Separation of Income
To reflect a student’s (or parents) financial situation properly when a change in family status occurs between the prior calendar tax year and the current time period, a Separation of Income form is required. This form enables the student (or parent) to assess the dollar amount of funds reported on the prior year tax return and/or FAFSA that are attributable to the student (parent).
This amount is then used in the EFC calculation, as it more accurately reflects the student’s (or parents) financial situation.
Conflicting and Inaccurate Information
If the results of the FAFSA indicate that further verification is needed, such as citizenship proof, proof of non-citizen eligibility, or proof of registration with Selective Service, additional documentation may be required. The Financial Aid Office is required to resolve conflicting data if there is a reason to believe that any information on an application used to calculate the EFC is inaccurate.
Filing a Tax Extension
When a student files a tax extension, proof of the filed extension must be provided. This consists of the documentation the student received from the IRS when the extension was filed. Once the taxes have been filed, the student must provide a copy of the tax transcript to the Financial Aid Office. No interim disbursements of financial aid will be made for students who are selected for verification while they are completing the verification process.
Time Limits
- There is no time limit for evaluating information to determine if a conflict exists
- The University will resolve the conflict expeditiously
- The University will not disburse aid (or make additional disbursements of aid) until the conflict is resolved
- No further action is needed if
- All aid for the period of enrollment has been disbursed
- At the time of disbursement, there was no conflicting information
- The student is no longer enrolled at the University and has not told the University they intend to re-enroll
- Post Withdrawal Disbursement: If aid remains to be disbursed, the University will resolve the conflict before making the late or post withdrawal disbursement
Handling Conflicts in Taxable Income
- Determine if the applicant/spouse/parent(s) were required to file a tax return
- Determine if the student/parent filed using the correct filing status
- For example, one individual filed as Married Filing Separately, but both claimed Head of Household
- Determine if interest and dividend income or capital gains are reported on the income tax return, but there are no assets are reported on the FAFSA
- Compare the verification worksheet and the tax transcript to the FAFSA/ISIR
- Inconsistent information represents conflicting information
- If the FAFSA or the ISIR disagrees with the income tax transcript, either the FAFSA/ISIR or the income tax return must be corrected
- The Financial Aid Office can insist the family submit a corrected tax return and then submit to the University an IRS generated tax transcript
- Aid will not be disbursed until the conflict is resolved
- Determine if a conflict exists regarding the relationship reported in the exemption section of the tax return and other information reported
- Verify Social Security Numbers reported by student and/or parents
- Verify marital status reported by student and/or parents
- Determine if a person was claimed as a tax exemption by more than one person
- Determine if the applicant reported a low income figure
- Determine if untaxed income needs to be resolved
Resolution Documentation
The University is required to document the resolution regarding conflicting information, including what it determines the correct information to be. This may be confirmation that an earlier determination is correct.
Examples of documentation to support resolution of conflicting information include:
- A signed federal tax transcript
- A letter from the tax preparer or accountant that adequately explains the situation
- A letter from the IRS
- A signed statement from the student/spouse/parent(s)
- FAFSA/ISIR with information corrected by the student or
- An IRS generated letter to reflect the data from an amended tax return
Referral of Fraud Cases
Suspicion of financial aid fraud should be reported to the Human Resources and Student & Financial Services leadership teams. The University refers for investigation to U.S. Department of Education’s Office of Inspector General (OIG) any credible information indicating that a Title IV aid applicant, school employee, or third-party servicer may have engaged in fraud or other criminal misconduct in connection with the Title IV programs.
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