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Student Eligibility and Financial Need - Appendix A: Documenting Citizenship Status

AwardYear: 1996-1997
EnterChapterNo: 2
EnterChapterTitle: Student Eligibility and Financial Need
SectionNumber:
SectionTitle: Appendix A: Documenting Citizenship Status
PageNumbers: 69 - 89


As authorized by Congress, the SFA Programs are intended to
provide needy students with financial aid if the students are 1) U.S.
citizens or nationals, 2) permanent residents, 3) certain Pacific
Islanders, or 4) persons who intend to become citizens or permanent
residents of the United States. Chapter 2, Section 1 summarizes these
four categories. To be eligible for SFA funds, a student must prove
that he or she qualifies under one of these categories, which are
explained here in detail.

Appendix A explains when a school is required to document a
student's citizenship status and what documents are acceptable as
proof of the student's status.*1* Note that for the 1996-97 award
year, in certain circumstances institutions are no longer required to
perform Secondary Confirmation. Exceptions to the Secondary
Confirmation requirement are also discussed in this appendix.
Financial aid administrators should bear in mind that required
documentation verifying a student's citizenship status must be kept in
the school's files until the record retention period expires.

U.S. CITIZEN OR NATIONAL

The term "U.S. citizen" includes citizens of the 50 states, the District
of Columbia, Puerto Rico, the U.S. Virgin Islands, Guam, and the
Northern Mariana Islands. All U.S. citizens are considered to be U.S.
nationals. However, not all nationals are U.S. citizens: Natives of
American Samoa and Swain's Island are not U.S. citizens but are
nationals and therefore may receive SFA funds.

[[Documentation]]
Generally, students in the U.S. citizen or national category are not
required to provide status documentation to receive SFA funds.
(Note that if a student leaves the citizenship question blank but
provides an Alien Registration Number [A-Number], the Central
Processing System [CPS] will assume the applicant is an eligible
noncitizen and will forward the A-Number to the Immigration and
Naturalization Service [INS] to confirm eligibility.)

[[NEW]]
Beginning with the 1996-97 academic year, the Social Security
Number (SSN) match with the Social Security Administration (SSA)
was expanded to verify citizenship status for applicants who report
themselves as U.S. citizens. (Previously, the SSA conducted a match
that verified only SSNs.) All applications for federal student aid are
sent to SSA for the SSN match. The applications of those who report
themselves as eligible noncitizens and who provide A-Numbers will
also be sent to the INS match. Results from the INS match take
precedence over the results from SSA. Note that the INS match
process has not changed from prior years.

If the SSA does not verify an SSN, name, or date of birth, then the
citizenship status will not be verified, and Comment 62 will appear
on the SAR and ISIR. In this case, the student must provide his or
her school with documentation of his or her citizenship. The school
determines what constitutes acceptable documentation of citizenship.
See the list below for documents the school may choose to accept.

Under the expanded match, citizenship information reported by the
student is matched with SSA database information. Comment 146 is
printed if the SSA did not confirm U.S. citizenship status, and--
again--Comment 62 is printed if the SSA could not verify citizenship
because there was no match with the student's SSN, name, or date of
birth. On the ISIR, only the comment code is printed. The result of
the SSA match is reported differently on the student's SAR than on
the institution's ISIR. A comment code and a comment explaining
the result are printed on the student's SAR. (See Action Letter #8,
March 1996, "A Guide to 1996-97 SARs and ISIRs," for more
information.)

When a student's reported data conflict with the SSA database--or
when no citizenship match can be performed--he or she will receive
Comment 146 on his or her SAR, along with a SAR flag "C" printed
next to the EFC. A student who receives this comment must provide
the school with documentation substantiating his or her claim to be a
citizen or eligible noncitizen. Again, a student claiming to be an
eligible noncitizen must resubmit his or her SAR, which must
include the A-Number.

If the student's status as a citizen or a national must be documented,
the following are permissible forms of certification:

- A copy of the student's birth certificate showing that he or she was
born in the United States.

- A copy of Form FS-240 ("Report of Birth Abroad of a Citizen of
the United States"), the FS-545 ("Certificate of Birth-Foreign
Service"), the DS-1350 ("Certificate of Birth"), or the INS
Form G-639 (the Freedom of Information Act Form). The first
three forms are generated by the State Department and include an
embossed seal with the words "United States of America" and
"State Department."

- A U.S. passport, which may be current or expired. (In the case of
nationals who are not citizens, the passport will be stamped
"Noncitizen National.")

- A Certificate of Citizenship from the INS. This certificate must
include at least the following information:

the student's name and the application number,
the certificate number (found in the upper right hand
corner), and the date the certificate was issued.

- A Certificate of Naturalization from the INS. This certificate must
contain at least

the student's name and petition number,
the certificate number (found in the upper right hand corner),
the INS A-Number,
the name of the court that granted the naturalization, and
the date of naturalization.

Older versions of the Certificate of Citizenship and of the Certificate
of Naturalization advise the holder not to photocopy them. The INS,
however, now permits photocopying of these documents if done for
lawful purposes.

Note that a Social Security card or driver's license is not acceptable
for documenting citizenship or national status: Noncitizens and
nonnationals may possess these forms of identification.

CITIZENS OF THE PACIFIC ISLANDS

The Compact of Free Association (P.L. 99-329) created three
political entities from the former Trust Territory of the Pacific
Islands. Two of these entities, the Marshall Islands and the Federated
States of Micronesia, voted in 1986 to end political ties with the
United States. Citizens of these islands are eligible for Federal Pell
Grants, Federal Work-Study, and Federal Student Equal Opportunity
Grants (FSEOGs) but are not eligible for loans. Under the original
law, eligibility was to have been limited to four years after the
compact was signed and was allowed only for students who had
begun postsecondary education prior to the signing of the compact.
P.L. 100-369 extended eligibility and removed the provision
requiring prior postsecondary training.

The third entity, Palau, voted to ratify the compact in 1994; its
independence was effective October 1, 1994. Citizens of Palau who
enroll after that date will, like citizens of the Marshall Islands and the
Federated States of Micronesia, be eligible for Pell Grants, FWS, and
FSEOGs--but not for loans.

Note that the Northern Mariana Islands voted to become a
Commonwealth of the United States on November 3, 1986. Citizens
of these islands are U.S. citizens and are eligible for all SFA funds on
that basis.

Students who are citizens of the Marshall Islands, the Federated
States of Micronesia, or the Republic of Palau should check Block 2
(indicating eligible noncitizen status) in the citizenship question on
the Free Application for Federal Student Aid (FAFSA) and leave the
item about the A-Number blank. As long as the student's file contains
consistent information on his or her citizenship, the financial aid
administrator is not required to collect documentation.

OTHER ELIGIBLE CATEGORIES

[[General overview of the matching program]]
In contrast to citizens, nationals, and Pacific Island citizens--whose
documentation is needed only in the restricted instances discussed
earlier (for example, when the student's citizenship data are not
matched or when the student initially fails to check the box on
citizenship)--permanent residents and other eligible noncitizens must
always provide documentation on eligibility status. For the majority
of students, the U.S. Department of Education (the Department)
initiates the documentation process by accessing the INS computer
database. This computer match, known as Primary Confirmation,
produces a SAR comment, as well as an ISIR comment code
indicating that the student's status was confirmed, that it was not
confirmed, or that the INS was unable to search its records. If the
student's citizenship status is confirmed by INS, a comment is
printed to that effect on the SAR and no further documentation is
needed.*2*

[[Details about Primary Confirmation]]
Unsuccessful Primary Confirmations occur even when a student is an
eligible noncitizen. Primary Confirmation may not confirm the
student's status, for example, if the student did not provide enough
information when completing the application or if INS did not
respond to the Department within 24 hours, as required. Although
the student is not automatically rendered ineligible for SFA funds if
the computer match does not confirm the student's status, additional
procedures may be necessary to document the student's eligibility.
This subsequent paper process is called Secondary Confirmation.

