Federal Student Aid Verification, Comment Code, and ISIR Resolution Policy

1. Policy Statement

Verification and ISIR resolution are processes used by The New School (TNS), through its Office of Financial Aid (OFA), to confirm the accuracy and completeness of information used to determine a student's eligibility for federal student aid and to resolve issues identified through the Free Application for Federal Student Aid (FAFSA®), Institutional Student Information Record (ISIR), federal comment codes, institutional records, and other reliable information.

Verification requirements apply to students selected by the Federal Student Aid Processing System (FPS) and, when applicable, to students selected by TNS in accordance with federal requirements and consistently applied institutional policies.

ISIR resolution includes the review and resolution of federal comment codes, conflicting information, FAFSA data discrepancies, eligibility-related messages, and other issues identified through an ISIR or subsequent FAFSA transaction. The presence of a comment code or other ISIR message does not, by itself, establish that verification is required or that a FAFSA correction must be made. The OFA will evaluate the underlying issue and applicable federal requirements to determine the appropriate action.

TNS administers verification and ISIR resolution in accordance with applicable federal laws and regulations, including the Higher Education Act of 1965, as amended, 34 CFR Part 668, Subpart E, applicable Federal Register notices, and the U.S. Department of Education's Federal Student Aid Handbook and other applicable Federal Student Aid guidance.

For each award year, the OFA will follow the verification, FAFSA correction, and eligibility requirements published by the U.S. Department of Education. Federal requirements may include the information to be verified, acceptable documentation, verification tracking groups, comment-code resolution, conflicting-information resolution, deadlines, corrections, tolerances, disbursement requirements, recordkeeping requirements, and applicable exclusions.

The OFA will administer these requirements consistently and will maintain documentation sufficient to demonstrate the basis for verification determinations, ISIR and comment-code resolution, FAFSA corrections, conflicting-information resolution, and related financial aid actions.

2. Policy

TNS administers federal student aid verification and ISIR resolution in accordance with federal Title IV requirements and the U.S. Department of Education's Federal Student Aid (FSA) guidance.

Verification is the process through which the institution confirms the accuracy of specified information reported on a student's FAFSA when the student's application is selected for verification by the Federal Student Aid Processing System (FPS). Verification may also be required when TNS selects a student for verification in accordance with applicable federal requirements and consistently applied institutional policies.

ISIR resolution is the process through which the OFA reviews and resolves issues identified on an ISIR, including federal comment codes, conflicting information, FAFSA data discrepancies, eligibility-related messages, and other information that may affect a student's eligibility for Title IV aid. ISIR resolution may require documentation, a FAFSA correction, resolution of conflicting information, verification, review of federal data, or another action permitted or required under federal guidance.

The OFA will distinguish among verification requirements, comment-code resolution, conflicting information, FAFSA corrections, professional judgment, and other financial aid processes. Completion of one process does not necessarily resolve an issue arising under another process.

Verification applies to the following Federal Title IV programs:

• Federal Pell Grant;

• Federal Supplemental Educational Opportunity Grant (FSEOG);

• Federal Work-Study (FWS); and

• Direct Subsidized Loans.

A student who is eligible only for unsubsidized Title IV assistance generally is not required to complete V1 verification. However, a student selected by the FPS for V4 or V5 must complete applicable identity verification requirements. For a V5 student who is eligible only for unsubsidized assistance, only identity verification is required; the remaining V5 income, tax, and family-size items need not be verified, consistent with applicable federal requirements.

A student who is eligible for both subsidized and unsubsidized Title IV aid may not avoid verification by declining subsidized aid and accepting only unsubsidized aid. When verification is required, the student must complete the applicable verification requirements before receiving Title IV aid, subject to any federal provisions governing interim or other permissible disbursements.

The verification tracking group assigned by the Department determines the information the OFA must verify. The Department assigns selected FAFSA filers to one of the following groups:

• V1 — Standard Verification Group: Requires verification of specified FAFSA information, including applicable income, tax, and family-size information.

• V4 — Custom Verification Group: Requires verification of the student's identity.

• V5 — Aggregate Verification Group: Requires verification of applicable V1 information and the student's identity.

Students selected solely by TNS are not assigned a federal verification tracking group unless the FPS has separately selected the FAFSA. TNS will identify the specific FAFSA information subject to school-selected verification and will apply its institutional requirements consistently and in accordance with applicable federal requirements.

