Institutions must refer applicants who are suspected of having engaged in fraud or other criminal misconduct in connection with Title IV programs to the Department of Education's Office of Inspector General. The regulations require only that the institution refer the suspected case for investigation, not that it reach a firm conclusion about the propriety of the applicant's conduct.
As stewards of Title IV funds, IIT is obligated to assure that processes are developed to protect against fraud by either applicants or staff. All financial aid staff are responsible for detecting and reporting fraud. If, in the financial counselor's judgment, the applicant and his/her family has provided a fraudulent application or documentation, it must be reported immediately to a supervisor.
The Office of Financial Aid must identify and resolve discrepancies in the information received from different sources with respect to a student's application for Title IV aid. Some of these areas include but are not limited to:
- All student aid applications (e.g., federal, state, institutional, etc.)
- Need analysis documents [e.g., Institutional Student Information Records (ISIRs) and Student Aid Reports (SARs)]
- Copies of federal and state income tax returns
- Information regarding a student's citizenship
- Previous educational experience (e.g., school credentials such as a high school diploma)
- Documentation of the student's Social Security Number (SSN)
- Other factors relating to the student's eligibility for funds under Title IV aid programs (e.g., compliance with the Selective Service registration requirement)
In the context of the financial aid office, fraud is the willful misrepresentation or falsification of information for the purpose of securing financial aid that the individual is not eligible for or not eligible to the extent received. Title IV fraud can take many forms, including but not limited to the following:
- Falsified documents or forged signatures on an application, verification documents, or loan promissory notes
- False statements of income
- False statements of citizenship
- Use of false or fictitious names or aliases, addresses, or SSNs, including the deliberate use of multiple SSNs
- False claims of independent status
- Patterns of misreported information from one year to the next
Referrals to the Office of Inspector General
If the school suspects that a student, employee, or other individual has misreported information and/or altered documentation to increase student aid eligibility or to fraudulently obtain federal funds, it must report those suspicions and provide any evidence to the Department of Education's Office of Inspector General.