In Primary Confirmation, an applicant's noncitizen information is
electronically matched with the database kept by INS. When
application data are received by the CPS, identifying information for
all noncitizen applicants is transferred electronically to INS's
computer. The match is conducted by using the A-Number collected
for all students who indicate that they are eligible noncitizens. (The
A-Number is a unique number assigned to each legal alien by INS.)
INS is responsible for matching this information and electronically
transmitting the INS response back to the CPS within 24 hours. The
CPS then prints the appropriate comment on the applicant's SAR.

[[SAR Comment 143]]
If the SAR comment states "Your citizenship status has been
confirmed by the Immigration and Naturalization Service (INS) and
you meet the citizenship requirements for Federal student aid"
(Comment 143), the student's status as an eligible noncitizen has
been confirmed. The SAR with that comment serves as
documentation of the student's eligibility, and the student need not
provide further evidence of his or her citizenship status.

If Comment 143 appears on the student's SAR, the required
documentation has been provided, and the SAR may serve as proof
of the student's eligible noncitizen status. (Note that the ISIR sent to
the school may also serve as proof.) There are four cases in which
additional documentation is needed, however. The student must
provide further documentation

[[SAR Comment 142]]
1. if Primary Confirmation was not attempted because certain key
information (e.g., the A-Number) was illegible or blank. In this
case, the following comment will appear on the SAR:

The Immigration and Naturalization Service (INS) could not
confirm your statement that you are an eligible noncitizen. You
must submit proof of your noncitizen eligibility to your school
within 30 days after you give this SAR to your school. If you fail
to submit proof within 30 days, you may be found ineligible for
Federal student aid.

This comment will also appear for citizens of the Marshall Islands,
the Federated States of Micronesia, and Palau because such
students are eligible noncitizens but would not have A-Numbers to
report. Again, proof of citizenship is not required in determining
eligibility for SFA funds for citizens of these areas.

[[SAR Comment 144]]
2. if the information needed to perform a match was on the
application but did not match the INS database information.
In this case, the following comment appears on the SAR:

The Immigration and Naturalization Service (INS) did not
confirm your statement that you are an eligible noncitizen. You
must submit proof of your noncitizen eligibility to your school
within 30 days after you give this SAR to your school. If you fail
to submit proof within 30 days, you may be found ineligible for
Federal student aid.

[[SAR Comment 145]]
3. if the INS was not able to match the student's record within 24
hours or if the computer matching program was not in service. In
this case, the following comment will appear on the SAR:

Because of processing problems, the Immigration and
Naturalization Service (INS) was not able to confirm your
statement that you are an eligible noncitizen. You must submit
proof of your eligible noncitizen status to your school before you
may receive Federal student aid.

[[Inconsistent information]]
4. if the school has on file conflicting data that cause the school to
question the validity of the match. (The General Provisions require
that the school resolve any conflicting information before paying
the student or certifying a loan application.)*3*

STUDENT RIGHTS WITH RESPECT TO THE COMPUTER
MATCH

If the student's citizenship status requires resolution, the school must
first ask the student to provide documentation of his or her status. If
the documentation provided does not appear to constitute reasonable
evidence of eligible noncitizen status, the school may determine the
applicant to be ineligible for SFA funds without sending the
documentation to INS for verification. On the other hand, if the
documents submitted appear to constitute reasonable evidence of
eligible noncitizen status, the school must then submit the
documentation to INS to verify its correctness. Sending the student's
documentation to INS for verification is a procedure known as
Secondary Confirmation, and requires the school to complete a Form
G-845S.

[[Limitations on using results of match to deny aid]]
The Computer Matching and Privacy Protection Act of 1988
prohibits a school from suspending, terminating, or reducing SFA
funds; making a final denial of SFA funds; or taking other adverse
action against a student based on the results of an interagency data
match unless the student has been notified and has had time to
respond to the notification.

As noted on the SAR for any student who must provide further
documentation, the student is permitted at least 30 days from the
time he or she submits the SAR to provide that documentation.
During this period and until the results of the Secondary
Confirmation are received, a financial aid administrator may not
deny, reduce, or terminate aid to a student. Disbursements may be
made to an otherwise eligible student pending the INS response if at
least 15 business days have elapsed since the date on which the
documentation was submitted to INS. (Of course, the general
exclusions for inconsistent data being on file are applicable here.)

[[Liability]]
A school is not liable for an error in its determination that a student is
an eligible noncitizen if, in making that determination, the school
had no conflicting data on file and it relied on 1) a SAR indicating
that the student meets the requirements for federal student aid, 2) an
INS determination of an eligible immigration status in response to a
request for Secondary Confirmation, or 3) immigration status
documents submitted by the student, if INS did not respond in a
timely fashion. The student (or parent for Federal PLUS borrowers)
is liable for any SFA funds received if he or she is ineligible. If the
school made its determination without having one of these types of
documents, the school is held responsible for repaying SFA funds to
the Department.

[[Appeal rights for SFA recipients]]
The school should establish procedures to ensure that if SFA funds
are disbursed and the school subsequently determines (using
Secondary Confirmation) that the student recipient is not an eligible
noncitizen, the student is provided with a notice of the determination,
an opportunity to contest the determination, and notice of the
school's final determination. The student may contest the
determination by submitting to the school all additional documents
the student believes support his or her claims to be an eligible
noncitizen. If the documents appear to support the student's claim,
the school should submit them to INS using Secondary
Confirmation. The school's final determination would be based on
the Secondary Confirmation results.

[[Requirements for notification to students]]
For every student required to undergo Secondary Confirmation, the
school is required to furnish written instructions providing

- an explanation of the documentation the student must submit as
evidence of eligible noncitizen status. (The "Summary Chart of
Acceptable Documentation" found at the end of this appendix is
acceptable);

- the institutional deadline for submitting documentation (which
must be at least 30 days from the date the school receives the
results of the Primary Confirmation on the SAR) and notification
that if the student misses the deadline, he or she may not receive
SFA funds for the award period or period of enrollment; and

- an acknowledgment that no determination of the student's
eligibility will be made until an opportunity to submit immigration
status documents is provided.

USING THE G-845S FOR SECONDARY CONFIRMATION

If the SAR (or ISIR) does not confirm the student's status as an
eligible noncitizen, the student must provide the school with
appropriate documentation (as explained in this appendix) showing
that he or she is a permanent resident or other eligible noncitizen.
The school must then initiate a Secondary Confirmation of this
documentation with INS to ensure validity.

To initiate Secondary Confirmation, the school must complete a
Form G-845S. The G-845S ("Document Verification Request") is a
standard INS form that is used to ask the File Control Office at INS
to confirm that an alien noncitizen's documentation is valid. To
complete the G-845S, fill in each item on the top half of the form.
The A-Number is provided in the first item; "Education
Grant/Loans/Work Study" must be marked in Box 8, "Benefits."
You must state your name as the submitting official and the school's
name as the submitting agency. Under Item 6, "Verification
Number," the school must provide the 13-digit number that is located
in the FAA Information section with the match flags.

[[No Verification Number]]
There are three circumstances in which a student will not receive a
verification number:

1. NO MATCH WAS PERFORMED DUE TO TECHNICAL
REASONS. If the student did not receive a number because no
match was performed due to technical reasons (Comment 145),
the aid administrator must write in large (preferably red) letters at
the top of the G-845S "Comment 145 present."

2. NO MATCH WAS PERFORMED BECAUSE THE STUDENT
FAILED TO PROVIDE AN ALIEN REGISTRATION
NUMBER. If the match was not performed because the student
failed to provide his or her A-Number on the application, the
school cannot initiate Secondary Confirmation for the student.
Instead, the SAR should be resubmitted for correction with the A-
Number.

