entity	confirming	to	the	school	that	the	individual	who	completed	the	FAFSA	form	and	was	selected	for	verification	is	the
person	signing	the	Statement	of	Educational	Purpose.
Immigrants	and	Tax	Filing
Immigrants	are	not	exempt	from	tax	filing.	The	IRS	is	more	concerned	whether	a	person	is	a	resident	or	nonresident
rather	than	a	legal	or	illegal	alien.	An	alien	is	anyone	who	is	not	a	U.S.	citizen	or	national.	A	resident	alien	is	one	who
either	is	a	permanent	resident	or	has	resided	in	the	U.S.	for	a	specific	minimum	amount	of	time	(has	met	the	substantial
presence	test).	All	others	are	nonresident	aliens.	Resident	aliens9	income	is	generally	subject	to	tax	in	the	same	manner
as	U.S.	citizens9,	and	they	file	Form	1040.	Nonresident	aliens	who	are	required	to	file	a	return	submit	Form	1040NR,	which
is	acceptable	documentation	for	verification.
Immigrants	who	do	not	have	an	SSN	and	are	unable	to	get	one	can	apply	with	the	IRS	for	an	individual	taxpayer
identification	number	(ITIN).	The	ITIN	is	only	for	tax	purposes.	It	does	not	authorize	a	person	to	work,	endorse	his	or	her
legal	status,	or	entitle	them	to	the	earned	income	credit	or	Social	Security	benefits.
See	the	IRS9s	
Publication	519,	U.S.	Tax	Guide	for	Aliens	at	www.irs.gov	for	more	information.
Interim	Disbursements
Interim	disbursements	are	allowed	either	prior	to	completing	verification	or	after	verification	but	before	receiving	the
corrected	FAFSA	Submission	Summary	or	ISIR.	If	you	have	no	reason	to	question	the	accuracy	of	the	information	on	the
FAFSA	form,	prior	to	completing	verification	you	may	at	your	discretion:
Make	one	disbursement	of	Pell	and	FSEOG	funds	for	the	applicant9s	first	payment	period;
Permit	FWS	employment	for	the	first	60	consecutive	days	after	the	student	enrolls	for	the	award	year;	or
Originate	but	not	disburse	a	Direct	Subsidized	Loan.
If	verification	results	in	changes	to	the	FAFSA	information	that	you	determine	will	not	alter	award	amounts,	you	may	at
your	discretion	also	disburse	a	Direct	Subsidized	Loan	prior	to	receiving	the	corrected	valid	FAFSA	Submission	Summary
or	ISIR	(defined	as	a	FAFSA	Submission	summary	or	ISIR	on	which	all	the	information	reported	on	a	student9s	FAFSA	form
is	accurate	and	complete	as	of	the	date	the	application	is	signed).
Overpayments	From	Interim	Disbursements
If	you	make	an	interim	disbursement	of	Pell	or	FSEOG	funds	prior	to	verification	and	the	student9s	eligibility	for	Title	IV
funds	changes	after	you	complete	verification,	your	school	is	liable	for	any	resulting	overpayment.	If	you	can9t	eliminate	it
by	reducing	subsequent	disbursements	or	having	the	student	return	the	money,	your	school	must	use	its	own	funds	to
Verification	for	Confined	or	Incarcerated	Individua ls
34	CFR	Part	668	Subpart	P
Dear	Colleague	Letter	GEN-24-10
Interim	Disbursements
34	CFR	668.58
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