Verification Relief for 2025–26? A Closer Look at GEN-24-10 and What It Means for Financial Aid Offices
After months of anticipation and frustration from financial aid professionals nationwide, the Department of Education has issued Dear Colleague Letter GEN-24-10, which outlines verification requirements for the 2025–26 award year. The updates, while welcome in some respects, highlight a continued burden on financial aid offices navigating limited resources and operational constraints.
A Summary of the Key Changes
On September 4, 2024, the Department published a Federal Register notice (89 FR 71893) detailing verification items and documentation for the 2025–26 FAFSA cycle. The July 22, 2025 update to GEN-24-10 introduces a few modifications that institutions should be aware of, especially regarding identity verification and procedures for incarcerated students.
Elimination of Statement of Educational Purpose for Most Students
Starting with the 2025–26 award year, institutions are no longer required to obtain a Statement of Educational Purpose from students selected for Verification Tracking Groups V4 or V5. This change alone could save financial aid staff hours of manual processing and reduce back-and-forth communication with students.
Expanded Methods to Verify Identity
Two new methods may now be used in place of a notarized statement or in-person appearance:
Live video call verification between institutional staff and the student.
Third-party identity verification that meets NIST Identity Assurance Level 2 (IAL2) standards.
These options provide more flexibility for remote and nontraditional students while maintaining the integrity of the verification process.
Flexibility for Confined or Incarcerated Students
The Department has extended its 2024–25 policy into the new cycle, allowing identity verification through authorized officials at correctional facilities. If a student cannot submit a notarized Statement of Educational Purpose, a signed statement from a correctional facility official confirming the student’s identity will suffice.
Importantly, incarcerated students selected for V1 verification will not be required to verify income or household information, which simplifies their path to aid eligibility.
IRS Identity Theft Victims
For those affected by IRS tax-related identity theft, the Department will now accept a signed 2023 tax return in lieu of the previously required Tax Return Database View (TRDBV) transcript, which often took more than a year to obtain. Students must also provide a signed statement or IRS 4674C letter confirming the identity theft and the IRS’s awareness of it.
Suggested Text for Institutions
GEN-24-10’s appendix provides suggested text for all verification items, which institutions can use to meet regulatory requirements. Although not mandatory (except for the Statement of Educational Purpose language), the Department recommends clear formatting, proper labeling, and inclusion of student identifiers on all pages. This helps reduce confusion and ensures proper file documentation in line with Title IV record retention policies.
A Fleeting Gesture of Support?
The July update and its incremental improvements seem to respond to long-standing complaints from the financial aid community. Over the last few years, institutions have expressed growing frustration with how verification, originally intended as a fraud prevention mechanism, has morphed into an administrative burden that disproportionately impacts low-income students and stretches under-resourced financial aid offices to their limit.
By loosening requirements around the Statement of Educational Purpose and accepting alternative methods of identity verification, the Department is signaling that it hears the field’s concerns. But let’s be honest, these adjustments are minimal compared to the operational challenges many institutions continue to face. With shrinking staffing, tighter compliance timelines, and ever-increasing scrutiny from oversight bodies, a more comprehensive overhaul of the verification process is still needed.
This update, while helpful, feels more like a fleeting attempt to pacify an overburdened system than a transformative solution. Financial aid administrators will appreciate the relief but are right to continue advocating for long-term process reform that centers access, equity, and institutional capacity.
Need help navigating verification compliance or updating your internal forms? Contact JHSG LLC for expert consulting tailored to your institution. Our team, led by a former Federal Student Aid official with 20 years of experience, helps schools stay ahead of changes and maintain operational excellence.