3. THE STUDENT'S ELIGIBLE NONCITIZEN STATUS WAS
CONFIRMED BY THE MATCH. A school is not allowed to
initiate Secondary Confirmation for such students unless it has
conflicting information about the student's status or has reason to
believe the status reported is incorrect. However, the school will
not be able to use Secondary Confirmation to help resolve the
conflict unless it has a verification number from a prior or
subsequent transaction. The school must still resolve the conflict
before paying the student, and the school may request that the
student submit either the documentation normally required for
Secondary Confirmation or any other documentation necessary to
determine his or her correct status.

Photocopies of the front and back sides of the student's citizenship
document (such as an I-94 with the appropriate stamps or an I-551)
must be attached to the Form G-845S. Be sure to submit each
pertinent visa and document along with the G-845S. The G-845S is
used only to certify the authenticity and identity of immigration
documents attached to it; the G-845S must not be submitted to INS
by itself for determining a student's eligibility for SFA funds.
Therefore, an applicant who has lost documents or surrendered these
documents when entering prison is responsible for obtaining copies
of these documents before the G-845S is submitted. (See "Replacing
Lost INS Documents" in this appendix.) Schools may request copies
of immigration documents directly from penal institutions at the
request of the applicant. The school must send the completed G-845S
and attachments to the File Control Office serving its locale (see the
list at the end of this appendix) no more than 10 business days after
receiving the documentation from the student.

A status-verifier at the District INS Office will search the applicant's
record to confirm the applicant's immigration status. The status-
verifier at the INS office completes the "INS Response" section of
the G-845S and sends it back to the financial aid administrator,
generally within 10 working days of receipt. The Department
recommends that the school document its mailings to INS. If the
school has not heard from INS, the financial aid administrator may
wish to call the INS office to make sure that the G-845S was
received. If the school does not receive a determination from INS
within 15 working days (10 working days plus 5 days mail time) of
the date the school sent the G-845S, the financial aid administrator
should review the file to determine whether he or she feels the
student meets the citizenship eligibility requirements based on the
documentation the student provided and the information in this
appendix. If the administrator believes that the student meets the
requirements, the school may make any disbursement for which the
student is otherwise eligible; the school, however, must note in the
student's file that INS exceeded the time allotment and, thus,
citizenship eligibility was determined without the benefit of INS
verification.

DOCUMENTATION OF PERMANENT-RESIDENCE STATUS

As noted earlier, an applicant who claims to be a permanent resident
but whose status was not confirmed through Primary Confirmation
must provide copies of his or her INS documents (as described
below). The following is a discussion of the acceptable documents to
accompany the G-845S.

[[Standard documentation]]
The standard documentation for a permanent resident of the United
States is the Alien Registration Receipt Card (Form I-151 or Form I-
551). Both forms are referred to colloquially as "green cards,"
although the newly issued forms are most often white with blue or
pink wavy lines. The INS is replacing cards issued before 1979 with
these new, counterfeit-resistant cards. The deadline established for
permanent residents to replace their old cards was March 20, 1996.
However, the older Form I-151 cards remain acceptable as evidence
of permanent residence for the purpose of receiving SFA funds. A
passport or an I-94 is also acceptable if it has one of the following
stamps:

- A passport stamped "Processed for I-551. Temporary Evidence of
Lawful Admission for Permanent Residence. Valid until
____________. Employment Authorized."

- A Departure Record (form I-94) stamped as above or stamped
"Temporary Form I-551. Admission for permanent residence at
_______________[port] on ______________ [date] verified.
_________________ [signature of issuing officer] _________
[title]." This Form I-94 will also contain the individual's photo and
an INS seal over the photo and the stamp.

SPECIAL CIRCUMSTANCES

[[I-551 with baby picture]]
If the student has an I-551 with a baby picture, the financial aid
administrator should suggest that the student update the I-551 with
INS. Permanent residents are expected to obtain a new picture and to
be fingerprinted at the age of 14. However, the school may submit
the documents to INS and ultimately pay a student who has an I-551
with a baby picture, as long as the school can confirm that the I-551
belongs to the student. This confirmation may be accomplished by
comparing the I-551 to a current photo ID that has the student's
name, date of birth, and signature. (The current photo ID must also
be consistent with any identifying information in the student's file at
the school.)

[[Applicants for permanent residence]]
A student who has an approved application for permanent residence
on file with INS and who is waiting for an Alien Registration Receipt
Card may not have proof of his or her citizenship status. The
financial aid administrator should advise such a student to contact his
or her local INS office for the passport stamp or I-94 stamp
described above, as these are available to the student before the
normal permanent-residency documentation is issued. Note that an
APPLICATION for permanent-resident status is not sufficient for
determining eligibility for SFA funds.

The Marriage Fraud Amendments established a two-year conditional
permanent-residence status for certain alien spouses and their
children. The alien spouse of a U.S. citizen or legal immigrant is
given conditional permanent-residence status if the marriage took
place less than two years before the spouse applied for permanent-
residence status or citizenship. This status may also apply to any of
the spouse's children who are aliens.

An alien who is granted conditional permanent-residence status will
be given a Form I-551. This form is the same I-551 that is issued to
regular permanent residents, except that the card will have a "C" (for
"conditional") on the front and an expiration date on the back. Once
the two-year period expires, a conditional permanent resident must
file a petition for removal of this restriction within 90 days after the
end of that period. The alien's petition will then be reviewed. If the
results of the review are satisfactory, the restriction will be dropped,
and new documents will be issued. Conditional permanent residents
holding an I-551 with a valid expiration date are eligible to receive
aid under the SFA Programs.

DOCUMENTATION FOR OTHER CATEGORIES OF ELIGIBLE
NONCITIZENS

Procedures for a student who belongs to another category of eligible
noncitizens (such as a refugee, asylee, or parolee) and for whom
Primary Confirmation did not confirm his or her citizenship status
are similar to those just described for the permanent resident. The
applicant must provide copies of his or her INS documents (as
described below). A school must then initiate Secondary
Confirmation of these documents by using the G-845S.

For humanitarian reasons, a student who has been designated
by INS as lawfully present in the United States for other than
temporary purposes is considered eligible for aid from the SFA
Programs. Evidence of this lawful presence is given on the
departure record (Form I-94). The I-94 departure record will
contain one of the following:

[[Refugee]]
- A stamp indicating that the student has been admitted to the
United States as a refugee. This stamp will read either
"Admitted as a Refugee Pursuant to Section 207 of the Act.
If you depart the United States you will need prior permission
to return. Employment Authorized," or "Status changed to
refugee pursuant to Section 207 (c)(2) of the Immigration
Nationality Act, on ___________. Employment Authorized."

[[Asylee]]
- A stamp indicating that the student has been granted asylum
in the United States. This stamp will read "Asylum status
granted pursuant to Section 208, INS. Valid to ________________.
Employment Authorized." Persons who have been granted
asylum in the United States are given employment authorization
for one year. At the end of that year, they are eligible to apply for
permanent residence. Asylum status continues unless revoked
by INS or until permanent residence status is granted.

NOTE THAT A REFUGEE OR AN ASYLEE MAY APPLY FOR
PERMANENT-RESIDENT STATUS. DURING THE PERIOD IN
WHICH THE APPLICATION IS BEING REVIEWED, THE
STUDENT MUST SURRENDER HIS OR HER ORIGINAL I-94
TO INS. INS WILL GIVE THE STUDENT A COPY OF THE
ORIGINAL I-94, WHICH WILL INCLUDE THE ENDORSEMENT
"209A (OR 209B) PENDING. EMPLOYMENT AUTHORIZED."
STUDENTS WITH THIS FORM OF DOCUMENTATION ARE
ELIGIBLE FOR SFA FUNDS.

