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U.S. Citizenship, Immigration Status & Secondary Confirmation for Federal Student Aid Programs

Basic eligibility criteria for Federal student financial aid programs require that a student be either a U.S. Citizen (by birth or naturalized) or an Eligible non-U.S. Citizen. Eligible non-U.S. citizen status is defined by law and encompasses a number of different categories. This article elaborates on the process of determining federal aid eligibility for non-U.S. citizens.

Who is Considered an Eligible non-U.S. Citizen?

Federal Student Aid publishes a comprehensive list of what defined an eligible non-U.S. Citizen. Click to learn more about the eligible categories.

When and why might you need to submit documents to prove you are a U.S citizen or eligible non-U.S. citizen?

U.S. Citizens
Naturalized U.S. citizens may need to submit proof that they are a U.S. Citizen after filing their FAFSA. The reason this occurs is because at the time the student became a U.S. citizen there was no automatic report to the Social Security Administration that the person is now a U.S. citizen. So, when the FAFSA is filed and the database match with the Social Security Administration is conducted, it does not report that the student is now a U.S. Citizen. In those cases federal law requires that the college obtain proof from the student that they are U.S. citizen before any federal aid can be disbursed.

To avoid having to submit these documents every year students are encouraged to update their citizenship status with the Social Security Administration. Click here for information on how to do that.
Eligible non-U.S. Citizens
FAFSA records for Eligible non-U.S. citizens go through a database match with the Department of Homeland Security (DHS) at the time the FAFSA is filed. If the database match confirms that the student meets one of the eligible non-U.S. Citizen categories then the student does not need to submit any documents to the college. If however, the database match comes back stating that the match is not confirmed then the college financial aid office is required, by law, to obtain proof form the student that they meet one of the eligible non-U.S. citizen categories before aid can be disbursed.

The office of financial aid, in many cases, must then submit that documentation to the U.S. Citizenship and Immigration Services (USCIS) electronically through the SAVE (Systemic Alien Verification for Entitlements) system to assist in confirming eligibility. This process can take up to 30 calendar days and as such can lead to delays in processing of aid. A negative response from SAVE would make a student ineligible for federal student financial aid.

Which Documents are acceptable to prove citizen or immigration status?

Students who hold any of the documents listed in the categories below would be considered eligible for federal student aid. As noted above some of these documents require additional Verification through the USCIS SAVE system.

U.S. Citizens born in the U.S.
A copy of a birth certificate showing that they were born in the U.S. (or a U.S. territory such as Puerto Rico, Guam etc.)

A U.S. passport book or card, current or expired. Note if the passport is expired it may not be used for verificaiton of identity. In those cases an additional valid government issued identity documents must accompany the U.S. Passport
U.S. Citizens not born in the U.S.
A valid U.S. passport book or passport card (described above in the “U.S. Citizens born in the U.S.” section above )

A Certificate of Citizenship (N–560 or N–561), issued by USCIS to persons who
derive U.S. citizenship through a parent;

A Certificate of Naturalization (N–550 or N–570), issued by USCIS (or, prior to 1991,
a federal or state court), or through administrative naturalization after December 1990
to those who are individually naturalized.

Note: A Certificate of Citizenship or Certificate of Naturalization must include the:
Certificate number
DHS Alien Registration Number
Student’s name
Student’s date of birth; and
Date & location of issuance

If issued to a minor child, a Certificate of Citizenship may bear the signature of the
parent instead of the child, this does not affect the legitimacy of the document.

A copy of Form FS-240 (Consular Report of Birth Abroad), FS545 (Certificate of
Birth Issued by a Foreign Service Post), or DS1350 (Certification of Report of Birth).
These are State Department documents.

U.S. Travel Document – Must be annotated with “Permit to Reenter Form I-327
Non-Citizen National
U.S. Passport book or card which must be stamped “Noncitizen National”
Eligible non-U.S. Citizen – U.S. Lawful Permanent Resident (LPR)
Unexpired Permanent Resident Card (Form I-551, since 1997)
Unexpired Resident Alien Card (Form I-551, before 1997),

These are commonly referred to as “green cards”.

Older Alien Registration Receipt Card – (remains acceptable as evidence of permanent residence for the purpose of receiving federal student aid.)

Note: A Permanent Resident Card or Resident Alien Card must be accompanied by additional government issued identity documents if the picture on the card is a baby picture. However, card holders should update their picture on the document with USCIS on or after age 14.

Unexpired Foreign Passport with MRIV stamped “Processed for I-551”

Must be stamped “Processed for I-551″ with an expiration date. May have Machine Readable Immigrant Visa (MRIV) with admission stamp and the following statement “Upon endorsement serves as temporary I-551 evidencing permanent residence for 1 year”

Arrival/Departure Record (CBP Form I-94) or the new electronic Departure Record (Form I94A) with the endorsement “Processed for I-551.

