1. Resolving INS Match Failures Pam McConahay Assoc Director, Compliance, Training & Lender Relations, University of Oklahoma SWASFAA 2002

2. Primary vs Secondary Confirmation is attempted between CPS and INS when a student indicates he is an eligible non-citizen AND he provides an Alien Registration Number (“A- Number”) If the student fails to provide A- Number, no match is attempted.

3. SSA Social Security Administration (SSA) confirms U.S. citizenship If SSA automated match fails to confirm citizenship for a U.S. citizen, documentation must be obtained by school to verify status. Documentation of U.S. citizen status is not submitted to any agency to confirm validity. The U.S. Department of State issues proof of citizenship to non-naturalized citizens, not INS or SSA.

4. INS Immigration & Naturalization Service (INS) confirms immigration status for non-citizens If INS fails to confirm eligible non-citizen status via the automated match with CPS, an automated “secondary” confirmation is attempted. If INS still can’t confirm via automated secondary confirmation, school must obtain documents and submit them to INS for paper secondary confirmation (Form G-845S)

5. Resolving Match Problems First Step---Clean Up the Record Bad demographic data Mistakes in spelling, DOB & A-Number Double match attempts Both SSA & INS databases may have been checked; if student is confirmed by either, make sure citizenship status on ISIR is correct and use the appropriate match. Clean up the ISIR via corrections

6. Automated Secondary Confirmation Y= status confirmed, student is eligible for TIV aid C= in continuance, INS is re-checking. Wait 10 days for updated results before starting paper secondary confirmation N= not confirmed. Start paper process. X = INS needs more info. Start paper process.

7. Requesting Documents Make clear to students what type of document is acceptable, how & where to submit it Specify deadlines (must give them at least 30 days)

8. Ineligible Students Familiarize staff with common international student visas (J-series, F- series) so they can be counseled of ineligibility before completing the FAFSA Don’t submit G-845S to INS for students whose documents clearly indicate they are ineligible.

9. Form G-845S Review documents before completing form; make sure student will be eligible non-citizen if document is valid. Always submit front & back copies of documents, even the new “hologram” cards Attach extra documentation, letters, etc. Track when you submit forms and followup

10. When INS Doesn’t Respond Can you evaluate documents yourself? Yes, if INS doesn’t respond within 15 business days AND There is no conflicting information AND The immigration status documents submitted by the student appear to meet the eligibility requirements Can’t use non-response as confirmation in subsequent year.

11. Resources Federal Student Aid Handbook, Volume 1, Chapter 2 Guide to ISIRs, Appendix B, Database Matches and Flags NASFAA Encyclopedia, General Program Administration, 1.11.1

12. INS National Customer Service Center 1-800-375-5283 www.ins.usdoj.gov District Offices Servicing SWASFAA: Arkansas, Louisiana: U.S. Dept of Justice, Immigration & Naturalization Service, 701 Loyola Avenue, Rm T-8011, New Orleans, LA 70113 Oklahoma, Texas: US Immigration & Naturalization Service, 8101 N. Stemmons Fwy, Dallas TX 75247 New Mexico, Texas: USINS El Paso District Office, 1545 Hawkins Boulevard, Suite 167, El Paso, TX 79925

13. Pam McConahay Assoc. Director, Compliance, Training & Lender Relations, University of Oklahoma Financial Aid Services pmcconahay@ou.edu 405.325.4617