[[Conditional entrant]]
- A stamp indicating that the student has been admitted to the
United States as a conditional entrant. Although this status remains
valid, INS stopped using this category on March 31, 1980.
Therefore, if the school does not hear from INS within the
permissible time frame, the school should not disburse to a student
who shows an I-94 with conditional-entrant status granted after
March 31, 1980.

[[Parolee]]
- A stamp indicating that the student has been paroled into the
United States for an indefinite period of time for humanitarian
reasons. The word "indefinite" and/or "humanitarian" will be
handwritten into the stamp.

[[Cuban-Haitian]]
- A stamp across the face of the I-94 indicating that the student has
been classified as a "Cuban-Haitian Entrant (Status Pending).
Reviewable January 15, 1981. Employment authorized until
January 15, 1981." Note that a document showing that the holder
is a Cuban-Haitian entrant is valid even if the expiration date
would make the document appear to be no longer valid.

The I-94 for some Cuban-Haitian entrants who are applying for
permanent residence may be stamped "applicant for permanent
residence." (Or the student may instead be given a separate
document acknowledging the receipt of his or her application for
permanent residence.) Because the application for permanent
residence is not sufficient to make a student eligible for SFA
funds, a student who is a Cuban-Haitian entrant must request
documentation of that status from INS.

[[Suspension of deportation]]
If a person is applying to suspend deportation, he or she must request
a hearing before an Immigration Law judge who will render an oral
or written decision. If the decision is favorable, INS will give the
applicant a Form I-551, which will certify his or her lawful
permanent-resident status. Therefore, there is no special category for
persons who have been granted suspensions of deportation.

[[Family unity status]]
An approved Form I-797, "Application for Voluntary Departure
Under the Family Unity Program," indicates that the student has
been granted relief from deportation under the Family Unity
Program. In order to qualify for SFA funds, the student must also be
the beneficiary of an approved "Immigrant Petition for Relative" or
"Visa Petition for Spouse." These statuses are documented on the
Form I-797. Note that such a student may receive aid even if he or
she has not yet received a visa.

[[IRCA]]
The Immigration Reform and Control Act of 1986 (IRCA) made it
possible for certain categories of aliens to receive temporary-resident
status and eventually permanent-resident status. These categories
included aliens who 1) entered the United States illegally before
January 1, 1982, resided continuously in the United States between
that date and the date they applied for temporary-resident status, and
met certain other eligibility requirements or 2) performed qualifying
agricultural employment in the United States during defined periods
and met certain other eligibility requirements. This legalization
program was colloquially called the amnesty program.

An alien who was eligible for temporary-resident status under IRCA
and applied to an INS office was issued an Employment
Authorization Card (Form I-688A), which permitted an eligible alien
to work legally in the United States while his or her application was
being processed. Although the deadline for applying for amnesty
under Section 245 of IRCA has expired, some students may still hold
amnesty-related statuses if their cases are being disputed in one of
several lawsuits. A student who has a Form I-688A is not eligible for
SFA funds. These forms expired six months from the date of issue.
Except for those applicants whose cases are still being disputed,
some time during the six-month effective period of the Form I-688A,
the holder should have been notified whether the application for
temporary-resident status was approved.

The next step in the amnesty process was the issuing of the interim
Form I-688B or the I-766. These Employment Authorization
Documents (EAD) are used for employment authorization purposes
only. None of these documents (I-688A, I-688B, or the I-766) is
sufficient by themselves to qualify the student for SFA eligibility.

[[Temporary Resident Card]]
If the application for temporary-resident status was approved, the
applicant would have received the Temporary Resident Card (Form
I-688), popularly called a "red card," which has an expiration date.
Students who have valid Forms I-688 are eligible for SFA funds.

[[Student visas, etc., are not acceptable]]
A student with an F-1 or F-2 Student Visa; a J-1 or J-2 Exchange
Visitors Visa; L-1; or a G series Visa (pertaining to international
organizations) is not eligible to apply for SFA funds unless he or she
has a Form I-94 with one of the endorsements listed earlier. Also,
someone who has only a "Notice of Approval to Apply for
Permanent Residence (I-171 or I-464)" cannot receive SFA funds.

[[Temporary protective status not eligible]]
Some students may present Forms I-94 stamped "Temporary
Protected Status." This status is used for persons who are from
countries that are in upheaval, but the status differs significantly
from "Refugee" or "Asylum" because it provides no conversion to
permanent-resident status. A student with this status is NOT eligible
for SFA funds.

[[Stamp and validation]]
Each of the documents described above will be stamped in a rust-
colored ink. It will normally contain a validation indicating the office
of issuance and a code that indicates what officer prepared the
document. Examples of codes are "WAS-82" (Washington District
Office, Officer Number 82) or "1/13/84 SPO.KD" (Spokane Office,
officer's initials KD).

The school must keep in the student's file a copy of the citizenship
documentation the student submits, along with the G-845S results.
Documentation provided as proof of the student's citizenship status
(such as the Alien Registration Receipt Card and the Departure
Record) may legally be photocopied by the student, as long as the
photocopies are made for this lawful purpose. The student must
understand that he or she is permitted to photocopy an INS document
ONLY for lawful purposes such as applying for SFA funds.
(Document photocopying, however, is generally not permitted even
for other purposes.)

Financial aid administrators must always examine and copy original
documents. Sometimes the endorsement (a stamp) does not
photocopy well due to the ink color on the original document. In this
case, the financial aid administrator should hand copy the exact
endorsement on the photocopy. Because the endorsement can be
placed anywhere on the I-94, the endorsement may be difficult to
locate. Note that although the endorsement may appear on the
student's passport, the endorsement MUST ALSO be on the I-94.
INS offices do not have uniform procedures or stamps. The school
should contact the local INS office with questions regarding
acceptable citizenship documentation.

INTERPRETING THE G-845S

A single form, INS Form G-845S, is used both for the financial aid
administrator's request for a Secondary Confirmation and for INS to
respond to the school's request. In reviewing INS's response, bear in
mind that the G-845S reflects the student's most recent status with
INS and, thus, may show a different status than the documentation
presented by the student. In this case, the school should verify that
both documents identify the same person. If so, the status on the G-
845S should be used since that status is the most current.

The following are possible INS responses and consequent
implications with respect to student eligibility. After each item, we
have indicated whether a check in this block by INS indicates

- eligibility, in which case payments to the student may be made;

- ineligibility, in which case the student is not eligible for payment
unless the student later provides other valid documentation from
INS showing that he or she is an eligible noncitizen; or

- inconclusive eligibility, in which case the financial aid
administrator must examine any other boxes checked by INS to
determine whether payment can be made. A check in such a box
does not indicate eligibility or ineligibility.

[[Permanent resident (eligible)]]
1. THIS DOCUMENT APPEARS VALID AND RELATES TO A
LAWFUL PERMANENT RESIDENT ALIEN OF THE UNITED
STATES. Block #1 is checked when the documentation submitted is
determined to be a valid I-551, I-151, I-181, or I-94 or a passport
stamped with the notation "Processed for I-551, Temporary Evidence
of Lawful Admission for Permanent Residence."*4* Immigration
law allows this person to live and work in the United States on a
permanent basis.

[[Conditional resident (eligible)]]
2. THIS DOCUMENT APPEARS VALID AND RELATES TO A
CONDITIONAL RESIDENT ALIEN OF THE UNITED STATES.
This is checked when the documentation submitted is determined to
be a valid I-551, I-181, or I-94 or a passport stamped with the
notation "Processed for I-551, Temporary Evidence of Lawful
Admission for Permanent Residence." Immigration law allows this
person to live and work in the United States; however, INS will
reevaluate the person's status within two years. Conditional resident-
alien status is granted to an alien who marries a U.S. citizen or
national or permanent-resident alien; a conditional resident must
remain married to that spouse for two years to maintain resident
status.