NOTE: The I-94 form will have an A-number annotated on it and is an acceptable
document as long as the expiration date has not passed at the time it is submitted for secondary confirmation. Applicants can access their I-94 status by visiting:
https://i94.cbp.dhs.gov/I94/#/home.
Other Eligible non-U.S. Citizens
Arrival-Departure Record” Form I-94 or electronic I-94A
Must be endorsed:
Refugee,
Asylum Status
Conditional Entrant (before April 1, 1980)
Parolee
Cuban-Haitian Entrant
UHP
NOTE: Students paroled into the U.S. must have a stamp indicating that the student has been paroled into the U.S. for at least one year.

Victims of Human Trafficking
Unexpired HHS Certification or Eligibility Letter or
Valid T-Visa (if spouse or child of HTV).
Status must be verified each year by a confirmation
phone call to HHS.

Battered immigrants-qualified aliens under the Violence Against Women Act (VAWA)– Form I-797 Notice of Action approval or prima facie letter or immigration judge’s court order. Form I-797 is USCIS’s formal communication with customers issued when an application or petition is approved or to confer an immigration benefit.

Afghan Special Immigrant – I94 with the following stamped:
Special Immigrant Status (SQ/SI) Parolee
Sec 602(b)(1) AAPA / Sec 1059(a) NDAA 2006
Date _____USCIS officer:______

There may be another document such as Form I-766, Employment Authorization Document (EAD), with a C11 parolee category.

Afghan Non-Special Immigrant Parolees
Form I-766, Employment Authorization Document (EAD), with a C11 category or a CBP “PAROLED” stamp in their passport;

Ukraine Citizens and National Paroled into the U.S

Ukrainian national paroled into U.S. between Feb. 24, 2022 and Sept. 30, 2023

OR

Ukrainian national paroled into U.S. after Sept. 30, 2023 if they are a:
▪ Spouse or child of a Ukrainian citizen or national paroled into U.S. between February 24, 2022 and September 30th, 2023 OR;
▪ Parent/guardian/primary caregiver of unaccompanied noncitizen child paroled into U.S. between February 24, 2022 and September 30th, 2023

Documentation
Paper Form I-94 with a UHP Class Of Admission (COA);
Foreign passport with parole stamp that includes a UHP COA; or
Form I-766, Employment Authorization Document (EAD), with a “C11” category, if they
have applied for and received one.
Jay Treaty of 1794 students – Native Americans Born in Canada
A “band card” issued by the Band Council of a Canadian Reserve, or by the Department of Indian Affairs in Ottawa.

Birth or baptism records

An affidavit from a tribal official or other person knowledgeable about the applicant’s or recipient’s family history

Identification from a recognized Native American provincial or territorial organization
Citizens of the Freely Associated States
Citizens of the Marshall Islands, the Federated States of Micronesia and the Republic of Palau

Documentation of citizenship (such as a birth certificate) in any of the above Freely Associated States.

Note: Citizens of the Freely Associated States are eligible for Federal Pell Grants but are not eligible for any federal loans.

Common Documents that are not acceptable for proving U.S. Citizenship or non-U.S. Citizen eligibility status

There are a number of common documents issued by federal state or local government which, although official, do not meet the statutory requirements in the law to make a student eligible for federal student aid. Some of these are listed below.

Unacceptable Visas
Non-immigrant visas such as but not limited to:

F-1, F-2 or M-1 Student Visa

B-1 or B-2 Visitor Visa

J-1 or J-2 Exchange Visitors Visa

H series or L series Visa (which allow temporary employment in the U.S.)

A2 and A3 Visas (foreign official, including attendants)

NATO Visas (NATO) or

G series Visa (pertaining to international organizations)

U-Visa
Other Unacceptable Government Issued Documents
Form I-817, Application for Family Unity Benefits

Notice of Approval to Apply for Permanent Residence (I-171 or I- 464)

Deferred Action for Childhood Arrivals (DACA) (students may be eligible for NY State Aid)

Employment Authorization Card (Form I-688A), Employment Authorization Documents (Form I-688B or Form I-766) or the Temporary Resident Card (Form I-688)

Social Security Number (SSN) Card

State issued ID or Driver’s license

Municipal/School Issued ID Cards

Form I-94 stamped “Temporary Protected Status

Withholding of removal” order issued by an immigration judge or by the Board of Immigration Appeals.

How do I know when I need to submit these types of documents?

Students who need to submit proof of U.S. citizenship or eligible non-citizen status will have a “Verify My FAFSA” to do list item in their CUNYfirst student center. Follow the link in the to do list item to login to the document submission system and follow the instructions on the screen.

What is the deadline to submit these documents?

You must confirm that you met the eligibility requirement under one of the categories above during your period of enrollment. All documents should be submitted before the last day of your enrollment.

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