation Credential, transcript, or the equivalent, signed by the parent or guardian, that lists the secondary school courses completed by the applicant and documents the successful completion of a secondary school education, or A secondary school credential for homeschool provided for under state law 35

36 Identity/Statement of Educational Purpose Students that appear in person Documentation Present to an institutionally authorized individual A valid (unexpired) government-issued photo identification, and A signed statement of educational purpose provided by ED, cannot be modified Maintain an annotated copy of the identification: The date documentation was received, and The name of the institutionally-authorized individual that obtained the documentation 36

37 Identity/Statement of Educational Purpose Student unable to appear in person Documentation Must provide the institution: A copy of a valid (unexpired) government-issued photo identification AND An original, notarized statement of educational purpose signed by the applicant (cannot be faxed or scanned) Maintain a copy in the file After examining the original Statement of Educational Purpose for accuracy and completeness, the institution may convert it into an electronic record 37

38 V5 Aggregate High School Completion Status Identity/Statement of Educational Purpose AND All items indicated-tax Filer (V1) All items indicated-non-tax Filer (V1) 38

39 V6 Household Resources All items indicated-tax Filer (V1), or All items indicated-non-tax Filer(V1), AND Other untaxed income from FAFSA: Payments to tax-deferred pension and savings Child support received Housing, food and other living allowance paid to members of the military, clergy and others Veterans noneducation benefits Other untaxed income Money received or paid on the applicant s behalf 39

40 V6 Household Resources Other Untaxed Income Documentation Documentation: Signed statement listing sources and amounts of income for tax year 2015 and Copy of IRS W-2s for sources of employment income received for tax year 2015, where applicable If institution determines amounts provided do not appear to provide sufficient support for family members reported, the applicant (and parent/spouse) must: Provide additional signed statement listing other resources used to support family (may include items not required to be reported on FAFSA or other verification forms) Explain how financially supported during 2015 calendar year 40

41 V6 Household Resources Institutions should use reasonable judgment when evaluating the validity of the income information provided by students and parents who are placed in Verification Tracking Group V6 Reasonable may differ among institutions Institutions may choose to accept a signed low-income statement, an income-to-expenses comparison, or other documentation as determined by the institution 41

42 FAA Access Identity Verification Results In an Identity Verification Results reporting function was added to FAA Access Institutions report the identity verification results for students who have been selected for verification under V4 or V5 Institutions should be reporting this information on a regular basis (Refer to Electronic Announcement posted November 6, 2014) 42

43 FAA Access Identity Verification Results Whom to report: student for whom school received an ISIR with a Verification Tracking Group of V4 or V5 AND for whom school requested verification documentation Do NOT include students the school selected for verification of identity or high school completion status When to report: 60 days following the institution's first request to the student to submit the required V4 or V5 identity and high school completion documentation changes to previously submitted Identity Verification Results must be updated within 30 days 43

44 V4/V5 Tracking Results Dropdown options will be: 1. Verification completed in person, no issues found 2. Verification completed remotely, no issues found 3. Verification attempted, issues found with identity 4. Verification attempted, issues found with HS completion 5. No response from applicant or unable to locate 44

45 IRS Data Retrieval Tool Process by which applicants can retrieve and transfer income tax return information from the IRS onto the FAFSA on the Web FAFSA IRS information (AGI, taxes paid and any applicable untaxed income) is considered verified if unchanged by applicant (02 IRS Request Flag) 45

46 IRS Data Retrieval Tool Items Imported from IRS forms 1040, 1040A and 1040EZ Type of tax return filed Filing status Adjusted Gross Income (AGI) Taxes paid Income earned from work Exemptions 46

47 IRS Data Retrieval Tool Items Imported from the 1040 and 1040A but not the 1040EZ Education credits IRA deductions Tax-exempt interest income Untaxed IRA distributions Untaxed pensions 47

48 Tax Return Transcript Obtained from the IRS Information based on initial tax filing Obtained in most situations where a student/parent cannot or does not use the IRS Data Retrieval process 48

49 Tax Return Transcript Exceptions In limited instances, Tax Return Transcripts are not used for verifying IRS data Those exceptions include Identity theft Tax returns from foreign countries Tax returns from U.S. Territories Certain situations where IRS Tax Return Transcripts are unavailable and ED issues guidance 49

50 Ordering IRS Tax Return Transcripts GET TRANSCRIPT ONLINE TOOL* 50 IRS website AUTOMATED PHONE TOOL* Toll-free IRS number SMART PHONE Download IRS2Go app free for iphone/ipod Touch from itunes or Google Play Store for Android phone MAIL Obtain form online & mail to the IRS pp/picklist/list/forms Publications.html

51 Submitting Changes to Data For subsidized programs, school must submit any changes for: Any non-dollar item or A single dollar item of $25 or more If required to submit one change, must submit all changes 51

52 Resources Federal Student Aid Handbook Application and Verification Guide Chapter 4 Federal Register June 26, 2015 ( verification items & documentation) Dear Colleague Letter GEN Published on June 29, 2015 Federal Regulations 668 Subpart E ( ) (f) 52

53 Resources Program Integrity Q & A Website (verification) ntegrity-qa.html FSA Assessments Activity 3 Verification Codes 53

54 QUESTIONS? 54

55 Contact Information For questions about this training, contact me: Bruce Honer, Training Officer, For comments on training, contact: Jo Ann Borel, Training Supervisor

56 Institutional Profiles How to interpret the data to prepare for federal Verification

57 Objectives Explain the profiles Enable schools to apply their profiles to their transition from QA to Federal verification Share FSA s recommended data analysis timeline Answer your questions (AT THE END!) 57

58 Institutional Profile Tour Data School selected records ONLY Information on CPS verification limited to records that happen to overlap Data Random sample Representative information from all records selected by the CPS for verification in Tale of Two Schools Public Four-Year Ball State University Private Four-Year Boston University 58

59 Impact of School and Federal Verification - Public 4 Year 59

60 Impact of School and Federal Verification - Private 4 Year 60

61 Impact of School and Federal Verification Program-wide 61

62 Random Sample School and Federal Verification 62

63 Random Sample School and Federal Verification 63

64 Random Sample Program-wide Impact 64

65 Potential Overpayments Corrected by School and Federal Verification 65

66 Potential Overpayments Corrected by School and Federal Verification 66

67 Potential Underpayments Corrected by School and Federal Verification 67

68 Potential Underpayments Corrected by School and Federal Verification 68

69 Random Sample Verification Outcomes 69

70 Random Sample Verification Outcomes 70

71 Take away What does the analysis of MY school s profile recommend? How/If my school will implement recommendations AFTER the QA Program ends? MUST verify CPS selected record MAY continue to verify records selected by (effective) school criteria 71

72 Data Analysis Requirements Up load data into the Tool Analyze data Profiles , as needed to fine tune What school criteria to keep, drop, or modify? How will just CPS verification work at your school? February 1, 2016 data extract IA Tool decommissioned March 1,

73 Next steps Review/circulate your profile Formulate strategy for moving to CPS verification by Compile questions for your QA Program regional representative to assist with analysis 73

74 Resources QA Program website Recording of November 19, 2015 webinar Ongoing transition guidance Regional Representatives 74

75 QUESTIONS? 75

76 Contact information Regional Representatives Data analysis ONLY 76

77 Recognition and Celebrate 77