[[Authorized employment (inconclusive eligibility)]]
3. THIS DOCUMENT APPEARS VALID AND RELATES TO AN
ALIEN AUTHORIZED EMPLOYMENT AS INDICATED
BELOW. This is checked to indicate whether the authorization
covers full-time or part-time employment and when, if applicable,
the period of employment will expire. "Indefinite" will be indicated
if there is no specific expiration date for employment eligibility.
Employment authorization by itself does not mean that the student is
eligible for SFA funds.

[[Application pending (inconclusive eligibility)]]
4. THIS DOCUMENT APPEARS VALID AND RELATES TO AN
ALIEN WHO HAS AN APPLICATION PENDING FOR...: This is
checked when an alien is waiting for a new immigration status or a
change of immigration status. If a change of status is pending, the
appropriate block indicating the current status will also be checked
elsewhere on the G-845S. A pending application for an immigration
status does not (by itself) render the student eligible for SFA funds.

[[Asylum/refugee status (eligible)]]
5. THIS DOCUMENT APPEARS VALID AND RELATES TO AN
ALIEN HAVING BEEN GRANTED ASYLUM/REFUGEE
STATUS IN THE UNITED STATES: This is checked when an
alien has been granted asylum or refugee status in the United States
because of persecution or because of a well-founded fear of
persecution in his or her country of nationality. These statuses are
considered temporary. Documentation presented may include either
Form I-94 stamped with "Section 207-Refugee" or "Section 208-
Asylee" or a Refugee Travel Document (Form I-571).

[[Parolee (eligible)]]
6. THIS DOCUMENT APPEARS VALID AND RELATES TO AN
ALIEN PAROLED INTO THE UNITED STATES PURSUANT TO
SECTION 212 OF THE IMMIGRATION AND
NATURALIZATION ACT: This is checked for an alien who has
been allowed to enter the United States under emergency conditions
or under the determination that his or her entry is in the public
interest. This status is temporary. Documentation presented may
include Form I-94 stamped with "Section 212(d)(5) - Parolee."

[[Cuban-Haitian entrant (eligible)]]
7. THIS DOCUMENT APPEARS VALID AND RELATES TO AN
ALIEN WHO IS A CUBAN-HAITIAN ENTRANT: This is checked
for Cubans who entered the United States illegally between April 15,
1980 and October 10, 1980 and Haitians who entered the country
illegally before January 1, 1981.

[[Conditional entrant (eligible)]]
8. THIS DOCUMENT APPEARS VALID AND RELATES TO AN
ALIEN WHO IS A CONDITIONAL ENTRANT: This is checked to
indicate a refugee who entered the United States under the seventh
preference category of P.L. 89-236 or whose status was adjusted to
lawful permanent-resident alien under that category. Documentation
presented may include Form I-94 stamped with "Section 203(a)(7)."
This status was defined by Section 203(a)(7) of the Immigration and
Nationality Act but was later abolished by the Refugee Act of 1980.
Noncitizens who fall into this category had to have entered the
United States prior to the enactment of the Refugee Act of 1980.

[[Alien nonimmigrant (ineligible)]]
9. THIS DOCUMENT APPEARS VALID AND RELATES TO AN
ALIEN WHO IS A NONIMMIGRANT. This is checked to indicate
an alien who is temporarily in the United States for a specific
purpose. This category includes students, visitors, and foreign
government officials. Documentation presented may include the
Form I-94.

[[Employment unauthorized (ineligible)]]
10. THIS DOCUMENT APPEARS VALID AND RELATES TO
AN ALIEN NOT AUTHORIZED EMPLOYMENT IN THE
UNITED STATES: This block is checked when an alien's status
prohibits employment in the United States.

[[Searching indices (inconclusive)]]
11. CONTINUE TO PROCESS AS LEGAL ALIEN. INS IS
SEARCHING INDICES FOR FURTHER INFORMATION. This
block is checked if INS is withholding judgment, pending further
investigation on the status or validity of documentation. This
statement does not imply that the applicant is an illegal alien or the
holder of fraudulent documentation. Benefits should not be denied
on the basis of this statement.

The document should be accepted at face value until INS sends final
notification regarding immigration status. If the student appears to be
an eligible noncitizen based upon the school's review of the
documents, the school may pay the student any SFA funds for which
he or she is eligible. If INS later notifies the school that the student's
documentation is not valid, the school must cancel further
disbursements but is not liable for the payments already made.

[[Invalid documentation (ineligible)]]
12. THIS DOCUMENT IS NOT VALID BECAUSE IT APPEARS
TO BE ALTERED OR COUNTERFEIT: This is checked when the
documentation presented has expired or when an item appears to be
counterfeit or altered. Notify the student that unless corrective action
is taken with INS, the case will be submitted to the Office of
Inspector General (OIG). Additional communication with INS will
allow any unfortunate mistakes in the status-verifier's review to be
corrected. Until this discrepancy is resolved, no further aid may be
disbursed, awarded, or certified. If the student does not take
corrective action in a timely manner, the case must be reported to the
OIG.

The INS will initial and stamp the front of the G-845S in the
signature block.

[[Comments on back of G-845S]]
The comments block on the back of the G-845S provides further
instructions. The intended meaning of each of the following blocks
that may be checked follows:

13. [ ] NO DETERMINATION CAN BE MADE FROM THE
INFORMATION SUBMITTED. PLEASE OBTAIN A COPY OF
THE ORIGINAL ALIEN REGISTRATION DOCUMENTATION
AND RESUBMIT. This is normally checked when the financial
aid administrator has failed to provide copies of any of the INS
documents. The statement is often accompanied by a listing of
acceptable forms of documentation. The financial aid
administrator should resubmit the G-845S with copies of the
original alien documentation.

14. [ ] NO DETERMINATION CAN BE MADE WITHOUT
SEEING BOTH SIDES OF THE DOCUMENT SUBMITTED.
Resubmit the G-845S with copies of both sides of each document.

15. [ ] COPY OF DOCUMENT IS NOT READABLE. Resubmit
the G-845S with higher quality copies of the original alien
documentation.

The comments listed under "Permanently Residing Under Color of
Law" (PRUCOL) reflect information about aliens who have applied
for special treatment (for example, by virtue of having life-
threatening medical situations) that may cause INS to refrain from
seeking their expulsion. These blocks will be checked only if a
request for evaluation for PRUCOL is made in Block 8 on the first
page of the G-845S. Comments will rarely be made in this section
because the financial aid administrator would not have asked for a
PRUCOL evaluation when submitting the G-845S. However, in all
cases, INS should check other responses on the form as well, and
these other responses should be used in the determination of the
student's status. Therefore, any INS response to Items 16 and 17
should render a decision of INCONCLUSIVE ELIGIBILITY.

[[Reconciling discrepancy]]
When Secondary Confirmation results in an eligible status, the G-
845S must be maintained by the school. If a discrepancy is
discovered as a result of the INS response, the school must notify the
student that he or she must correct the discrepancy with INS and that
no certification of loans or further disbursement of funds can be
made until the discrepancy is corrected. If the discrepancy is not
reconciled with INS, the student must repay all aid except wages
earned under the Federal Work-Study Program. Whenever the
student is able to provide new information, it must be submitted to
INS on a new G-845S form.

As long as the school has followed the procedures outlined here,
including notifying the student of the discrepancy and withholding
further payments and loan certifications as soon as a discrepancy is
found, the school is not liable for aid disbursed prior to Secondary
Confirmation. (This, of course, assumes that the school had no other
conflicting information prior to making the disbursement and had
reviewed the documentation and felt on that basis that the student
was eligible.)

