What the Department of Education’s 2027–28 verification letter asks of financial aid offices, and where a remote IAL2 option fits
Every flagged student is waiting on the same thing: someone to confirm they are who they say they are. Until that happens, their federal aid can’t go out. Getting verified can mean a trip to the financial aid office during business hours or a video call that has to fit around classes, work and everything else on a student’s plate. For the financial aid office, it’s one more appointment on a calendar that’s already full.
The U.S. Department of Education (ED) published its 2027–28 verification letter on October 26, 2026, and it repeats the four approved ways to verify a student’s identity. Only one of them lets a student verify on their own, without meeting anyone. Here’s what each method involves and what it asks of your team. We’ll also cover two other moments where remote verification helps: a legitimate student whose FAFSA is rejected, and the admissions application, where ghost students first appear.
What the Department of Education requires for V4 and V5 identity checks
ED selects some FAFSA applicants for verification and assigns each one a tracking group. Two of those groups include an identity check. V4, the Custom Verification Group, asks students to verify their identity. V5, the Aggregate Verification Group, adds identity to the standard checks of income and household information, according to the 2026–27 Federal Student Aid Handbook.
Under ED’s June 2025 identity verification guidance, students in either group must present a valid, unexpired, government-issued photo ID before the school can complete verification. The 2027–28 Dear Colleague Letter lists four approved ways to do that:
- In-person identity verification
- A signed notary statement, completed in person
- A video call with institutional staff
- Documentation that the student’s identity was verified under the NIST Identity Assurance Level 2 (IAL2) standard
The letter adds a condition to two of them: a notary statement or a video call may be used only when the student can’t appear in person.
That leaves the fourth option, and the only one that doesn’t involve a school official or a notary: NIST IAL2. The National Institute of Standards and Technology (NIST) publishes digital identity guidelines that set levels of confidence in an identity, and IAL2 is the level at which an identity can be proven remotely. In practice, that usually means checking a government ID for authenticity and confirming, often with a live selfie, that the person holding it is the person pictured. When a school relies on IAL2, ED’s guidance asks it to keep documentation of the date the student’s identity was verified and the entity that performed the verification.
How the four approved methods compare
| Method | When it can be used | Who has to be there | Records to keep |
|---|---|---|---|
| In person | Any time | The student and an authorized school official | Your standard verification records |
| Notary statement | Only when the student can’t appear in person | The student and a notary, in person | The signed notary statement |
| Video call | Only when the student can’t appear in person | The student and an authorized school official, on a scheduled call | A scanned copy of the ID with the date and the reviewer’s name |
| NIST IAL2 | Any time | Just the student, wherever they are | The date and verifier, recorded automatically |
In-person checks are the default, but they aren’t always easy. Students on campus are juggling classes, jobs, practices and labs, and the financial aid office keeps business hours. Students are also used to handling almost everything else from their phones, from banking to booking a doctor’s visit. Asking them to come in, find a notary or schedule a call can feel like a step backward.
The video option also carries its own recordkeeping. According to ED’s guidance, the school keeps a scanned copy of the ID showing the date it was presented and the name of the staff member who reviewed it, and a legible screenshot from the call can serve that purpose.
Why appointments slow down staff and students
Every manual check takes staff time. Someone schedules it, sends reminders, follows up on no-shows, runs the check and files the record. Each step is small, but together they add up in offices that are already stretched.
In the National Association of Student Financial Aid Administrators’ (NASFAA) 2025 Administrative Burden Survey, 91% of financial aid administrators said the time and resources their office spends processing each aid application had increased over the past five years, and 52% reported moderate or severe resource shortages during peak periods. NASFAA named verification tasks among the burdens that limit how much time offices can give to direct support and counseling for students.
Manual checks can also miss things. CalMatters reported that in San Diego, a potentially fraudulent applicant joined a Zoom call with a valid-looking ID that matched their face. What gave them away was their IP address, which jumped from Nairobi to Virginia.
And while a student waits for an appointment, their aid waits too. Under ED’s rules, identity verification has to be completed before the school can disburse federal aid to a flagged student. For online programs and schools with rolling start dates, that isn’t a seasonal crunch: flagged students arrive all year.
When a legitimate student’s FAFSA is rejected
Since April 26, 2026, ED has screened FAFSA submissions for identity fraud in real time, according to its FAFSA real-time fraud detection announcement. Applicants it rates as high risk are asked to show a government ID and complete a live camera check inside the FAFSA itself. If that step isn’t finished or doesn’t succeed, or if the application falls in ED’s highest-risk category, the FAFSA is rejected.
ED expects most rejected applications to be fraudulent, but some legitimate students may be caught too, and they’ll come to your financial aid office. To resolve the rejection, the school follows the same procedures it uses for V4 identity verification, then reports the result in the FAFSA Partner Portal using the FAA Fraud Override field.
ED has also said it is working to reduce V4 and V5 selection to minimal levels as its screening improves. Fewer flags is good news. It also means the students who are flagged are the ones your team most needs to verify accurately and quickly, so a real student isn’t left waiting on aid.
Stopping ghost students at the application
The federal screen also covers the FAFSA, not your admissions application. Fraud shows up there too. Open Campus reported that Lakeland Community College in Ohio had about 700 suspected incidents of application fraud over one year.
Students handle almost everything else on their phones. Verifying who they are shouldn’t require an appointment.
How remote verification works with Vouched
In June 2026, Vouched received Ready to Operate approval from the Kantara Initiative for NIST Special Publication 800-63A Identity Assurance Level 2 (IAL2). The independent review covered document verification, biometric matching, liveness detection and fraud controls. Liveness detection confirms that a real, present person is taking the selfie, not a photo, a mask or a replayed video.
All a student needs is their government ID and the phone or laptop they already use. They take a photo of the ID and a selfie, and most real students finish in under 10 seconds. For your team, verification can be embedded in your application or enrollment portal, and Vouched connects to existing portals and student information systems through standard developer tools (SDKs and APIs). Low-risk applicants pass automatically, while suspicious ones are stepped up or routed to your team for review. You can also re-verify flagged students before financial aid is released. Each verification records the date and that Vouched performed it, so your team has nothing extra to file.
Verification exists to protect real students and the aid meant for them. The goal is a process that does that the way students already handle the rest of their lives: on their phone, on their own time. It also says something about your school. A verification step that takes seconds on a phone shows students that you’re keeping up with how they live and that you respect their time.
Talk to a student aid fraud expert about keeping verification moving all year, whatever your start dates.