The OFA will review applicable ISIRs, including federal comment codes and other eligibility-related messages, to determine whether additional action is required. Depending on the nature of the issue, the OFA may:

• Require verification or additional documentation;

• Resolve conflicting information;

• Request clarification or documentation from the student or parent;

• Submit a FAFSA correction;

• Review a subsequent ISIR;

• Recalculate the student's Student Aid Index (SAI) or federal aid eligibility;

• Adjust, cancel, or reinstate federal aid when required; or

• Determine that no further action is required.

The OFA will not require documentation solely because a comment code appears on an ISIR when federal guidance does not require documentation and the underlying issue can otherwise be resolved using available federal data, institutional records, or other reliable information.

TNS will provide students selected for verification or otherwise required to take action on an ISIR with timely notification of the information and documentation required, applicable deadlines, and the consequences of failing to complete the required action.

If verification, ISIR review, comment-code resolution, or conflicting-information resolution results in changes to information used to determine the student's eligibility or award amount, TNS will make required FAFSA corrections and financial aid adjustments in accordance with federal requirements before or as part of the applicable disbursement, reconciliation, or other required financial aid process.

TNS will maintain documentation supporting the completion of verification and the resolution of ISIR-related issues and will administer verification, ISIR review, comment-code resolution, FAFSA corrections, and related processes consistently and in accordance with applicable federal regulations, Federal Student Aid guidance, and institutional policies and procedures.

2.1 Institutional Selection and ISIR-Identified Issues

TNS may select a student for verification when the OFA has reason to believe that FAFSA information may be inaccurate or when TNS elects to verify additional FAFSA information pursuant to applicable federal requirements and consistently applied institutional policies.

School-selected verification will be administered in accordance with applicable federal requirements, including requirements governing the information to be verified, acceptable documentation, deadlines, corrections, tolerances, and disbursement of Title IV aid.

The OFA may also identify a student for additional review based on information contained in an ISIR, including federal comment codes, eligibility-related messages, conflicting information, discrepancies between FAFSA information and institutional records, or other information received from a reliable source. An ISIR-identified issue will be evaluated based on the underlying circumstances and applicable federal requirements.

An ISIR comment code or other federal message does not automatically constitute a verification requirement. The OFA will determine whether the issue requires:

• Verification;

• Documentation or clarification from the student or parent;

• Resolution of conflicting information;

• A FAFSA correction;

• Review of a subsequent ISIR;

• Recalculation of the student's Student Aid Index (SAI) or federal aid eligibility; or

• No further action.

When an ISIR-identified issue requires student action, the OFA will notify the student of the information or documentation required and the applicable institutional deadline. When federal requirements require resolution of the issue before Title IV aid may be awarded or disbursed, the OFA will complete the required review or correction before proceeding with the applicable aid action.

The OFA will document the basis for institutional selection, the nature of the ISIR-identified issue, the information or documentation reviewed, the action taken, and the final resolution in the student's financial aid record.

Institutional selection for verification and ISIR resolution will be applied consistently and in accordance with applicable federal requirements and institutional policies. An institutional review or resolution of an ISIR issue does not replace or eliminate a federal verification requirement when the student is separately selected by the FPS for verification.

3. Notification of Verification Selection

The OFA will notify students selected for verification through the University's approved communication methods, of which email is the preferred method used by the FAO. The date and time of the notification will be recorded in Banner.

The notification will:

• Inform the student that verification is required;
• Identify the documentation required;
• Direct the student to the appropriate location in the MyNewSchool portal to view and submit required documents;
• Provide the applicable institutional deadline;
• Explain the consequences of failing to complete verification; and
• Provide instructions for contacting the OFA with questions.

4. Verification Tracking Groups

Students selected by the FPS will be assigned to one of the following verification tracking groups:

Verification Tracking Groups

V1 – Standard Verification Group

Elements required for verification are defined by whether a Federal Income tax return was filed, no Federal income tax was filed or if a foreign income tax return was filed.