UPDATING CITIZENSHIP STATUS IN LATER AWARD YEARS

There are several cases in which the school must verify a student's
citizenship in a subsequent award year if that student again does not
receive Primary Confirmation through the application process.

[[Updating the Temporary Form I-551]]
A student who presented a Temporary Form I-551 in a prior award
year should have received a permanent I-551 by the next year and,
thus, should not still be holding a temporary card. The school should
refer the student to INS to obtain a permanent I-551 or an updated
endorsement on the previous card. The documents should also be
submitted to INS on a G-845S.

The school must also document the citizenship status each award
year and obtain Secondary Confirmation if Primary Confirmation
has not produced a match for a conditional permanent resident, a
refugee, a Cuban-Haitian entrant, or a person granted asylum.
Students in any of these categories may have been adjusted to
permanent-resident status or may have had their statuses revoked.

The school does not have to perform Secondary Confirmation to
document a student's citizenship status in subsequent award years if
the school previously documented that the student is a U.S. citizen or
national; is a citizen of the Republic of Palau, the Federated States of
Micronesia or the Marshall Islands; or has a Form I-551 or I-151.

EXCEPTION TO THE SECONDARY CONFIRMATION
REQUIREMENT

[[NEW]]
The December 1, 1995 regulations added a new exception to the
Secondary Confirmation requirement (34 CFR 668.133 [b]). Schools
are not required to perform Secondary Confirmation if in a previous
award year a school determined the student to be an eligible
noncitizen after it performed Secondary Confirmation and if the
school does not have conflicting information or reason to doubt the
student's claim of having eligible noncitizen status. Also note that the
school must have CONFIRMED THE STATUS in a previous award
year. (The school may not disburse aid just because INS did not
respond.)

REPLACING LOST INS DOCUMENTS

If a student cannot locate his or her official INS documentation, the
student must request that the documents be replaced because
immigrants are required to have--in their possession--documentation
verifying their statuses. Requests for replacement documents should
be made to the INS District Office that issued the original
documents. (See the addresses at the end of this appendix.)

The student will be asked to complete a Form I-90, "Application to
Replace Lost Documents." A temporary I-94 may be issued while
the replacement documents are pending.

In cases of the student's undue hardship, in which the student
urgently needs documentation of his or her status, the Freedom of
Information (FOI) Act allows the student to obtain photocopies of
the documents from the INS District Office that issued the original
documents. The student may submit an INS Form G-639 to make
this request or may simply send a letter to the district office. If the
student is not sure which district office issued the original
documents, he or she may submit the request to the FOI office in
Washington, DC. (See addresses at the end of this appendix.)

ADDITIONAL INFORMATION

On the following pages, we have included several reference materials
that may prove helpful:

1. A summary chart of the documentation requirements discussed in
this appendix.

2. Examples of the principal types of documentation discussed in
this appendix.

3. A copy of the G-845S. This may be photocopied and used for
submission to INS.

4. A glossary of terms used in processing applications for
noncitizens.

5. A list of INS offices and addresses.

[[The "Summary Chart Of Acceptable Documentation" on page 2-89
is currently unavailable for viewing. Please reference your
paper document for additional information.]]

[[The examples of the principal types of documentation on
pages 2-90 through 2-92 are currently unavailable for viewing.
Please reference your paper document for additional
information.]]

[[The copy of the G-845S on page 2-93 and 2-94 is currently
unavailable for viewing. Please reference your paper document
for additional information.]]

GLOSSARY

You may encounter several unfamiliar terms in processing
applications from noncitizens. The definitions in this glossary are
informational in nature and should not be used for any other purpose.
They do not represent any formal source or policy of INS. Official
definitions have been shortened or edited whenever possible.

ALIEN: Any person who is not a citizen or national of the United
States.

ALIEN FILE (A-FILE): The history file containing all data and
documentation pertaining to an individual alien. An A-file is created
or amended when any one of several actions occurs: for example,
when applications for permanent resident status or for a Certificate of
Citizenship are submitted. Alien Registration Numbers (A-Numbers)
are assigned at the local File Control Office (FCO) processing the
initial action.

ALIEN REGISTRATION NUMBER (A-NUMBER): An eight- or
nine-digit number assigned to an alien at the time the alien file is
created.

ALIEN STATUS VERIFICATION INDEX (ASVI): A database
designed for the use of entitlement benefit agencies in verifying alien
immigration status in accordance with the Immigration Reform and
Control Act of 1986 (IRCA). The database is commonly known as
"SAVE".

ASYLEE: An alien, already in the United States or at a port of entry,
who is granted asylum in the United States. Asylum may be granted
to those persons who are unable or unwilling to return to their
countries of nationality, or who to seek protection because of
persecution or a well-founded fear of persecution upon returning to
their countries. Asylum is covered by Section 212 of the Immigration
and Nationality Act of 1952 (I&NA). (See also the definition for
refugee.)

CENTRAL INDEX SYSTEM (CIS): An automated system
containing information about aliens. The CIS, from which SAVE is
extracted, is INS' most complete database on aliens in the United
States.

CERTIFICATE OF CITIZENSHIP: An identity document proving
U.S. citizenship.

CERTIFICATE OF NATURALIZATION: An identity document
proving U.S. citizenship.

CHANGE TO NONIMMIGRANT STATUS: The act of changing a
nonimmigrant's classification (for example, changing from visitor to
student status).

CITIZEN: A person born in a country or who has become a
naturalized citizen of that
country.

CONDITIONAL ENTRANT: A refugee. (See definition for
refugee.)

CONDITIONAL RESIDENT ALIEN: An alien granted a two-year
period of permanent resident status based on a "qualifying" marriage
to a U.S. citizen, national, or permanent resident alien. Children of a
U.S. citizen, national, or permanent resident alien also may have this
status. The conditional status may be removed after two years if INS
rules favorably on granting lawful permanent resident status to the
alien.

CUBAN-HAITIAN ENTRANT: The status afforded to (a) Cubans
who entered the United States illegally between April 15, 1980 and
October 10, 1980, and (b) Haitians who entered the country illegally
before January 1, 1981. This status is covered by Section 502(e) of
the Immigration and Nationality Act.

DOCUMENT VERIFICATION REQUEST (FORM G-845S): A
form designed to request secondary confirmation of alien status from
INS under the Immigration Reform and Control Act of 1986.
Documented Alien: An alien who is in the United States and who is
in possession of valid documents.

FAMILY UNITY STATUS: Individuals who have been granted
relief from deportation by INS under the provision of the Family
Unity Program and who are the beneficiaries of an approved
"immigrant petition for relative" or "visa petition for spouse" are
eligible noncitizens for purposes of the SFA Programs.

FILE CONTROL OFFICE (FCO): An INS field office where alien
files are maintained.

GREEN CARD: A slang term describing the Alien Registration
Receipt Card (Form I-151 or Form I-551). Many versions of these
forms are not green in color.

ILLEGAL ALIEN: A foreign national (a) who entered the United
States without inspection or with fraudulent documentation or (b)
who, after entering legally as a nonimmigrant, violated status and
remained in the United States without authorization. (See also
definition for undocumented alien.)

IMMIGRANT: An alien who has been lawfully afforded the
privilege of residing permanently in the United States. His or her
status allows authorization for work and entitlement benefits. (See
also definitions for lawful permanent resident alien and permanent
resident alien.)

IMMIGRANT VISA: A document issued by a U.S. Consul abroad,
which authorizes an alien to apply for admission as an immigrant to
the United States.

IMMIGRATION AND NATIONALITY ACT OF 1952 (I&NA):
Legislation that defined most immigration statuses now in use and
that helped form the basis for U.S. immigration law and policies.

IMMIGRATION REFORM AND CONTROL ACT OF 1986
(IRCA): Legislation that was passed to deter illegal immigration to
the United States; the legislation uses employer sanctions and status
verification and allows the legalization of specific groups of aliens.

