1. Citizenship Eligibility Requirements
Citizens v. Eligible Noncitizens
The Whys and Hows
of Determining an Eligible Status
for Financial Aid

2. Why do we need to verify?
A student has to be a citizen or eligible noncitizen to receive Federal Student Aid (FSA).
All applications are matched with the SSA to determine U.S. citizenship.
Applications that have an ARN (Alien Registration Number) are matched against DHS records.
If the DHS match fails after automated primary and secondary confirmation, the school must collect documentation and conduct manual third-step confirmation.

3. Data Matches
In addition to checking the FAFSA data against predetermined edits, the CPS also performs several database matches. If discrepancies arise, the student’s record is flagged and the student may not be eligible to receive federal student aid unless the discrepancy is resolved.
Data matches include checking for information from DHS, SSA, Selective Service, NSLDS, etc.

4. Department of Homeland Security Match (formerly Immigration & Naturalization Service)
The CPS matches FAFSA records against citizenship records maintained by the U.S. Department of Homeland Security (DHS). If the student reports on the FAFSA that he or she is an eligible noncitizen (and, therefore, could be eligible for federal student aid) and reports an Alien Registration Number, that information is checked against the database maintained by the DHS.
If the match does not confirm the student is an eligible noncitizen, he or she will receive a comment on the SAR. A student is not eligible for federal student aid until his or her status as an eligible noncitizen is resolved.

5. How Data Match Works CPS Database Match
U.S. citizenship database match with Social Security Administration. If U.S. citizenship is not confirmed, students must submit documentation to the school. Schools must give students at least 30 days to provide documentation.
The DHS assigns to all legal immigrants an A-number, which FSA uses to verify the immigration status of permanent residents and other eligible noncitizens. If the applicant indicates on the FAFSA that he is an eligible noncitizen and provides an A-Number, identifying information is sent to the DHS for primary (and, if necessary, secondary) verification.
CPS Database Match

6. Who Is Eligible for FSA Funds?
U.S. citizens or nationals
A person is a United States citizen by birth or by naturalization. Persons (except for the children of foreign diplomatic staff) born in the 50 states, the District of Columbia, and, in most cases, Puerto Rico, the U.S. Virgin Islands, Guam, and the Northern Mariana Islands are U.S. citizens, as are most persons born abroad to parents (or a parent) who are citizens.
All U.S. citizens are considered to be U.S. nationals, but not all nationals are citizens. Persons whose only connection to the United States is through birth on American Samoa, Swain’s Island, or the United States Minor Outlying Islands are not U.S. citizens but are nationals and therefore may receive FSA funds.

7. Who Is Eligible for FSA Funds?
Eligible Noncitizens The general requirement for eligible noncitizens is that they be in the U.S. for other than a temporary purpose with the intention of becoming a citizen or lawful permanent resident, as evidenced by the United States Citizenship and Immigration Services (USCIS) in the Department of Homeland Security (DHS).

8. Secondary Confirmation
If the DHS match fails after automated primary and secondary confirmation, the school must collect documentation and conduct manual third- step confirmation. The student must give the school unexpired documentation that shows he is an eligible noncitizen. If the documentation appears to demonstrate that he is an eligible noncitizen, it must be submitted to the USCIS (in the DHS) to confirm it is valid.

9. Statuses Requiring Paper Secondary Confirmation:
• U.S. permanent resident
• Conditional permanent resident
• Asylee/Refugee
• Parolee
• Cuban-Haitian entrant
• Conditional entrant

10. Obtaining Documents for Secondary Confirmation:
The Advising staff must always examine and copy original immigration documents, and the Verification Department must keep a copy in the student’s file with the secondary confirmation results from the USCIS. While generally not permitted, an advisor may legally photocopy immigration documents (such as Forms I-551 or I-94) when a person needs to prove his immigration status for a lawful purpose such as applying for Federal Student Aid.

