Students of journalism become very familiar with the “who what, when, where, why, and how” questions of fact gathering. These five questions are sometimes called the “Five Ws and one H”, or more simply, the “Five Ws”. These basic investigative questions are utilized to get to the crux of a matter being considered. The origin of such method for inquiry dates back to the ancient Greeks (e.g., Hermagoras and Cicero), although it was revitalized in more recent times by Rudyard Kipling in his writings, and specifically in “The Elephant’s Child”. So, what does this have to do with financial aid?
Financial aid can, in many situations, be viewed as a prime opportunity for utilizing the Five Ws. One specific case in point is the recent guidance offered by the U.S. Department of Education (ED) on reporting “Identity Verification Results.” This guidance was provided in the November 13, 2013 Electronic Announcement (EA) and was highlighted at the Federal Student Aid Conference in early December 2013. More recent direction is provided in the 2014-2015 Application and Verification Guide (AVG) volume released April 3, 2014, as part of the Federal Student Aid Handbook. While this AVG was being cleared for release on IFAP, ED provided further direct clarification to FAME staff. (NOTE to FAME Financial Aid Processing clients: As you read through this article to gain an understanding of this new requirement, please keep in mind that FAME will notify clients when ED makes a process available for third-party servicers to report this information on your behalf.) So, do we have all of the answers to the Five Ws that are important to verification reporting? Let us review the “Five Ws” to see.
Who? Schools must now ensure that the results of verification are reported to ED. This reporting requirement is applicable only for those students selected for verification by the Central Processing System (CPS). It does not apply to those students selected solely at the school’s discretion. Specifically, schools are to report on students in Verification Tracking Groups V4 and V5. Moreover, the written guidance in the EA of November 13, 2013, states that “Financial Aid Administrators” are required to report the results of verification on these students. On the surface, this would seem to indicate that third-party servicers would not be able to perform this requirement for schools. For example, third-party servicers do not have access to FAA Access to CPS Online. Therefore, if that mode of reporting is the only means of submitting the outcomes of the Identity Verification Results, it would preclude schools being assisted by third-party servicers. However, FAME’s latest direct contact with ED has provided assurance that for those schools that do utilize a third-party servicer (e.g., FAME’s servicing), ED will make available batch reporting processes that servicers may utilize on behalf of schools. This is critical to ensuring third-party servicers are able to continue to provide comprehensive and timely assistance to schools in areas which the schools may deem too challenging on time, staff, and/or financial resources to do themselves. As just stated, ED has given understanding that they will allow third-party servicers to perform this reporting function for schools. But, at this point, the details of that option have not been delineated. More information on that process is to be forthcoming. Thus, the “who” that is able to report Identity Verification Results is currently “schools”, which is soon to be expanded to “third-party servicers” (acting on behalf of schools), as well.
What? The “what” of the requirement to report Identity Verification Results pertains to the outcome of a school’s verifying and documenting a student’s identity and high school completion status for those students in Verification Tracking Groups V4 and V5. The details stipulate that a school may report the results of its verification of students in those groups by using the Results Codes as numbered here:
1 – Verification completed in person, no issues found
2 – Verification completed using notary, 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
NOTE: In cases where issues are found with a student’s high school completion status and identity, schools must report using the Results Code ‘3’ response listed above.
It is important that schools understand that this new Identity Verification Results reporting is in addition to, and does not replace, the long-established reporting of verification statuses to the Common Origination and Disbursement (COD) System. Schools must continue to report the traditional verification status codes for each recipient of a Federal Pell Grant who was selected for verification. Those customary codes are represented as: V = you have completed verification of the student’s application data whether the student was selected by the Central Processing System (CPS) or the school; W = the student was selected for verification but you made an interim first Pell Grant payment before completing verification; S = the CPS selected the student for verification, but you did not verify the student because the student satisfied a verification exclusion reason; and, Blank = neither CPS or the school selected the student for verification or the CPS selected the student after he or she was no longer enrolled and all disbursements (including late) were already made.
When? That part of the journalistic analysis of the Identity Verification Results reporting requirement has not been defined yet. ED has not given the specifics of “when” to report. Rather, it has only stated that, in this first year of the reporting requirement, results must be submitted shortly after the end of the 2014-2015 award year. ED will give more specificity when it publishes the annual notice in the Federal Register that gives the deadline dates for receiving documents and other information required from schools and students. Ironically, although the reporting timeframes have not been defined yet, ED did state that schools are expected to report results on a regular basis. This would seem to indicate that schools should not wait until the end of the award year to submit all Identity Verification Results at once. Nonetheless, for the specifics of “when” results must be reported, we await ED’s announcement in the Federal Register, which historically is generated in late June or early July each year.
Where? The initial direction from ED is that “where” schools will have to report verification results is on the FAA Access to CPS Online website at https://faaaccess.ed.gov. At present, FAA Access to CPS Online is the only place where schools may enter the Identity Verification Results. The screen images below, adapted from those provided by ED at the 2013 FSA Conference, are used to illustrate “where” the reporting is to be done. Then, we will move to the next of the “Five Ws”, the “why” related to this reporting process.
Why? As has been indicated above, effective with the 2014-2015 award year processing, schools now have to report the Identity Verification Results for those students so selected. But, “why” is this reporting requirement being implemented? Students designated by the Central Processing System (CPS) for Verification Tracking Groups V4 and V5 are required to provide acceptable documentation of their identity and high school completion status. Fraud has been discovered in the Title IV programs, e.g., the emergence and growth of the so-called Pell Grant fraud rings. Fraud in financial aid has been highlighted in such ED documents as the September 26, 2011, Office of Inspector General’s report on fraud and further discussed in Dear Colleague Letter GEN-11-17, as well as at ED’s Federal Student Aid Conferences. The expansion of verification requirements to include identity and high school completion status has as a basic goal to ensure that those receiving Title IV Federal Student Aid are legitimate, and otherwise eligible, students appropriately enrolled at the school. Reporting of Identity Verification Results is one effort ED initiated to reduce potential for fraud in these major programs. And, undoubtedly, the earlier discussion of ED’s admonition to encourage early and frequent reporting is to identify and stop potential fraudulent activity as soon as possible.
How? The current method for reporting the Identity Verification Results is online. The original process for reporting allowed only manual entry of the results. Effective with the 2014-2015 upgrades made available on April 14, 2014, the data may now also be entered by uploading a flat file of the necessary data. The flat file feature will allow users to upload results for multiple students. Each flat file may contain up to 2000 student records. The flat files may be created by using any generic text editor, e.g., Notepad.
As we have deliberated this new reporting requirement related to verification, we have examined each of the critical components for understanding the topic. The outcome of our analysis is that ED will require the Identity Verification Results codes to be provided effective with the 2014-2015 award year. Such reporting will assist in reducing opportunities for fraud. The data required to be reported will be submitted on an ongoing basis within time parameters yet to be disclosed by ED. Schools may now begin to report information on students selected by ED in Verification Tracking Groups V4 and V5. However, the latest information disclosed indicates ED is also in the process of developing a means for third-party servicers (e.g., FAME) to report this information on behalf of those schools that utilize such a third-party servicer. Thus, we have used the Five Ws as basic investigative questions in our analysis of the new reporting requirements. As Rudyard Kipling would say, we now know the “What and Why and When, And How and Where and Who” of Identity Verification Results as we have completed this journalistic inquiry.
(EA 11132013; EA 04042014; 1415 AVG-79; 2013 FSA Conference GS3)
The Literature Network – https://www.online-literature.com/kipling/165/. “The Elephant’s Child”.