V1 – Income Tax Filers

• Adjusted Gross Income (AGI);
• Income earned from work;
• U.S. income tax paid;
• Untaxed portions of IRA distributions;
• Untaxed portions of pensions;
• IRA, Pension, and Annuity Rollovers;
• IRA deductions and payments;
• Tax-exempt interest income;
• Education credits;
• Foreign income exempt from federal taxation; and
• Family size—in certain circumstances as follows, family size is not a required verification item.

Dependent student

• Family size is 2, and the parent is single, divorced, separated, or widowed.
• Family size is 3, and the parents are married/remarried or unmarried and living together.

Independent student

• Family size is 1, and the student is single, divorced, separated, or widowed.
• Family size is 2, and the student is married/remarried.

IRS-derived family size

If the applicant manually updated family size on the FAFSA, but the number they entered is the same as the family size derived from IRS data transferred through the FAFSA Direct Data Exchange (FA-DDX), family-size verification is not required.

V1 – Non-Tax Filers

For a non-tax filer, the OFA will obtain documentation required by federal guidance, which may include a signed and dated nonfiling statement, documentation of sources and amounts of income earned from work, W-2 forms or equivalent wage statements for each employer, and verification of nonfiling from the applicable tax authority when required.

The OFA will determine if the non-tax filer is required to file a tax return by referencing the IRS minimum income filing char. The chart shows the minimum income amount that requires filing by a tax payer. If the student or parent earned more than the minimum income and is required to file a Federal tax return, OFA will email the student or parent to alert them to the requirement.

V1 – Foreign or U.S. Territory Tax Filers

The FAO may accept a transcript obtained from a government of a U.S. territory or commonwealth or a foreign nation (i.e. non-IRS tax document) that includes all of the tax filer’s income and tax information required to be verified for required tax year.

Federal Tax Information (FTI)

Federal Tax Information (FTI) transferred directly from the IRS through the FUTURE Act Direct Data Exchange (FA-DDX), when applicable and unchanged, is considered verified for the applicable income and tax information. Additional documentation may still be required for information that is not transferred through the FA-DDX or that requires separate verification, such as certain rollover information.

Pension Rollover

When an untaxed IRA distribution or untaxed pension distribution includes a rollover, the rollover amount must be separately documented in accordance with federal requirements. A signed statement confirming the rollover amount is acceptable documentation.

V4 – Custom Verification Group

Students selected for the V4 verification tracking group must verify their identity in accordance with federal requirements and the procedures established by the OFA.

Acceptable identity verification methods may include:

In-person presentation of acceptable government-issued photo identification to an institutionally authorized individual;

Presentation of acceptable identification in person to a notary when the institution determines that the student is unable to appear in person; or

Video-call verification with an institutionally authorized individual when the institution determines that the student is unable to appear in person.

The OFA will maintain appropriate documentation of the identity verification process.

V5 – Aggregate Verification Group

V5 combines the requirements of the V1 Standard Verification Group and the V4 Custom Verification Group.

5. Verification Documentation

Documentation must be sufficient to establish the accuracy of the FAFSA information being verified.

5.1 Tax Information

Acceptable documentation may include, as applicable:

• Federal Tax Information received through the FA-DDX;
• IRS tax transcripts;
• Foreign or U.S. territory tax documentation;
• Signed copies of federal or foreign tax returns;
• W-2 forms;
• Signed statements from tax filers or non-tax filers;
• Family-size statements;
• Government-issued photo identification; and
• Other documentation specifically permitted by federal guidance.

Documentation must be complete, legible, and sufficiently reliable to establish the information being verified.

The OFA Aid may request additional documentation when submitted materials are incomplete, inconsistent, unclear, or insufficient to resolve the information being verified.

5.2 Identity Verification

For identity verification, students must provide acceptable, unexpired government-issued photo identification.

Acceptable identification may include:

• U.S. passport;
• State-issued driver's license;
• State-issued identification card; or
• Other qualifying government-issued photo identification.

Identification issued by a college or university and military identification are not acceptable for this purpose.

When identity is verified in person, the institution must maintain an annotated copy of the acceptable identification documenting the date it was reviewed and the name of the institutionally authorized individual who reviewed it.

For remote verification, the OFA will maintain documentation consistent with federal requirements.

6. Institutional Verification Deadline

TNS requires students to complete verification within 45 calendar day from the date they are notified by TNS.

