Posted Date: March 9, 2015

Author:  Lisa DiCarlo, Director, Student Experience Group, Federal Student Aid

Subject: Procedures to follow When Adding or Changing Alien Registration Numbers

We are reminding schools about the procedures to follow when adding or correcting a student’s Alien Registration Number (ARN) on the Free Application for Federal Student Aid (FAFSA®) to confirm eligible noncitizen status with the U.S. Department of Homeland Security (DHS). Following these procedures will reduce the number of unnecessary G-845 forms Financial Aid Administrators (FAAs) are completing and submitting to DHS. As you know, all applications are sent to the Social Security Administration (SSA) for U.S. Citizenship status verification and, when alien registration numbers (ARNs) are provided, they are matched with DHS. Based on the database match results, the Institutional Student Information Record (ISIR) will have: no code or comment (in the case of a successful SSA match), a code indicating that the FAA needs to request additional documentation, or a code indicating that the student’s eligible noncitizen status has been confirmed. These procedures are outlined in the SAR Comment Codes and Text Guide.

Social Security Administration Citizenship Status Match

All applications are matched with SSA records to verify name, date of birth, U.S. citizenship status, the Social Security number (SSN), and, if applicable, the date of death.

If the SSA match is successful, the student’s citizenship status will be confirmed and a comment code will not be displayed.

If the SSA is unable to confirm that the student is a U.S. citizen or national, the ISIR will display a C code and comment code 146. In these cases, resolution is required (see the SAR Comment Codes and Text Guide for resolution). If the student claims to be a U.S. citizen or national, your school must decide what documents are acceptable to prove U.S. citizenship or nationality. The Department doesn’t specify which documents are acceptable but some documents your school might choose include (but are not limited to): a copy of the student’s birth certificate showing that the student was born in the United States or its territories, a U.S. passport, a Consular Report of Birth Abroad, a Certificate of Citizenship, and/or a Certificate of Naturalization. Note that a driver’s license or voter registration cards are not adequate proof of citizenship since some localities do not require proof of citizenship to possess these IDs.

DHS Primary Verification Match

If the student provides an eligible noncitizen document, instruct the student to correct question 14 on the FAFSA (to indicate that they are an eligible noncitizen) and add their ARN in question 15. This correction will tell CPS to send the record to DHS. An updated ISIR will be available to the school within three days, with a DHS Match flag response of
Y(es) or N(o), since CPS identifies records that contain an ARN and sends the Name, SSN, Date of Birth and ARN to DHS for eligible noncitizen matching. The DHS system uses the ARN, rather than name or SSN to identify individuals in their system.

Procedure for Comment Code 144 and C Flag:

Comment Code 144 appears on an ISIR when the DHS Match Flag equals “N.” Eligible noncitizen status was not confirmed when matching with the DHS primary database.

FAAs need to determine whether the ARN on the ISIR matches the ARN on the student’s eligible noncitizen documentation. If the ARN on the ISIR does not match the ARN on the noncitizen documentation, the ARN must be corrected on the student’s FAFSA. The G-845 form should not be completed and submitted in this case, because the DHS Match Flag on the ISIR is associated with the incorrect ARN. Instead, once the ARN is corrected CPS will send the corrected ARN to DHS for matching. The record will go through the DHS primary confirmation process because DHS identifies the corrected ARN as a new record in their system. CPS will produce a corrected ISIR within three days with the corrected ARN.

The DHS Match Flags on the corrected ISIR are applicable to the corrected ARN. FAAs should follow the procedures for the Match flags and code, and complete a G-845 form only if the DHS Match Flag = “N” and the DHS Secondary Match Flag = “N” (see comment code 46) or “X” (see comment code 109).

If the DHS Secondary Match Flag = “C” (see comment code 105), wait ten business days for another system generated ISIR with an updated DHS Secondary Match flag before beginning the mandatory paper (G-845) Secondary Confirmation process. See the “Electronic Announcements” section of the IFAP Web site, located at ifap.ed.gov for the most recent G-845 form and mailing addresses. If the requested documentation includes a U.S. Department of Health and Human Services (HHS) Eligibility or Certification letter and/or the student provides a copy of a T-visa, follow the instructions in Dear Colleague Letter GEN 06-09 in lieu of completing and submitting the G-845 form.

If the DHS Match Flag OR the DHS Secondary Match Flag = “Y” (see comment code 120), continue processing the student’s financial aid.

Do not complete a G-845 without evidence of eligible noncitizen status.

If a student submits documentation that does not provide evidence that the student is an eligible noncitizen, the FAA should not complete and submit a G-845 form. Page 1-32 of the Federal Student Aid Handbook (click on link below) describes documents that do not prove a student’s eligibility for federal student aid. Examples are: a Social Security Card stamped “Employment Authorized”, and “U” or “F” Visas. FAAs should inform these students that they are ineligible for federal student aid, and should keep a copy of the student’s documentation and an explanation of the determination in the student’s file.

If the student indicates that he or she has obtained an eligible status, but has lost the documentation to prove it, the student must call the USCIS National Customer Service Center at 1-800-375-5283 to replace the lost document.

More information about eligible and non-eligible citizen documentation, SSA and DHS matches, codes and the G-845 form can be found in the Federal Student Aid Handbook, Volume 1, Chapter 2: Citizenship at: http://ifap.ed.gov/fsahandbook/attachments/1415Vol1Ch2.pdf.

Contact Information

If you have questions, contact CPS/SAIG Technical Support at 1-800-330-5947 (TDD/TTY 1-800-511-5806) or by e-mail at CPSSAIG@ed.gov.

   

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