reimburse	the	appropriate	program	by	the	earlier	of	60	days	after	the	student9s	last	day	of	attendance	or	the	last	day	of
the	award	year.
If	your	school	permits	provisional	FWS	employment	of	students	for	up	to	60	days	prior	to	verification,	your	school	is	liable
for	any	overpayment	it	can9t	recover	by	adjusting	other	aid,	and	it	must	reimburse	the	FWS	account	from	its	own	funds.
Students	must	be	paid	for	all	work	performed	out	of	your	school9s	payroll	account4they	can9t	be	required	to	repay	FWS
wages	earned	except	when	they	are	proven	guilty	of	fraud.
Because	the	school	made	interim	disbursements	at	its	discretion,	the	school	is	ultimately	responsible	for	repaying	any
overpayment.	Therefore,	in	this	situation,	a	student	does	not	owe	a	
Title	IV	overpayment	and	the	school	must	not	report
an	overpayment	to	NSLDS	or	refer	it	to	the	Department	for	collection.
If	you	make	an	interim	disbursement	after	completing	verification	but	prior	to	receiving	a	correct	valid	FAFSA	Submission
Summary	or	ISIR,	and	you	fail	to	receive	the	FAFSA	Submission	Summary	or	ISIR	within	the	deadlines	discussed	later	in
this	chapter,	your	school	must	use	its	own	funds	to	reimburse	the	appropriate	program	and	pay	the	student	under	your
own	payroll	account	for	all	work	performed.
Schools	that	Can9t	Make	Interim	Disbursements
Schools	on	the	Heightened	Cash	Monitoring	2	(HCM2)	and	Reimbursement	payment	methods	(see	Volume	4,	Chapter	1	of
the	FSA	Handbook)	must,	as	part	of	their	request	for	Title	IV	funds	from	the	Department,	submit	documentation	showing
that	students	were	eligible	to	receive	the	funds	disbursed	to	them	(and	for	which	the	schools	are	seeking	reimbursement).
Because	final	determination	of	student	eligibility	includes	completing	verification,	HCM2	and	reimbursement	schools	may
not	make	interim	disbursements.
Updating	Information
Generally,	a	student	cannot	update	information	that	was	correct	as	of	the	date	the	application	was	signed	because	the
FAFSA	form	is	a	<snapshot=	of	the	family9s	financial	situation	as	of	that	date.	For	example,	if	the	student9s	family	sold
some	stock	after	the	student	signed	the	FAFSA	form	and	spent	the	money	on	an	unreported	asset	such	as	a	car,	they
cannot	update	their	information	to	show	a	change	in	assets.	After	the	FAFSA	form	is	signed,	only	certain	items	can	be
updated	under	the	following	conditions:
All	applicants	whose	dependency	status	changes	must	update	that	and	the	related	FAFSA	information
throughout	the	award	year	except	when	the	update	is	due	to	the	student9s	marital	status	changing.
All	applicants	selected	by	the	Department	or	a	school	for	verification	of	family	size	must	update	family
size	to	be	correct	as	of	the	date	of	verification	unless	the	update	is	due	to	a	change	in	the	student9s	marital	status.
Applicants	selected	for	verification	are	not	required	to	document	family	size	in	a	subsequent	verification	in	the	same
year	if	the	information	has	not	changed.
At	your	discretion	you	may	update	either	dependency	status	or	family	size,	even	if	the	update	is	due	to	a	change	in	the
student9s	marital	status,	if	you	deem	it	necessary	to	address	an	inequity	or	to	reflect	more	accurately	the	student's	ability
to	pay.	Such	a	decision	must	be	on	a	case-by-case	basis,	and	you	must	document	your	reasons	for	it.	You	must	also
update	all	other	pertinent	information,	such	as	spousal	income	and	taxes	paid,	to	be	consistent	with	the	new	marital
status.	If	you	change	the	student's	status	to	unmarried	and	that	makes	them	dependent	(because	they	were	independent
only	due	to	marriage),	the	student9s	FAFSA	form	must	be	updated	with	their	parents9	information.	If	the	student	is
selected	for	verification,	update	the	application	first,	then	complete	verification	of	the	updated	application.	Your	school
may	have	a	policy	of	not	considering	such	updates	after	a	specific	census	date.
Recovery	of	Funds	From	Interim	Disbursements
34	CFR	668.61
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