Failure to submit documentation within the institutional deadline may result in:

• Delay or withholding of federal financial aid;
• Delay in completing the student's financial aid package;
• Revision or cancellation of federal financial aid;
• A balance becoming due on the student's account; and/or
• Additional charges or consequences under applicable University policies.

7. Review and Completion of Verification

The OFA will review submitted documentation to determine whether the information reported on the FAFSA is supported by the documentation and whether corrections are required.

Verification is considered complete when:

• All applicable required documentation has been received;
• The documentation has been reviewed;
• Required verification items have been resolved;
• Any required FAFSA corrections have been submitted or otherwise resolved;
• Required identity verification has been completed, when applicable; and
• The student has satisfied all applicable federal verification requirements.

The OFA will document completion of verification in the student's financial aid record.

8. Subsequent ISIRs and Changes in Verification Status

The OFA must review subsequent ISIRs received for a student.

A student may become selected for verification on a subsequent FAFSA transaction as a result of:

• A FAFSA correction;

• New information received by the FPS;

• Changes to FAFSA data;

• Federal selection criteria.

• If a student moves from V1 or V4 to V5, the student must complete any verification requirements that were not previously completed.

If verification was completed for the prior tracking group, the student generally must verify only the additional information required for the new tracking group.

The OFA will review the student's most recent valid ISIR and determine whether additional verification or corrective action is required.

8.1 Comment Code Review and Resolution

The OFA will review applicable FAFSA Processing System (FPS) Institutional Student Information Records (ISIRs), including federal comment codes and other eligibility-related messages, to determine whether additional action is required before federal student aid may be awarded or disbursed.

Comment codes may identify potential issues involving FAFSA data, federal eligibility requirements, conflicting information, verification, unusual circumstances, identity, citizenship, dependency status, income or tax information, or other matters affecting Title IV eligibility. The presence of a comment code does not, by itself, establish that a student has failed verification or that a FAFSA correction is required. The OFA will evaluate the underlying issue and applicable federal requirements before determining the appropriate resolution.

The OFA will:

• Review applicable comment codes and accompanying ISIR messages on the student's most recent valid ISIR;

• Determine whether the comment code requires verification, resolution of conflicting information, FAFSA correction, documentation, professional judgment review, or another institutional action;

• Determine whether the issue affects the student's eligibility for Title IV aid, the amount of aid for which the student may qualify, or the timing of disbursement;

• Obtain documentation from the student when documentation is required by federal guidance or reasonably necessary to resolve the issue;

• Review documentation for completeness, consistency, and reliability;

• Resolve conflicting information before awarding or disbursing Title IV aid when required by federal regulations;

• Submit FAFSA corrections when the institution is authorized or required to do so;

• Review subsequent ISIRs generated as a result of corrections or other FAFSA transactions;

• Document the resolution and supporting rationale in the student's financial aid record; and

• Notify the student when additional action or documentation is required from the student.

8.1.1 Comment Codes Requiring Student Action

When a comment code requires action by the student, the OFA will provide the student with appropriate instructions identifying, as applicable:

• The issue requiring resolution;

• The documentation or information required;

• The method for submitting the required documentation;

• The applicable institutional deadline;

• The potential effect on federal financial aid eligibility or disbursement; and

• The OFA contact information for questions or assistance.

The OFA will not require documentation solely because a comment code appears on an ISIR when federal guidance does not require documentation and the underlying issue can be resolved through available federal data or institutional records.

8.1.2 Comment Codes Associated With Verification

When an ISIR comment code indicates that verification is required, the OFA will determine the applicable federal verification tracking group and required verification items. The student will be required to complete the applicable verification requirements before Title IV aid is disbursed, subject to applicable federal exceptions and requirements.

If the comment code identifies an issue that is separate from the student's verification tracking group, completion of verification does not eliminate the OFA's obligation to resolve the separate issue.

8.1.3 Comment Codes Indicating Conflicting Information

When a comment code identifies or contributes to conflicting information, the OFA will resolve the conflict in accordance with federal requirements before determining or disbursing Title IV aid when resolution is required.

Resolution may include:

• Reviewing FAFSA information against institutional records;

• Reviewing federal tax or other federal data available through the FAFSA/ISIR;

• Obtaining documentation or clarification from the student or parent, when appropriate;

• Determining which information is accurate based on reliable documentation;

• Submitting a FAFSA correction when required;

• Reviewing the resulting ISIR; and

• Documenting the resolution in the student's financial aid record.

