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2026-2027 ISIR Review and Verification Policy (FINAID 100-010)

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Image of the Baker College logo (Red on White background) Baker College Policy

Policy # FINAID 100-010 2026-2027 ISIR Review and Verification Policy

Responsible Oversight: VP of Financial Aid

Date of Current Revision / Creation: January 27, 2026

1.0 Purpose

The purpose of this policy is to ensure compliance with Title IV Verification Regulations and to ensure that students receive the federal financial aid they are eligible for by confirming the accuracy of information provided on the Free Application for Federal Student Aid (FAFSA).

2.0 Definitions

FA-DDX - The FUTURE Act Direct Data Exchange (FA-DDX) is a tool that allows the Internal Revenue Service (IRS) to directly transfer federal tax information (FTI) to the Free Application for Federal Student Aid (FAFSA) form. The FA-DDX is a result of the Fostering Undergraduate Talent by Unlocking Resources for Education (FUTURE) Act, which amended the Internal Revenue Code (IRC).

FAFSA - The Free Application for Federal Student Aid (FAFSA) is a form that students use to apply for federal financial aid, such as grants, work-study, and loans. It's the first step in the financial aid process and is also used by most states and colleges to award non federal aid.

FPS - The FAFSA Processing System (FPS) is a system that determines eligibility for federal student aid based on the Free Application for Federal Student Aid (FAFSA). The FPS is part of the Federal Student Aid (FSA) program, which is managed by the U.S. Department of Education.

FSA - Federal Student Aid (FSA), an office of the U.S. Department of Education, provides student financial assistance in the form of grants, loans and work-study funds.

FTI - Federal Tax Information (FTI) is data provided automatically from the IRS after consent and approval is provided by the student, spouse, parent or parent’s spouse during the FAFSA completion process.

Federal Register - The Federal Register is the official daily publication of the United States federal government that informs the public of changes to federal law.

ISIR - An Institutional Student Information Record (ISIR) is an electronic document that contains information about a student's Free Application for Federal Student Aid (FAFSA). The ISIR is sent to the schools that the student designated on the FAFSA. The ISIR is used to determine a student's eligibility for federal financial aid and to package, award, and originate that aid.

Verification - Verification is the process used by the institution to check the accuracy of the information the student and, in the case of a dependent student, the student's parents, provided when applying for Title IV federal student aid via the Free Application for Federal Student Aid (FAFSA).

3.0 Scope

This policy applies to all students who complete the Free Application for Federal Student Aid (FAFSA) and are subject to verification or ISIR review. The Financial Aid Department is responsible for administering this policy, including its implementation, documentation requirements, and compliance monitoring.

The Vice President of Financial Aid is responsible for approving any exceptions to required documentation. This policy will be reviewed annually and updated as necessary to reflect changes in federal regulations and institutional practices.

4.0 Policy Statement

This policy and procedure is designed to ensure that Baker College adheres to federal regulations and maintains the integrity of the financial aid process, ultimately supporting student success through accurate and timely financial aid administration.

Institutional Student Information Record (ISIR) Review

All ISIRs received by the financial aid office will be reviewed for accuracy and completeness only after a student record has been created in Jenzabar. Typically student records are created after the student is admitted to Baker College.

Dependent students who file the FAFSA indicating Direct Unsubsidized loans only based on the parent's refusal to provide FAFSA information, will be sent a Parent Refusal form to determine their eligibility prior to packaging.

ISIRs received for students prior to admission will be referred to the admissions office for outreach and guidance on the application process.

The financial aid office will implement a standardized review process, ensuring consistency and compliance with federal guidelines.

Any discrepancies identified during the review will be addressed promptly, including reaching out to students for clarification or additional documentation.

General Verification Policy Statements

Baker College follows the requirements published in the Federal Register, Dear Colleague Letters, Electronic Announcements and the FSA Application and Verification guide which are published annually on the FSA Knowledge Center. These documents detail acceptable documentation for Free Application for Federal Student Aid (FAFSA®) information subject to verification for a given award year.

Baker College follows the resolution requirements as stated in the ISIR Guide and SAR Comment Codes and Text document available on the FSA Partner Connect Knowledge Center.

Verification Selection

All applications selected by the Federal Processing System (FPS) will be verified according to the requirements of the verification group they are selected into.

Applications with conflicting information that needs to be resolved will also be verified. This includes:

C-Code resolution as indicated within the ISIR Guide.
Other data conflicts based on a review of ISIR’s received - examples include:
- The amount of income from work exceeds IRS filing thresholds, but tax filing status is blank.
- Manual tax data listed conflicts with FA-DDX data.
- Changes in dependency status which create a potential data conflict.
- Other conflicts as determined through the file review process.

Applications selected for verification and previously verified by another college will be re-verified by Baker College unless the student is otherwise exempt from verification.

Verification Exclusions:

Graduate students who only qualify for Unsubsidized and/or Grad PLUS loans are generally not verified, except for those selected into the V4 or V5 verification groups.

Applicants selected for verification after they are no longer enrolled and all Title IV disbursements have been made (including late disbursements).

