I'm an independent student who filed a 1040A last year so I was not
required to answer questions about assets on the FAFSA application. I
had very little income last year and have a zero EFC. I reported taxes
on capital gains and now my school is asking for information about my
investment assets (which are about $40,000). Can they use this to
lower my federal grant amount? I guess they can use whatever rules
they want about their own grants, but I want to be sure that this will
not impact my eligibility for Pell Grants.
— Ethan G.
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Federal law and regulations grant college financial aid administrators
the authority to request information and documentation from financial
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aid applicants. Assuming that the information reported on the
financial aid application is accurate and that there is no unreported
income, this is unlikely to affect eligibility for federal student
aid. It may affect eligibility for the college's own grant funds,
depending on the college's policies.
The college is asking for more information as part of a process called
. Verification is designed to detect and resolve
errors and discrepancies on the Free Application for Federal Student
Aid (FAFSA). Previously up to 30 percent of all FAFSAs were selected
by the US Department of Education for verification. College financial
aid staff can select additional FAFSAs for verification at their
discretion. Some colleges even select all FAFSAs for verification.
The US Department of Education is transitioning to a targeted
verification system where specific data elements on the FAFSA are
selected for verification based on a risk model. There will no longer
be a minimum or maximum number of FAFSAs selected for
verification. College financial aid administrators can continue to
choose to verify additional FAFSAs, even every FAFSA.
There are several possible reasons why your FAFSA may have been
selected for verification. FAFSAs are often selected for verification
when there is an apparent discrepancy involving income and assets. For
example, a potential discrepancy arises when capital gains,
interest and dividends are reported on the federal income tax return
but no assets are reported on the FAFSA. FAFSAs can also be selected
for verification when the applicant appears to have insufficient
income to pay for basic living expenses. These FAFSAs are selected for
verification because of the likelihood of unreported assets and
The mismatch between capital gains on the federal income tax return
and the lack of assets on the FAFSA may have been caused by the
simplified needs test.
The simplified needs test causes assets to be disregarded on the
FAFSA. To qualify for the simplified needs test, the income reported
by the student and the student's spouse (if the student is
independent) or the student's parents (if the student is dependent)
must be less than $50,000. Income is based on adjusted gross income
for tax filers and earned income for those not required to file a
federal income tax return. In addition, they must each have filed or
been eligible to file an IRS Form 1040A or 1040EZ (or were not
required to file an income tax return), or one of them must have been
a dislocated worker, or someone in the household size must have
received certain federal means-tested benefits during the past two
years (e.g., SSI, Food Stamps, Free and Reduced Price School Lunch,
This apparent discrepancy can be explained by the simplified needs
test, since the applicant is not required to report assets. Often the
models that trigger verification look for simplistic mismatches, such
as an amount of assets reported that seems inconsistent with the
capital gains and interest/dividend income reported on the income tax
return. This also potentially explains the lack of income, since an
applicant with assets can survive off of the assets and student aid
Authority to Request Documentation
Regardless of the reason for selecting a FAFSA for verification, the
college has the absolute authority to request such documentation as they
see fit in connection with the FAFSA. If a student or parent refuses
to provide this documentation, the student will be denied financial
The authority to request documentation comes from multiple
sources. First, the signing statement on the FAFSA provides this authority:
If you are the parent or the student, by signing this application you
certify that all of the information you provided is true and complete
to the best of your knowledge and you agree, if asked, to provide
information that will verify the accuracy of your completed form. This
information may include U.S. or state income tax forms that you filed
or are required to file. Also, you certify that you understand that
the Secretary of Education has the authority to verify information
reported on this application with the Internal Revenue Service and
other federal agencies.
Section 479A(a) of the Higher Education Act of 1965 also grants the
college financial aid administrator the authority to request documentation.
In addition, nothing in this title shall be interpreted as limiting
the authority of the student financial aid administrator in such cases
to request and use supplementary information about the financial
status or personal circumstances of eligible applicants in selecting
recipients and determining the amount of awards under this title.
The regulations also grant authority to the college financial aid
administrator to request documentation. For example, the regulations
at 34 CFR 668.51(b) states "Applicant responsibility. If the Secretary
or the institution requests documents or information from an applicant
under this subpart, the applicant shall provide the specified
documents or information." The regulations at 34 CFR 668.54(a)(5)
also state that "An institution or the Secretary may require an
applicant to verify any data elements that the institution or the
The college financial aid administrator is
required to request documentation if he or she believes that the
information reported on the FAFSA is inaccurate. For example, the
regulations at 34 CFR 668.54(a)(3) state "If an institution has
reason to believe that any information on an application used to
calculate an EFC is inaccurate, it shall require the applicant to
verify the information that it has reason to believe is inaccurate."
The regulations at 34 CFR 668.16(f) require colleges to have an
adequate system for identifying and resolving discrepancies in all the
information available to the college about a financial aid applicant,
including discrepancies between the income tax returns and the FAFSA.
If the application fails to provide the documentation within a
reasonable time period as specified by the college, the regulations at
34 CFR 668.60(b)(1) and 34 CFR 668.60(c)(2) prohibit the college from
disbursing any further federal student aid to the student, including
grants, loans and student employment. The student will also be
required to repay any federal student aid already disbursed. The
regulations at 34 CFR 668.60(d) also preclude processing any
subsequent year's FAFSAs until the applicant provides the requested