[Oasfaa] Non filer statement vs. Verification Worksheet

[Jeannie Shore]

I have a colleague who recently provided clarification regarding the requirement of "non filer" students/parents.  It is my opinion that the clarification provided is in error, but would like to solicit opinions.

 

Situation:  Student was selected for verification.  Both parents are non filers and so stated on the verification worksheet which was submitted with the student signature and one parent signature.

 

The guidance provided is that the verification worksheet is not sufficient in the case of non filers.  That either two parent signatures is required (a signature for each non filer) or to secure a non filer statement from both parents (both parents signing) IN ADDITION to the verification worksheet and states this is required by federal regulation cited below.

 

It has always been my opinion that a valid and complete verification worksheet is sufficient, with one parent signature and further have never been cited for this in a Program Review or audit.

 

Have I been mistaken all these years?  Thoughts?  The clarification given is provided below.

 

"The regulations do require a non-filer from each individual non-filer.  

 

I think you are mixing the VF requirement for one signature with the non-filer requirements. In the case of two non filers the school will need to document the additional non-filer's information. 

34 CFR § 668.57 (d)(ii) If no tax return was filed or is required to be filed, a statement signed by the relevant individuals certifying that no tax return was filed or is required to be filed and providing the sources and amount of untaxed income and benefits specified in §668.56(a)(5) (iii), (iv), (v), and (vi);"

Jeannie Shore

Divisional Director 

Student Finance

Health Education Division

Cell Phone - 847.909.2898

Fax - 847.585.2763

 

 

 

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