Notification, Documentation and Deadlines

Students will be notified of missing or incomplete documentation via the Student Financial Aid Portal, email and/or letter.

Verification documents are accepted throughout the year but should be submitted promptly to ensure timely awarding of aid. Financial Aid priority dates are published for students:

Fall 2026: July 24, 2026
Spring 2027: December 11, 2026
Summer 2027: April 17, 2027

Failure to complete verification may result in the loss of federal aid, and most forms of state and institutional funds unless an allowable exception is listed in the Federal Student Aid Handbook.

Verification must be completed within the lesser of 120 days of their last date of enrollment or the deadline established in the Federal Register.

Baker College will send an official financial aid offer notification email to students upon initial awarding and for all substantial award amount changes which instructs the students to view their Student Financial Aid Portal.

Corrections, Awarding and Reporting

Baker College will use the documents the student submits to complete verification to make any necessary ISIR corrections for all non-dollar items and/or a single dollar item of $25 or more.

If corrections cannot be completed by the college, students will be contacted by phone and/or email of their responsibility to make the necessary corrections.

Baker College will not award federal aid or most forms of state or institutional aid until required verification is complete.

Baker College will use specific verification status codes to satisfy federal reporting requirements.

Blank: not selected
V: Verified
S: Selected, but not required to verify (based on verification exclusion criteria)
W: Interim disbursement without completing verification (will not be used unless approved by the Vice President of Financial Aid)

Unpaid disbursements will be canceled if a selected ISIR is received after awarding.

Fraud Prevention

Baker College will refer any student,employee, or other individual suspected of fraud to the Office of Inspector General (OIG).

5.0 Procedures

Determination of Verification Requirements

Edconnect is used to receive ISIR files which are imported into Jenzabar Financial Aid (JFA).

A series of processes and reports are established to identify conflicting information, verification groups, and C-Codes requiring resolution.

Any required documentation that students must submit to complete verification are added in JFA based on the outcomes of these processes.

ISIR records requiring a manual review are identified and added to a work queue. Any necessary documents are added manually within JFA as applicable.

Verification is determined based on the verification group, C-Code, or reason for institutional selection.

V1: Income, family size
V4: Identity Verification
V5: Identity Verification, income and family size

Verification of Income for Tax Filers

IRS data transferred through the Direct Data Exchange (FA-DDX) process is considered verified and no additional documentation will be required (unless manually entered data creates a conflict).

One of the following documents are allowable for verification of tax data:

2024 IRS Tax Transcript (signature not required) or an acceptable IRS alternative.
Signed copy of the 2024 income tax return that the filer submitted to the IRS along with any applicable IRS schedules and forms.
2024 income tax return with the relevant taxing authority of a U.S. territory, commonwealth, or with a foreign central government.
If an amended return was filed, 2024 IRS Record of Account or Form 1040X that was filed with the IRS, along with a copy of the tax return transcript or tax return with applicable schedules and forms.
Tax filers who have a marital status change after December 31st of the tax year must submit the appropriate corresponding transcripts and/or tax returns.
Tax filers who are married but file separately must submit tax transcripts or tax returns for both parties.
Additional verification options as listed in the FSA Application and Verification guide which are published annually on the FSA Knowledge Center.

Verification of Income for Non-Tax Filers

The following documents may be collected for verification of income:

W-2 Forms for each source of income or equivalent document.
The Baker College Verification Worksheet.
Verification of Non-filing letter from the IRS or a signed and dated statement certifying that the individual has not filed and is not required to file an income tax return, and a listing of the sources of any income earned by the individual from work and the amount of income from each source.
If Baker College has reason to believe that a student and/or parent are required to file a U.S. tax return, this constitutes conflicting information.
Additional verification options as listed in the FSA Application and Verification guide which are published annually on the FSA Knowledge Center.
Dependent students are exempt from submitting verification of non-filing.

Verification of Identity

Students must verify their identity as part of the financial aid verification process. The preferred method of verification is in person; however, if it is determined that the student cannot appear in person, they may complete identity verification through one of the two alternative methods described below.

In-Person Verification (Preferred Method):

The student presents a valid, unexpired government-issued photo ID to a OneStop or Financial Aid staff member.

Documentation Process:

Confirm the photo on the ID matches the student.
Photocopy the ID.
Write your name and the date received directly on the copy.
Scan the endorsed copy into OnBase as: Gov’t Issued ID Student.

Video Call Verification:

If the student cannot appear in person, they may verify their identity by showing a valid government-issued photo ID to a Financial Aid staff member during a live video call.

Documentation Process:

Ensure your own video camera is off before capturing any images.
Capture a screenshot using the Print Screen key that clearly shows:
- The student’s ID.
- Your name (as displayed in Google Meet).
- The current date and time (ensure the bottom right-hand corner of your screen/taskbar).
Paste (Ctrl + V) the screenshot into a new Word document.
Review for clarity, then print/upload to OnBase as: Gov’t Issued ID Student.
In the event that a screenshot obtained during a video session does not clearly show the identity document, the student must also submit their government-issued ID via email. Upon receipt, the FAA who verified the identity will annotate the document (name/date), then scan the document into OnBase a: Gov't Issued ID Student.