11. Using the G-845 Document
Request for confirmation of eligible noncitizenship status is done by completing a U.S. Citizenship and Immigration Services G- 845, Immigration Status/ Document Verification Request document. The G-845 is a standard form provided by DHS to confirm a noncitizen’s immigration status. When secondary confirmation results in an eligible status, the school must keep the G-845. If the confirmation process indicates a discrepancy, you must ask the student to correct the discrepancy with the USCIS. No certification of loans or further disbursement of funds can be made until the discrepancy is corrected.

14. Documentation for Citizen Not Born in the US/Noncitizen National
US Passport~

15. Documentation for Citizen Not Born in the US/Noncitizen National
US Passport
Card
This resembles a credit card in size and form. Though it cannot be used for international air travel, it is, like the passport book, proof of U.S. citizenship

16. Documentation for Citizen Not Born in the US/ Noncitizen National
Certificate Of Citizenship
The Certificate of Citizenship is
issued to persons who were
born abroad of U.S. parent(s),
who became citizens when their
parents were naturalized, or
who were adopted by U.S.
parents.

17. Documentation for Citizen Not Born in the US/ Noncitizen National
Certificate of
Birth Abroad
Issued to U.S. citizens born abroad. Must have embossed seal of the State Department

18. Documentation for Naturalized U.S. Citizens
Certificate of Naturalization
The Certificate of Naturalization is issued
to naturalized U.S. citizens

19. Documentation for Citizens Who Filed for Naturalization after Oct
A revised version of the Certificate of Naturalization is issued to citizens who filed for naturalization after October 1, 1991.

20. Documentation for Eligible Noncitizens
I-94 Arrival-Departure Record for Eligible Non- Citizens
Immigrant Visa Proviso—Temporary I-551
Permanent Resident Card I-551

21. I-94 Arrival-Departure Record for Eligible Noncitizens
For permanent resident status, must be stamped “Processed for I‑551” with expiration date or “Temporary Form I-551” with appropriate information filled in.
For other eligible noncitizens, must be stamped as Refugee,

22. I-94 Arrival-Departure Documentation (cont.)
Asylum Status, Conditional Entrant (before April 1, 1980), Parolee, or Cuban-Haitian Entrant.

23. Immigrant Visa Proviso—Temporary I-551
Machine Readable Immigrant Visa (MRIV)
The MRIV will appear in the holder’s (foreign) passport. If the passport is unexpired and endorsed with an admission stamp and the statement “Upon endorsement serves as temporary I-551 evidencing permanent residence for 1 year,” it serves as a temporary I-551 and as valid documentation for establishing aid eligibility.

24. Eligible Noncitizen Documentation-I-551 Permanent Resident Card
Permanent Resident Card I-551 (front only for older versions, front and back for the current version)
The Permanent Resident Card was introduced in December 1997 and revised in In 2010 it was again updated, with the color green used once more in the design of the front of the card.

25. I-551 Permanent Residence Card (continued)
Backside of I-551

26. Exempt Statuses for 2d Confirmation
Eligible Noncitizens statuses for which paper secondary confirmation is not conducted:
Student who meets criteria of Jay Treaty of 1794
Victim of human trafficking
Qualifying relative of a victim of human trafficking
Battered Immigrant—Qualified Alien unless student has lost or cannot provide documents, documentation is unclear, or documents have expired

27. Interpreting the USCIS Response
After submitting the G-845, DHS (USCIS) will perform their document search and make a determination of the applicant’s eligibility.
The DHS (USCIS) will return the G-845 completed with remarks.
Verification will analyze the completed G-845 and compare the remarks with the guidelines in the Eligibility Handbook (See pages 1-32 through for how to interpret the responses).

28. Returning Documentation
If we receive a response from USCIS that the documentation provided was ineligible, we will update the Verification Screen Remarks Table, send a copy of the USCIS response document to applicant, and file the originals in Verification’s hold file.
See the sample below for ineligible response

29. Distance Ed Students
The Verification Department will accept supporting documentation from distance education students that has been verified by another financial aid officer at another school and certified that they viewed the original submitted document and made a copy of the document.

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