Noncitizens are eligible for federal aid through the FAFSA application if they fall within specific classifications—such as permanent resident, conditional entrant, or refugee, etc.—and provide a valid Alien Registration number that is verified by the Department of Homeland Security (DHS). While the vast majority pass the initial identity verification, those who don’t undergo a secondary process and an even smaller percentage take a third step through the Systematic Alien Verification for Entitlements system (SAVE) if needed. Unfortunately, this secondary confirmation process remains inactive, according to Kerry Mosley-Hobbs, a Policy Specialist for Federal Student Aid, who made the statement during NASFAA’s Virtual Session on July 9th.
The secondary confirmation typically involves Financial Aid administrators seeing Comment Code 155 on an applicant’s ISIR if they did not pass DHS’ first verification attempt; then, a pushed ISIR arrives within 10 business days (often less, depending on confirmation) to determine if the third step is needed. However, for the 2024-25 academic year, this process is not available through the Federal Processing System (FPS) because current contracts with the Department of Homeland Security only allow one platform to perform this task, and CPS is currently being used for 2023-24. This policy has effectively placed these FAFSA applications in limbo, will cause significant delays beyond the traditional timeframe that administrators are accustomed to, and will prevent these students from receiving any financial aid they qualify for.
In early May, FSA acknowledged the issue and stated that “the DHS secondary match process will be available in the near future, and we will notify schools by posting additional updates to the Knowledge Center.” Still, two months have passed and it is still unclear if there are any potential workarounds or when the Department of Education plans to resolve the problem. FSA is currently developing a timeline, according to Mosley-Hobbs, but she could not provide any indication as to when this would be released to the general public.