Notary Verification:

If neither in-person nor video call verification is feasible, the student may complete the Verification of Identity form in the presence of a notary public.

Documentation Process:

Verify the notary stamp and seal using the Requirements listed on the State website.
Ensure the form is complete and the attached copy of the photo ID is unexpired and matches the name on the form.
Scan both the form and the ID copy into OnBase as: Gov’t Issued ID Student.

Verification of Family Size

Students will submit the Baker College Verification Worksheet or the Baker College Family Size Worksheet, as appropriate if the student manually entered family size (was not transferred directly from the IRS or was transferred and was updated).

Exceptions to this requirement:

Applicant is dependent and applicant’s parent’s marital status is single, separated, divorced or widowed and the family size reported is two.
Applicant is dependent and applicant’s parent’s marital status is married or unmarried and living together and the family size reported is three.
Applicant is independent and the applicant’s marital status is single, separated, divorced or widowed and the family size reported is one.
Applicant is independent and the applicant’s marital status is married and the family size reported is two.

Verification of Homelessness Status

Baker College will verify homelessness status for initial applications by requesting that applicants submit the 26-27 Homeless Youth Clarification form. For additional information, please refer to the Professional Judgment policy. The College will review all requests for an independent status determination as promptly as possible, and no later than 60 days after the student enrolls or 60 days after the request is received, whichever occurs later.

Dividing Joint Tax Return Income

Baker College will use the Proportional Distribution Method for dividing income from a joint tax return if completing verification on a student/parent record and the marital status is divorced/separated with jointly filed taxes.

Documents to support the appropriate division of income and assets on the FAFSA are required (1099 forms, Pension/IRA Statements, etc.).

Proof of the marital status change is required.

Marital Status Updates

An initially dependent student’s marital status or an independent student’s marital status can be updated if Financial Aid determines that the status change will more accurately reflect the student’s ability to pay.

Additional Verification Documents

When resolving conflicting information in a file, the following documents may be used:

Asset Verification Form (student and parent).
Other documents deemed necessary for resolution.

Processing Verification

Verification documents will be reviewed and compared to the ISIR data in JFA.

Necessary ISIR corrections will be made using FPP or JFA's "Edit Record" function.

Once verification is complete, the ISIR transaction will be frozen, and the verification status will be updated to "Verified."

Reporting of Identity Verification to FPS

To ensure compliance with federal reporting requirements for students selected for identity verification (V4/V5 tracking groups), Baker College tracks the resolution and manually updates the results in FAFSA Partner Portal (FPP) using the Verification of Identity results link.

The reporting occurs through two primary workflows: during the individual student verification process and a comprehensive monthly review.

The V4/V5 reporting lists available in FPP will be used to determine which students must be reported.
There are separate lists available for all campus codes (004673, E40395 and E40396).
Manually review each student’s Verification of Identity document type in JFA to determine how the verification was completed (In person, video or notary) and update the results in FPP to indicate the appropriate response.
The lists with the results reported are maintained in FPP.
A monthly query will be run to identify students who have had 60 days to respond, but have not completed the Verification of Identity requirement. The response in FPP will be ‘No response from applicant or unable to locate.’ If the student later completes the verification requirement the status will be changed in FPP to the appropriate response.

Determination of Parent Refusal Eligibility

Dependent students selecting Direct Unsubsidized Loans only due to parent refusal are sent the parent refusal form to determine eligibility prior to packaging.
If the parents refuse to sign a statement confirming this, the student must provide third-party documentation (such as from a teacher, counselor, cleric, or court) confirming the situation. Statements from the student alone will not be sufficient.
Through a review of the documentation provided, Financial Aid may make a determination that the situation warrants a professional judgment rather than parent refusal. If this determination is made, the professional judgment process will be completed.

Notification of Changes

Students will be notified via email of any changes to their award amounts resulting from verification.

Handling Subsequent ISIR's Selected for Verification

Future disbursements of federal or state aid which require verification to be completed will be canceled, and the student will have 120 days to submit verification documents.

Failure to submit documents for enrolled students will result in the reporting of over-awards and loss of eligibility for federal aid.

If verification is completed and results in a change to the student’s eligibility, disbursed aid and future disbursements will be adjusted accordingly. Students will be sent notification of these award changes via email.

Fraud Referral

Baker College will refer to the Office of Inspector General (OIG) any students, employees or other individuals who are suspected of misreporting or altering documentation to fraudulently obtain federal funds. Baker College will contact the Ann Arbor Office at (734) 330-2059 or file online via the U.S. Department of Education Office of Inspector General website.

6.0 Responsibilities

Vice President of Financial Aid

Approval of the annual policy
Maintain regulatory compliance of the policy

Director of Financial Aid Advising / Director of Financial Aid Operations

Develop and review policies and procedures annually
Train staff annually on the policy
Comply with policies and procedures when completing file reviews and verification

Financial Aid Advisors / Specialists