The regulations that govern the verification of Title IV Federal student aid application information are set forth in 34 CFR Part 668 Subpart E (34 CFR 668.51-668.61). In accordance with these regulations, a school is required to complete verification of information submitted by an applicant on the Free Application for Federal Student Aid (FAFSA) in connection with the calculation of the applicant's expected family contribution (EFC) for the Title IV Federal student aid programs if the applicant has been selected for verification.
For each Federal Pell Grant (Pell Grant) award disbursed to a student who was selected for verification, a school must report the student’s verification status to the Department of Education (the Department) via the Common Origination and Disbursement (COD) System. To do this, the school includes a verification status code (“W,” “V,” or “S”) in the Common Record document it submits to the COD System via batch processing or when it creates the award online via the COD website.
Verification Status Code Reporting Reminders
As explained in the 2019–20 Federal Student Aid Handbook, generally, for each 2019–20 Pell Grant recipient selected for verification by the Central Processing System (CPS), a school should have reported a verification status code of “V” or “S.” Below are some reminders regarding verification status code reporting for recipients selected for verification by the CPS as well as recipients not selected for verification by the CPS.
Recipients Selected for Verification by the CPS
Your school is required to verify all recipients selected for verification by the CPS, as described below, unless a recipient is exempt from verification in accordance with the exclusions from verification provided for in the regulations at 34 CFR 668.54(b). These exclusions are outlined in Chapter 4 of the “Application and Verification Guide” of the 2019–20 Federal Student Aid Handbook.
Even if your school does not need to verify a student under the exemptions referenced above, it is required to report a verification status code for every student selected for verification by the CPS. Your school should ensure that it
- has provided a verification status code for all recipients selected for verification by the CPS. If your school previously did not report a verification status code, (that is, the field was left blank), it must report a “V” or an “S.” Blank is not an acceptable verification status code, except in the case when a student is selected after he or she is no longer enrolled at your school.
- has reported an “S” only if the student is selected for verification but is exempt under the allowable exclusions.
If verification was not completed and the student is not exempt from verification, the Pell Grant must be adjusted to a zero dollar amount ($0.00).
Recipients Not Selected for Verification by the CPS
A school may choose to verify recipients not selected for verification by the CPS.
- A school should ensure that it has 1) reported a verification status code of “V” if it chose to verify or 2) has left the field blank if it did not choose to verify.
- A school should ensure that it has not reported a verification status code of “S” for recipients in this category.
2019–20 Verification Status Code “W” Warning Message will be Processed on July 30, 2020
A school that has made an interim Pell Grant disbursement to a student selected for verification should be concluding verification activities and changing a student's verification status code from “W” to “V” or “S,” as appropriate. In the following two cases, it is acceptable for the verification status code field to be blank:
- If the student was not selected for verification or if a selected transaction was received by the school after the student was no longer enrolled and the school has reported the verification status code as “W,” the school should change the “W” to blank (nil = “True”).
- If the student was not selected for verification or if a selected transaction was received by the school after the student was no longer enrolled and the school has reported no verification status code to date, the school does not need to submit a verification status code and should leave the field blank (nil = “True”).
As noted in an April 3, 2020 Electronic Announcement, we cancelled the verification warning and “deobligation” process usually completed in April. At this time, we plan to continue with the process in July 2020. On July 30, 2020, we will begin processing a message to schools that have one or more 2019–20 student records still reported with a verification status code of “W.” The message is a warning that disbursements to all students with a verification status code of “W” will be considered overawards and reduced to a zero dollar amount ($0.00), even though the disbursements were previously accepted in the COD System. The reduction of the affected disbursements is scheduled to occur on Aug. 20, 2020.
We will send the July 30, 2020 warning message to schools' Student Aid Internet Gateway (SAIG) mailboxes in the message class PGTX20OP. Additionally, we will send a file of 2019–20 student records reported to the COD System with a verification status code of “W” in the Reconciliation Report message class PGRC20OP. A school that receives the warning message should review the accompanying Reconciliation Report and submit appropriate changes to the verification status codes for affected students before Aug. 20, 2020.
Note Regarding Verification Deadline:
Some of the student records included in the Reconciliation Report may be for students who are still within the allowable timeframe for submitting verification documentation/completing the verification process by the deadlines specified in the “2019–2020 Award Year Deadline Dates” published in the Federal Register on Nov. 1, 2019. The Nov. 1, 2019 notice is also posted on the IFAP website.
Following the Aug. 20, 2020 reduction, if a school needs additional time to complete verification for an individual student in accordance with the allowable timeframe in the Federal Register notice, the school may resubmit a disbursement record with a value greater than zero ($0.00) until October 1, 2020. After October 1, 2020, the COD System will no longer accept “W” as a valid verification status code for 2019–20 Pell Grant awards.
If you have questions about the warning message or about reporting verification status codes to the COD System, contact the COD School Relations Center at 1-800-848-0978. You may also email CODSupport@ed.gov.