In a recent electronic announcement, Jeff Baker who announced his retirement at this year’s FSA Conference in Atlanta, GA, provided guidance to schools when an applicant is moved from a previously assigned Verification Tracking Group of V1, V4, or V6 to Verification Tracking Group V5. Thankfully, the announcement also comes with a (very) handy “Verification Tracking Groups Chart” which breaks down the verification results and institutional requirements that must be met when an applicant is either not initially selected or has changed from V1, V4, or V6 to Verification Tracking Group V5 on a subsequent transaction.
In general, if student is initially or subsequently selected for verification, they must complete verification of all the information required for the applicant’s current Verification Tracking Group. Failure to complete verification will, in most instances, require the student (not the institution) to repay any Title IV aid that had been disbursed. Similarly, if after completing verification, the school FAA determines that the student received an over award of Title IV aid, the student (not the institution) is responsible for repaying those funds unless the aid was disbursed as an interim disbursement; then it’s the institution’s responsibility.
According to the announcement, there have been instances where an institution received a subsequent 2016-2017 ISIR that placed the student into Verification Tracking Group V5 after some 2016-2017 Title IV aid had been disbursed. If that student does not satisfactorily complete verification, including verification of identity/statement of educational purpose and high school completion status, the student must return all 2016-2017 Title IV aid that had been disbursed. Under these situations the institution is not liable for the return of any of these funds.
Check out the Electronic Announcement and attached chart here: http://bit.ly/2gDTPiO