A verification exclusion, waiver, or completed verification does not eliminate the requirement to resolve conflicting information when federal requirements require such resolution.

8.1.4 Comment Codes Requiring FAFSA Correction

When a comment code or the underlying circumstances establish that FAFSA information is incorrect, incomplete, or otherwise requires correction, the OFA will follow the FAFSA correction procedures in Section 9 of this policy.

The OFA will review the corrected ISIR to determine whether:

• The student's verification status has changed;

• Additional documentation or verification is required;

• The Student Aid Index (SAI) has changed;

• Federal aid eligibility has changed;

• Previously awarded or disbursed aid must be adjusted; or

• Additional conflicting information remains unresolved.

8.1.5 Documentation and Recordkeeping

For comment codes requiring institutional action, the OFA will maintain sufficient documentation to demonstrate how the issue was reviewed and resolved. Documentation may include:

• The applicable ISIR and comment code;

• Student or parent statements;

• Tax or income documentation;

• Identity or citizenship documentation, when applicable;

• Institutional records;

• Federal or government documentation;

• Correspondence with the student;

• Documentation supporting a FAFSA correction;

• The resulting corrected ISIR; and

• A case note or other institutional record describing the resolution.

The documentation will identify, as appropriate, the issue reviewed, information considered, action taken, date of resolution, and staff member responsible for the determination.

8.1.6 Subsequent ISIRs After Comment Code Resolution

When a correction or other action results in a subsequent ISIR, the OFA will review the new ISIR for additional comment codes, verification requirements, eligibility issues, or conflicting information.

Resolution of one comment code does not constitute resolution of another unrelated comment code. The OFA will address each unresolved issue based on the requirements applicable to the student's current FAFSA transaction and award year.

The OFA will use the most recent valid ISIR to determine the student's current federal eligibility and whether additional institutional action is required.

9. FAFSA Corrections

The OFA will make corrections to FAFSA information when required based on verification results, conflicting information, documentation received, or other information available to the institution. Corrections may be made by the student or, when authorized, by the OFA.

When a correction is required:

• The incorrect FAFSA information will be identified;
• Supporting documentation will be reviewed;
• The appropriate FAFSA correction will be submitted;
• The corrected information will be transmitted to the FPS;
• A new ISIR will be generated when applicable;
• The OFA will review the resulting SAI and federal aid eligibility; and
• The student's financial aid package will be adjusted when required.

A correction may result in an increase, decrease, or no change to the student's eligibility.

10. Student Aid Index and Financial Aid Recalculation

Verification may result in a change to the FAFSA information used to calculate the student's Student Aid Index (SAI).

When verification results in a change to the student's FAFSA information, the OFA will review the student's federal aid eligibility.

If the student's eligibility changes, the OFA will:

• Recalculate applicable federal aid eligibility;
• Repackage the student's financial aid when necessary;
• Reduce, cancel, or increase applicable aid as required;
• Return federal funds when required by federal regulations; and
• Notify the student of applicable changes.

Students will be notified of financial aid revisions through the MyNewSchool portal and/or official University email communication.

11. Conflicting Information

The OFA must resolve conflicting information affecting a student's eligibility for federal student aid, regardless of whether the student was selected for verification.

Conflicting information may include discrepancies between:

• The FAFSA and submitted documentation;
• The FAFSA and institutional records;
• The FAFSA and other financial aid records;
• Tax documentation and FAFSA information;
• Subsequent ISIRs; or
• Information received from another reliable source.

Verification of one FAFSA item does not eliminate the requirement to resolve other conflicting information.

The OFA will document the resolution of conflicting information in the student's financial aid record.

12. Professional Judgment

Professional Judgment (PJ) and verification are separate processes. When a student has been selected for verification, the OFA will complete applicable verification requirements before exercising professional judgment.

13. Verification Exclusions

Federal regulations identify circumstances in which a student may be excluded from completing verification or in which verification may not be required.

