JUSTIFICATION AND EXPECTED RESULTS. The parties to this Agreement have determined that this computer matching program is justified because it is the most efficient and expeditious means of obtaining and processing the information needed by CA-DSS to verify the immigration status of Benefit Applicants for, and recipients of, TANF and SNAP. It is expected that this matching program will enable CA-DSS to rapidly confirm the eligibility of Benefit Applicants with proper immigration status, identify those Benefit Applicants who require further checks to confirm proper eligibility status, administer sponsor deeming and agency reimbursement requirements, and to identify and prevent improper payments to those Benefit Applicants whose immigration status does not entitle them to receive TANF and SNAP administered by CA-DSS. Available alternatives to the use of this computer matching program for verifying immigration status would impose a much greater administrative and processing burden, would result in higher annual administrative costs, and would protract the average case response time. The anticipated savings from the use of the SAVE Program, including administrative costs and savings derived by eliminating fraudulent benefit payments, is $20,071,766 based on historical savings. Using a computer matching program, CA-DSS can process, in an extremely expeditious manner, a higher volume of queries with reduced overall labor demands. Additionally, because of the rapid response capability provided by this computer matching program, there will be a greater deterrent effect on applicants seeking to fraudulently receive entitlement benefits administered by CA-DSS as compared to a much slower mail- in procedure. One of the major objectives of IRCA, to reduce incentives for undocumented entry and presence in the United States, is furthered by this matching program’s deterrent effect. Finally, this system also supports efforts to curb waste, fraud, and abuse within federally-funded entitlement programs.
JUSTIFICATION AND EXPECTED RESULTS. ED and DHS-USCIS have determined that a computer matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to verify the immigration status of applicants for the Title IV Student Financial Assistance Programs. The principal alternative to using a computer matching program for verifying immigration status would be to institute a mail-in procedure using Form G-845 for all eligible noncitizen verifications, which would impose a greater administrative burden and delay response times. Using the computer matching program, responses can be provided within 24 hours of ED inquiries. Applicants who require automated additional verification are provided a response in as little as 72 hours from ED’s additional verification request. ED expects that this computer matching program will enable it to quickly and efficiently verify the status of applicants for the purpose of determining their eligibility for Title IV Student Financial Assistance Programs. The matching program will also quickly identify those applicants who require manual additional verification before the institution of higher education can independently determine whether the applicant meets the eligibility requirements of the Title IV Student Financial Assistance Programs. ED estimates that this computer matching program costs $487,386 per 18-month award period to operate. Given an estimated processing time of 15 minutes per applicant, and an average cost per record to process a DHS verification of $6.80 per application, and approximately 967,036 applicants per 18-month award period, verification of immigration status in the absence of computer matching (i.e., using mail-in procedures) would cost institutions approximately $6,575,845 per year. Because computer matching reduces the number of applicants requiring manual verification by 95.85%, this administrative cost to institutions is reduced from $6,575,845 to $272,646 for a total savings of $6,303,199. (Attached is a detailed cost/benefit analysis). In addition to the savings in administrative costs, the computer matching program provides identification of categories of immigration statuses allowing ED to deny eligibility to non-citizens who are not Title IV eligible under the law (and who, without the match, might receive aid). The notice to applicants informing them that their application information is subject to computer matching is expected to have a deterrent effect on applican...
