As schools seek to understand the 2013-2014 verification requirements recently published in the Federal Register, they are learning more about two new items, also discussed in Dear Colleague Letter (DCL) GEN-12-11, that they may need to verify for certain applicants:

• High school completion status
• Applicant's identity and statement of educational purpose

This article will take a closer look at the acceptable documentation that the applicant may submit to the college to verify his or her high school completion status.

Eligibility requirements for Title IV funds
In order to qualify for federal student aid, a student who first enrolls in a program of study on or after July 1, 2012 must have a high school diploma, a recognized equivalent of a high school diploma, or have completed a home school program. If selected for verification, the applicant may need to provide documentation that verifies he or she meets the eligibility requirements. The Federal Register classifies the types of acceptable documentation an applicant may provide by the three categories listed above.

High school diploma
An applicant with a high school diploma must submit either:

• A copy of the high school diploma, or
• A copy of a final transcript from the high school showing the date when the applicant completed his or her education.

ED has noted that in limited cases a school may accept alternative documentation to meet this verification requirement, such as when a high school diploma or final transcript is not available because the school has closed or is located in a foreign country and records are not available.

Recognized equivalent of a high school diploma
An applicant who has the recognized equivalent of a high school diploma must submit any one of the following:

• A General Educational Development (GED) certificate
• A state certificate received by the student after passing an exam the state recognizes as the equivalent to a high school diploma
• An academic transcript demonstrating the student has successfully completed at least a two-year program that is acceptable for full credit toward a bachelor's degree

The Federal Register further describes cases in which a student is excelling academically and seeking to enroll in an educational program that at minimum leads to an associate degree or the equivalent, but has not yet completed high school. The acceptable documentation the applicant must submit for these cases is two-pronged and must come from both the high school and the college. To meet the verification requirements:

• The high school must validate that the student is excelling academically; and
• The college or university must confirm that the student meets the admission requirements as outlined in the school's formal written policies.

Completion of a home school program
An applicant who has completed a home school program must submit either of the following:

• A transcript or its equivalent that lists the courses completed by the applicant and that documents completion of high school. Such a transcript or the equivalent must be signed by the applicant's parent or guardian.
• A high school completion credential for homeschool provided for under state law.

More information
While it is too early to tell which applicants will be selected to verify high school completion status, schools will need to remember that certain applicants who first enrolled in a program of study before July 1, 2012, may have established Title IV eligibility using an ability-to-benefit alternative. Schools should refer to Dear Colleague Letter (DCL) GEN-12-09 as needed for more information about Title IV eligibility for students without a valid high school diploma.

Finally, schools are encouraged to periodically check the Information for Financial Aid Professionals website for new guidance, as ED will be providing additional training and information in future publications about the verification process.