Examples may include:

• The student dies during the award year;

• The student will not receive Title IV aid for reasons other than failure to complete verification;

• The student is eligible only for unsubsidized student financial assistance, subject to applicable V4/V5 requirements;

• The student completed verification at another institution during the same award year and the applicable federal requirements for accepting that verification have been satisfied;

• The student has ceased enrollment, does not intend to reenroll during the award year, and will receive no additional disbursement; or

• Certain circumstances involving deceased, incapacitated, or unreachable parents or spouses, when permitted under federal requirements.

• Verification exclusions must be documented in the student's financial aid record.

An exclusion from verification does not automatically eliminate the institution's responsibility to resolve conflicting information.

14. Failure to Complete Verification

A student who does not complete required verification may be ineligible to receive or retain applicable federal student aid.

If the student fails to submit required documentation:

• Federal aid may not be disbursed;
• Pending federal aid may be placed on hold;
• Previously disbursed aid may require recalculation or return when required by federal regulations;
• The student's financial aid package may be revised;
• The student's account balance may increase; and
• The student may be responsible for outstanding institutional charges.

The OFA will provide the student with appropriate notification when failure to complete verification affects financial aid eligibility.

15. Verification and Withdrawal

If a student withdraws before completing verification, the OFA will determine whether verification must still be completed based on the student's enrollment status, aid received, potential late disbursement, and applicable federal requirements.

For Pell Grant recipients, the OFA will follow the federal verification deadlines and post-withdrawal disbursement requirements applicable to the award year.

An institutional verification deadline may not be used to deny a federal post-withdrawal disbursement when federal regulations require the institution to make the disbursement.

16. Fraud and Misrepresentation

The OFA will take appropriate action when information or documentation indicates possible fraud or intentional misrepresentation for the purpose of obtaining federal student aid.

Potential indicators may include:

• Altered or fraudulent documentation;
• Falsified tax documents;
• Identity concerns;
• Misrepresentation of income or family information;
• Falsified signatures;
• Inconsistent information that suggests intentional misrepresentation; or
• Other information indicating possible fraudulent activity.

The OFA will document the circumstances and follow applicable federal requirements and institutional procedures.

When required, suspected fraud involving federal student aid will be referred to the U.S. Department of Education's Office of Inspector General (OIG).

The OFA will not make a finding of fraud solely because information is incomplete or inconsistent. The institution will distinguish between ordinary conflicting information, documentation deficiencies, and suspected intentional fraud.

17. Reporting Verification Results

For students selected by the FPS for V4 or V5 identity verification, TNS will report verification results through the FAFSA Partner Portal.

Identity verification results must generally be reported no later than 60 days following the institution's first request for identity documentation.

The OFA will maintain documentation supporting the reported result.

18. Recordkeeping and Documentation

The OFA will maintain verification documentation in accordance with federal record-retention requirements and University policy.

Documentation may include:

• Verification worksheets or institutional forms;
• Tax documentation;
• W-2 forms;
• Family-size documentation;
• Identity documentation;
• Identity verification records;
• Student statements and certifications;
• Correspondence with students;
• Documentation of conflicting information resolution;
• Documentation supporting verification exclusions;
• FAFSA corrections;
• Verification results reported to the Department; and
• Documentation supporting fraud referrals, when applicable.

Records must be maintained in a secure manner and accessible only to authorized personnel.

19. Student Notification of Financial Aid Changes

When verification results in a change to the student's SAI or Title IV eligibility, the OFA will notify the student through the University's approved communication methods.

The notification will explain, as appropriate:

• That the student's financial aid has been revised;
• The type of aid affected;
• The revised amount;
• The reason for the revision;
• Any action required by the student; and
• The potential impact on the student's account balance.

20. Regulatory and Federal Guidance References

This policy should be read in conjunction with the following authorities and guidance:

34 CFR Part 668, Subpart E – Verification and Updating of Student Aid Application Information

34 CFR § 668.52 – Subsidized and unsubsidized student financial assistance programs

34 CFR § 668.53 – Policies and procedures

34 CFR § 668.54 – Selection of applicants for verification

34 CFR § 668.55 – Updating information

34 CFR § 668.56 – Information to be verified

34 CFR § 668.57 – Acceptable documentation

34 CFR § 668.59 – Interim disbursements

34 CFR § 668.61 – Recovery of funds

2026–27 Federal Student Aid Handbook, Application and Verification Guide, Chapter 4

2026–27 Federal Register notice identifying FAFSA information to be verified and acceptable documentation