JUSTIFICATION AND EXPECTED RESULTS. Section 5301 provides an option to sentencing judges to deny all or selected Federal benefits (including Title IV, HEA student financial assistance) to individuals convicted of drug trafficking or possession. Section 5301 is one of a number of provisions enacted by Congress with the intent of reducing the demand for illegal drugs. It represents a strong objective that Federal benefits not be used to support individuals engaged in illicit drug activities. DOJ is administering this law in a manner designed to achieve these objectives to the maximum extent possible. The Agencies have determined that a matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to determine whether Title IV, HEA applicants have been convicted of certain drug-related offenses and subsequently denied Federal student financial assistance pursuant to section 5301. By matching the names, dates of birth, and SSNs in the DFB/DPFD database with ED’s student financial aid records, ED is able to identify students who do not qualify for Federal student financial assistance pursuant to the provisions set forth in the Controlled Substances Act. Thus, ED avoids the cost of disbursing student financial assistance funds to individuals who do not qualify for Federal student financial assistance, but who would otherwise receive aid had the matching program not existed. Finally, a manual system would require ED to locate matched students after they have already enrolled in school. As of December 2019, DOJ reports that about 19,951 individuals were actively debarred from the receipt of certain Federal benefits, including Federal student financial assistance. In addition, over 18.5 million individuals apply for Federal student financial assistance each award year. In view of these numbers, an automated matching program is the only practical method to prevent improper payments to applicants who are not eligible to receive the benefits administered by ED under Title IV, HEA. For the award year cycle covering 2018-2019, a cost-benefit analysis demonstrated the benefit of using the matching program. While the cost of running the computer matching agreement was $6,162, the total cost avoidance, based upon Title IV, HEA student financial assistance denied in accordance with section 5301, was $310,155 (see Appendix A: Cost-Benefit Analysis). The cost benefit ratio is 0.020. As discussed above, there is no viable alternative to a comput...
JUSTIFICATION AND EXPECTED RESULTS. ED and DoD have determined that a matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to identify applicants who are children of military personnel who died as a result of U.S. military service in Iraq or Afghanistan after September 11, 2001. DoD will provide ED, from DoD’s DEERS system, with a list containing the dependent’s name, Social Security number (SSN), and date of birth; as well as, from DoD’s DMDC Data Base, the date of death of the parent or guardian of each child whose parent or guardian died as a result of performing military service in Iraq or Afghanistan after September 11, 2001. By matching those data with ED’s Federal Student Aid Application File, ED will be able to identify Federal student aid applicants who meet the qualifications for increased Federal student financial assistance pursuant to sections 473(b) and 420R of the HEA. Because of the number of individuals who apply for Federal student financial assistance (more than 18.5 million annually), an automated matching program is the only practical method to identify applicants who may be eligible for increased amounts of Federal student assistance. ED will disclose the data received from DoD to the Common Origination and Disbursement (COD) System to determine the amounts and types of Title IV, HEA program assistance that an applicant will receive. This CMA will allow both ED and DoD to accomplish their statutory mandates under the HEA. There are no other data sources available with the information needed to comply with the legal requirements. The use of computer technology to transfer data between DoD and ED is faster and more efficient than the use of any manual process. Attached is a cost-benefit analysis (CBA) for the 2018–19 academic year, adjusted for three years of inflation since the previous CBA, and demonstrating the benefit of using the matching program. The cost of running the matching program was $20,815, but the total quantifiable benefit to recipients is estimated to be $627,908 (See Appendix A: Cost-Benefit Analysis).
JUSTIFICATION AND EXPECTED RESULTS. ED and DoD have determined that a computer matching program is the most efficient, expeditious, and effective means of obtaining and processing the information needed by ED to identify applicants who are children of military personnel who have died as a result of U.S. military service in Iraq or Afghanistan after September 11, 2001. DoD will provide ED, from DoD’s DEERS system, with a list containing the dependent’s name, Social Security number (SSN), and date of birth; as well as, from DoD’s DMDC Data Base, the date of death of the parent or guardian of each child whose parent died as a result of performing military service in Iraq or Afghanistan after September 11, 2001. By matching those data with ED’s Federal Student Aid Application File, ED will be able to identify Federal student aid applicants who meet the qualifications for increased Federal student financial assistance pursuant to sections 473(b) and 420R of the HEA. Because of the number of individuals who apply for Federal student financial assistance (more than 19 million annually), an automated matching program is the only practical method to identify applicants who may be eligible for increased amounts of Federal student assistance. This CMA will allow both ED and DoD to accomplish their statutory mandates under the HEA. There are no other data sources available with the information needed to comply with the legal requirements. The use of computer technology to transfer data between DoD and ED is faster and more efficient than the use of any manual process. Attached is a cost-benefit analysis for the 2015-16 academic year, demonstrating the benefit of using the computer matching program. The cost of running the computer matching program was $15,678, but the total quantifiable benefit to recipients is estimated to be $459,539 (See Appendix A: Cost-Benefit Analysis).
JUSTIFICATION AND EXPECTED RESULTS
