ES4322 - Institutional Selection for Aggregate Verification

1. Institutional Regulations
   1. At the discretion of the Institution, the DMACC Financial Aid Office will institutionally select applicants for aggregate verification of the data contained on the FAFSA.
   2. Institutional selection for aggregate verification will be required if a student is suspected of an attempt to engage in fraud, a student’s educational purpose is in question, or other criminal misconduct is suspected in connection with his or her application for Financial Aid.
   3. Aggregate verification is defined in the same manner utilized by the U.S. Department of Education, Federal Student Aid. All requirements set forth for the Aggregate Verification Group, as outlined under federal regulation, will be enforced for those students selected by the institution.
   4. Acceptable documentation utilized to complete aggregate verification is defined in the same manner utilized by the U.S. Department of Education, Federal Student Aid.
   5. All other verification requirements to include deadlines, allowable tolerances, and interim disbursement rules, apply.
   6. The criteria used to establish an institutional selection for aggregate verification include (but are not limited to):
      1. Suspected false claims of independent student status.
      2. Suspected false claims of citizenship.
      3. Suspected use of false identities.
      4. Suspected forgery of signatures of certifications.
      5. Suspected false statements of income.
      6. Suspected use of “application rings”, whereas one individual uses multiple identities and/or individuals to apply for financial aid for the purposes of accessing federal or state aid dollars.
      7. Repeated and continual phone contacts by suspected individuals concerning the disbursement of financial aid credit balances.
      8. Inaccurate or non-functional phone numbers or addresses used during the application process.
      9. Multiple Financial Aid or DMACC Admission applications originating in areas not commonly served by DMACC on or close to the same date.
      10. Applications for Financial aid or Admission originating from areas, regions, or locations previously identified as containing suspected fraudulent activity.
      11. Multiple Financial Aid or DMACC Admission applications originating with similar characteristics including but not limited to addresses, phone numbers, or e-mail addresses.
2. Procedure
   1. DMACC students must complete the Free Application for Federal Student Aid (FAFSA), prior to June 30th of each award year.
   2. The Application Support Analyst in the Financial Aid Office will establish a weekly query/report to be provided to a Financial Aid Specialist identifying the application information utilized on each ISIR and corresponding Application for Admissions received by unique ID. The Financial Aid Specialist will review the report and identify ISIR’s utilizing the same or similar characteristics including but not limited to those identified in I(F).
   3. The designated Financial Aid Specialist will identify suspected fraudulent activity based on the provided report(s) and communicate his or her findings to a Financial Aid Advisor or Director. The Advisor or Director will make the final determination of institutional selections for aggregate verification.
   4. Each Financial Aid Office staff member will be recommended to attend annual training to recognize fraudulent activity in Title IV aid. Each staff member will make recommendations to an Advisor or Director if he or she suspects fraudulent activity to include but not limited to the characteristics identified in I(F). If a recommendation is made, the Advisor or Director will make the final determination of institutional selection for aggregate verification.
   5. In the event a student is institutionally selected for aggregate verification, comments and details outlining the selection for institutional verification will be made by the designated Financial Aid Specialist using RHACOMM within Banner. Selection will only be made on a case-by-case basis.
   6. The designated Financial Aid Specialist will send an “Institutionally Selected for Verification Letter” to each student via regular US Mail or student email. Pending requirements will be added to RRAAREQ allowing the student to complete the aggregate verification process.
   7. Verification will be completed by the verification processors within the Financial Aid Office.
   8. DMACC will refer for investigation to the 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 an aid application. Students suspected of fraud or other criminal misconduct that have been referred for investigation will not be offered any form of federal or state aid by DMACC.