IMMIGRATION STATUS: The legal status conferred on an alien
by immigration law.

IMMIGRATION STATUS VERIFIER (ISV): An INS employee or
contractor that performs secondary verification duties at local INS
File Control Offices.

LAWFUL PERMANENT RESIDENT ALIEN: An alien who has
been lawfully afforded the privilege of residing permanently in the
United States. (See also definitions for immigrant and permanent
resident alien.)

LEGALIZATION: A program whereby an illegal alien could
receive amnesty and adjustment of his or her immigration status to
that of a temporary resident. The alien was required to establish
proof of entry prior to January 1, 1982, and continuous unlawful
residence since that time. This program is covered by section 245(A)
(c)(5) of IRCA.

NATIONALITY: The state or country to which a person owes
allegiance. Note that the country of birth does not necessarily
correspond to the nationality.

NATURALIZATION: The conferring of nationality of a state or
country upon a person who has been born under allegiance to
another nation.

NONIMMIGRANT: An alien who seeks temporary entry to the
United States for a specific purpose. This category includes foreign
government officials, visitors for business and pleasure, and students.
Some nonimmigrants have specialized employment privileges (for
example, foreign nationals who are employees of the U.S. office of a
foreign-owned company).

NONIMMIGRANT INFORMATION SYSTEM (NIS): INS on-line
files that store information on nonimmigrants in the United States,
such as foreign visitors, government personnel, and ship and flight
crews.

PAROLEE: An alien who appears to be inadmissible to the
inspecting officer but who is allowed to enter the United States either
under emergency conditions or under a determination that the alien's
entry is determined to be in the public interest. Although parolees are
required to leave when the conditions supporting their parole cease
to exist, they may sometimes adjust immigration status to asylee.
Parolee status is covered by Section 212 of the I&NA.

PASSPORT: Any travel document issued by competent authority
showing the bearer's origin, identity, and nationality which is valid
for the entry of the bearer into a foreign country.

PERMANENT RESIDENT ALIEN: A person who enters the
country with an immigrant visa or adjusts his status after entering as
a nonimmigrant, refugee, or asylee. Persons with this status are
entitled to live and work in the United States and collect entitlement
benefits, if qualified. (See also definitions for immigrant and lawful
permanent resident.)

PRIMARY CONFIRMATION: A query to confirm alien
documentation using the ASVI database.

PRUCOL: A person permanently residing in the United States under
color of law. This is not a status as defined by the I&NA of 1952,
and persons residing under this status are not eligible for SFA funds.

REFUGEE: Any person who is outside his country of nationality
and who is unable or unwilling to return to that country because of
persecution or a well-founded fear of persecution. Unlike asylees,
refugees apply for and receive this status prior to entry into the
United States. This status is covered by Section 207 (formerly
Section 203(a)(7)) of the I&NA. (See also definition for asylee.)

REFUGEE CONDITIONAL ENTRANT: An alien who entered the
United States or who adjusted his or her status to Lawful Permanent
Resident under the seventh preference category of Public Law 89-
236, which was enacted in 1965. This status was established by
Section 203 (a)(7) of the I&NA, but was abolished by the Refugee
Act of 1980 (Public Law 96-212).

SECONDARY CONFIRMATION: A request to validate alien
documentation, using Form G-845S, after Primary Confirmation has
been attempted. Secondary Confirmation is performed by the
immigration status verifier, using various automated and manual
sources.

SPECIAL AGRICULTURAL WORKER (SAW): This was part of
the legalization program in which an alien who had resided in the
United States and performed agricultural labor for at least 90 person-
days during the one year period prior to May 1, 1986 could apply for
temporary lawful resident alien status. The SAW status was limited
to the first 350,000 aliens that applied. Although most successful
applicants have now been converted to permanent resident status,
there are a limited number of pending cases, who may have I-688, I-
688a or I-688b status. See the description in the text for the
eligibility of these statuses.

STUDENT/SCHOOLS SYSTEM (STSC): INS's on-line file that
contains information on foreign students in U.S. academic and
vocational educational institutions.

SYSTEMATIC ALIEN VERIFICATION FOR ENTITLEMENTS
(SAVE): An automated or manual information sharing program
whereby institutions can certify the immigration status of alien
applicants for federal student financial aid. (See also Alien Status
Verification Index.)

TEMPORARY LAWFUL RESIDENT ALIEN: An alien granted a
one-year period of lawful resident status based on his or her
qualifications under the legalization or SAW programs. The
temporary status may be removed after one year, when INS rules
favorably or unfavorably on granting permanent resident status to the
alien.

UNDOCUMENTED ALIEN: An alien in the United States without
proper documentation. He or she is in violation of U.S. immigration
law. (See also definition for illegal alien.)

UNITED STATES: Defined in a geographic sense as the continental
United States, Alaska, Hawaii, Puerto Rico, Guam, United States
Virgin Islands, and Northern Mariana Islands.

VERIFICATION NUMBER: An INS tracking number which is
assigned to each noncitizen application if a match is attempted. It is
13 digits in length and can be found in the Financial Aid
Administrator section of the SAR, along with the match flags. With
one exception, it must be provided when the G-845S is submitted
(see text).

INS FIELD OFFICES DIRECTORY

ALASKA

Anchorage

INS: Immigration Status Verifier
Suite 102
620 East 10th Avenue
Anchorage, AK 99513

Phone: 907-271-4519
Fax: 907-271-3112


ARIZONA

Phoenix

INS: Immigration Status Verifier
2035 North Central Avenue
Phoenix, AZ 85004

Phone: 602-379-3255
Fax: 602-379-4009


CALIFORNIA

Los Angeles

INS: Immigration Status Verifier
300 N. Los Angeles Street
Los Angeles, CA 90012

Phone: 213-894-6285 / 6286
Fax: 213-894-6660

San Francisco

INS: Immigration Status Verifier
Appraisers Building
630 Sansome Street, Room 300
San Francisco, CA 94111

San Diego

INS: Immigration Status Verifier
880 Front Street
San Diego, CA 92101

Phone: 619-557-6727
Fax: 619-557-6565

California Service Center

INS: Immigration Status Verifier
P.O. Box 30080
Laguna Niguel, CA 92607

Phone: 714-360-2800


COLORADO

Denver

INS: Immigration Status Verifier
4730 Paris Street
Denver, CO 80239

Phone: 303-371-4415
Fax: 303-361-0617


CONNECTICUT

Hartford

INS: Immigration Status Verifier
450 Main Street
Ribicoff Federal Building
Hartford, CT 06103-3060

Phone: 203-240-3166
Fax: 203-240-3214


FLORIDA

Miami

INS: Immigration Status Verifier
7880 Biscayne Boulevard, Room 620
Miami, FL 33138

Phone: 305-536-5703 / 5704
Fax: 305-350-5708


GEORGIA

Atlanta

INS: Immigration Status Verifier
77 Forsyth Street, S.W.
Atlanta, GA 30303

Phone: 404-331-3251
Fax: 404-331-1146


GUAM

Agana

INS: Immigration Status Verifier
Pacific Daily News Building, Suite 801
238 Archbishop Flores Street
Agana, Guam 96910

Phone: 671-472-7349
Fax: 671-472-7491


HAWAII

Honolulu

INS: Immigration Status Verifier
595 Ala Moana Boulevard
P.O. Box 461
Honolulu, HI 96813


ILLINOIS

Chicago

INS: Immigration Status Verifier
10 West Jackson Boulevard, Room 222
Chicago, IL 60604

Phone: 312-886-0909
Fax: 312-353-7260


INDIANA

Indianapolis

INS: Immigration Status Verifier
Gateway Plaza, Room 400
950 North Meridian Street
Indianapolis, IN 46204

