301 - Financial Aid Fraud Prevention and Identity Verification Policy
- Policy Number: 301
- Policy Title: Financial Aid Fraud Prevention and Identity Verification Policy
- Policy Owner: VP Student Affairs
- Date Approved: Mar. 27, 2026
- Date Revised: NA
- Date Reviewed: Nov. 20, 2025
Scope
This policy applies to all students who apply for or receive federal financial aid under Title IV of the Higher Education Act and/or Washington State financial aid administered through the Washington Student Achievement Council (WSAC).
Purpose & Background
Olympic College is required to protect federal and Washington State financial aid funds from improper or fraudulent use. This policy establishes procedures to identify potential fraud, require identity verification, and take appropriate action when a student’s identity cannot be confirmed, while ensuring students are notified and provided an opportunity to respond.
Definitions
Title IV educational funds are federal financial aid funds authorized under Title IV of the Higher Education Act of 1965 (HEA). These funds are provided by the U.S. Department of Education to help eligible students pay for postsecondary education expenses such as tuition, fees, books, housing, and other educational costs.
Policy
- Olympic College may require identity verification when activity suggests potential fraud. Indicators may include, but are not limited to, conflicting, incomplete, or unverifiable identity information; unusual enrollment, attendance, or financial aid patterns; reused or shared contact information across multiple student accounts; alerts, matches, or referrals from WSAC, the U.S. Department of Education, or other oversight agencies; or the inability to authenticate a student using standard verification methods.
- In addition to cases where indicators of potential fraud are identified, Olympic College will require identity verification through the Welcome Center for the following categories of students as a preventative control measure:
- First-Time Federal Direct Loan Borrowers Any student who is receiving a Federal Direct Loan at Olympic College for the first time, regardless of prior enrollment history.
- Students Enrolled Exclusively in Online Coursework Any student enrolled in courses delivered fully online for a given term.
- Students in these categories are subject to identity verification regardless of whether fraud indicators are present, unless they have been verified through an approved college program or partnership that includes identity verification, as determined by the Financial Aid Office. Verification must be successfully completed prior to loan disbursement or, when applicable, prior to a financial aid refund.
- The College reserves the right to expand or modify mandatory verification categories based on risk assessment, audit findings, regulatory guidance, or emerging fraud trends.
- When potentially fraudulent activity is identified, the student will be notified through official college communication channels and required to verify their identity. Identity verification may include submission of a government-issued photo identification, completion of live or virtual identity verification, or provision of additional documentation reasonably necessary to confirm the student’s identity. Students will be given a reasonable timeframe to respond.
Students must complete the required identity verification within the reasonable timeframe provided in the notification. Failure to respond within this timeframe may result in administrative action as outlined in this policy.
A student who fails to respond to or complete the identity verification request within the required timeframe may be subject to administrative action, including:
- Withholding, cancellation, or reversal of federal and Washington State financial aid
- Removal from enrolled courses
- Suspension of financial aid eligibility pending resolution
- A fraud flag placed on the student record
- When a student’s identity cannot be verified or fraudulent activity is reasonably suspected, Olympic College may report the case to the WA State Auditor’s Office, SBCTC Business Operations and the Department of Education Office of the Inspector General, and other appropriate oversight or regulatory agencies, as required.