Phone: 317-226-6009


LOUISIANA

New Orleans

INS: Immigration Status Verifier
Postal Service Building
Room T-8005
701 Loyola Avenue
New Orleans, LA 70113

Phone: 504-589-6614 / 6615
Fax: 504-589-4451


MAINE

Portland

INS: Immigration Status Verifier
739 Warren Avenue
Portland, ME 04103

Phone: 207-780-3443 / 3266
Fax: 207-780-3481


MARYLAND

Baltimore

INS: Immigration Status Verifier
Equitable Tower 1, 12th Floor
100 South Charles Street
Baltimore, MD 21201

Phone: 410-962-2436 / 2437
Fax: 410-962-9229


MASSACHUSETTS

Boston

INS: Immigration Status Verifier
JFK Federal Building
Government Center
Boston, MA 02203

Phone: 617-565-3046 / 3048


MICHIGAN

Detroit

INS: Immigration Status Verifier
Federal Building
333 Mt. Elliott Street
Detroit, MI 48207

Phone: 313-568-6012
Fax: 313-568-6014


MINNESOTA

St. Paul

INS: Immigration Status Verifier
2901 Metro Drive, Suite 100
Bloomington, MN 55425

Phone: 612-335-2235 / 2236
Fax: 612-335-2262


MISSOURI

Kansas City

INS: Immigration Status Verifier
9747 N. Conant Avenue
Kansas City, MO 64153

Phone: 816-891-0640
Fax: 816-891-7006

St. Louis

INS: Immigration Status Verifier
Robert A. Young Federal Building
1222 Spruce Street, Room 1100
St. Louis, MO 63103-2815

Phone: 314-539-2534 / 2535
Fax: 314-539-2539


MONTANA

Helena

INS: Immigration Status Verifier
2800 Skyway Drive
Helena, MT 59601

Phone: 406-449-5428
Fax: 406-449-5752


NEBRASKA

Lincoln

INS: Immigration Status Verifier
850 S Street
Lincoln, NE 68508

Omaha

INS: Immigration Status Verifier
3736 S. 132nd Street
Omaha, NE 68144

Phone: 402-697-9302 / 9305
Fax: 402-697-9064


NEVADA

Las Vegas

INS: Immigration Status Verifier
3373 Pepper Lane, Room 104
Las Vegas, NV 89120

Phone: 702-388-6626
Fax: 702-784-5899


NEW JERSEY

Newark

INS: Immigration Status Verifier
Federal Building, Room 304
970 Broad Street
Newark, NJ 07102

Phone: 201-645-4537 / 4538 / 4539
Fax: 201-645-3543


NEW YORK

Albany

INS: Immigration Status Verifier
U.S. Post Office & Courthouse
445 Broadway
Room 220
Albany, NY 12207

Phone: 518-431-0320
Fax: 518-472-4531

Buffalo

INS: Immigration Status Verifier
130 Delaware Avenue
Buffalo, NY 14202

Phone: 716-551-4741, ext. 4218 / 4627 / 4207

New York

INS: Immigration Status Verifier
26 Federal Plaza, Room 7-130
New York, NY 10278

Phone: 212-264-5872
Fax: 212-264-2189

NORTH CAROLINA

Charlotte

INS: Immigration Status Verifier
6 Woodlawn Green, Suite 138
Charlotte, NC 28217

Phone: 704-523-1704


OHIO

Cleveland

INS: Immigration Status Verifier
1240 E. 9th Street, Room 1917
Cleveland, OH 44199

Phone: 216-522-2268 / 2612
Fax: 216-522-7039


OKLAHOMA

Oklahoma City

Contact the Dallas, TX office:

INS: Immigration Status Verifier
8101 Stemmons Freeway
Dallas, TX 75247

Phone: 214-655-3073 / 3080
Fax: 214-655-3052


OREGON

Portland

INS: Immigration Status Verifier
Federal Office Building
511 Northwest Broadway
Portland, OR 97209

Phone: 503-326-7186
Fax: 503-326-7182


PENNSYLVANIA

Philadelphia

INS: Immigration Status Verifier
1600 Callowhill Street
Philadelphia, PA 19130

Phone: 215-656-7184 / 7185
Fax: 215-656-7200

Pittsburgh

INS: Immigration Status Verifier
2130 Federal Building
1000 Liberty Avenue
Pittsburgh, PA 15222

Phone: 412-644-4552
Fax: 412-644-6375


PUERTO RICO

San Juan

INS: Immigration Status Verifier
GPO Box 5068
San Juan, PR 00936

Phone: 809-766-5276 / 5021
Fax: 809-766-5838


RHODE ISLAND

Providence

INS: Immigration Status Verifier
200 Dyer Street
Providence, RI 02903

Phone: 410-454-2865


TENNESSEE

Memphis

INS: Immigration Status Verifier
1341 Sycamore View
Memphis, TN 38134

Phone: 901-544-3089
Fax: 901-544-4123


TEXAS

Dallas

INS: Immigration Status Verifier
8101 Stemmons Freeway
Dallas, TX 75247

Phone: 214-655-3073 / 3080
Fax: 214-655-3052

El Paso

INS: Immigration Status Verifier
1545 Hawkins Boulevard
El Paso, TX 79925

Phone: 915-540-1776

Harlingen

INS: Immigration Status Verifier
2102 Teege Avenue
Harlingen, TX 78550

Phone: 210-427-8922
Fax: 210-423-7147

Houston

INS: Immigration Status Verifier
509 North Sam Houston Parkway
Houston, TX 7707

Phone: 713-847-7964

San Antonio

INS: Immigration Status Verifier
8940 Fourwinds Drive
Suite 2020
San Antonio, TX 78239

Phone: 210-871-7065 / 7037 / 7038 / 7039


UTAH

Salt Lake City

INS: Immigration Status Verifier
5272 South College Drive, Suite 100
Salt Lake City, UT 84123

Phone: 801-265-8892


VERMONT

St. Albans

INS: Immigration Status Verifier
Federal Building
P.O. Box 328
St. Albans, VT 05478

Eastern Service Center

INS: Immigration Status Verifier
75 Lower Welden Street
St. Albans, VT 05479-0001

Phone: 802-527-3160


VIRGINIA

Norfolk

INS: Immigration Status Verifier
5280 Hannamon Drive
Norfolk, VA 23513

Phone: 804-858-6292

Washington, DC Processing Center

INS: Immigration Status Verifier
4420 North Fairfax Drive
Arlington, VA 22203

Phone: 202-307-1501


VIRGIN ISLANDS

Charlotte Amalie

INS: Immigration Status Verifier
P.O. Box 610
St. Thomas, VI 00804

Phone: 809-774-1390
Fax: 809-776-4981


WASHINGTON

Seattle

INS: Immigration Status Verifier
815 Airport Way South
Seattle, WA 98134

Phone: 206-553-7928 / 2319
Fax: 206-553-2730


WISCONSIN

Milwaukee

INS: Immigration Status Verifier
Federal Building, Room 186
517 E. Wisconsin Avenue
Milwaukee, WI 53202

Phone: 414-297-3565




*1* The rules discussed in this chapter regarding documenting
citizenship status also apply to the parent(s) borrowing a Federal
PLUS Loan.

*2* The process of documenting citizenship status should not be
confused with the process of verifying financial and household data.
Although verification is required only for students selected by the
CPS, documentation of citizenship status (either on the SAR or on an
INS document) is required of all permanent residents and eligible
noncitizens other than citizens of Palau, the Federated States of
Micronesia, and the Marshall Islands.

*3* The school may not be able to use Secondary Confirmation to
resolve the conflict if the student's status was confirmed through
Primary Confirmation.

*4* The term "temporary" as used here refers to the documentary
evidence. It is not intended to imply that the immigration status itself
is temporary.