FAQ’s
Enrolled students must be verified by no later than the end of drop/add. Institutions may opt to have earlier
deadlines.
Institutions may work with students who are unable to meet the legal name verification requirement by the end
of drop/add due to extenuating circumstances. Professional judgment must be used to determine if alternative
documentation is appropriate to satisfy the requirement.
Institutions should strive to align names in the System of Record to Official Government Documents.
The legal name verification applies to new students starting with those first enrolling Fall 2025. Institutions may opt to verify their continuing and returning students.
Each institution should establish a tracking process to ensure the Legal Name for each enrolled student is verified. Institutions may be asked to show how they are complying with the procedure in a future audit.
Yes, the Legal Name verification may be completed using a student’s ISIR when the student’s name on the ISIR matches the student’s Legal Name in the System of Record and other student information on the ISIR (DOB, SSN, address, etc.) supports that the records match.
No. Instead, use source documents for name verification.
No. Currently, GRITS does not appear to rely upon legal documents to validate a person’s identity on Form 3231.
Yes, while a current document is preferred, it is recognized that some students may not be able to present an
unexpired document.
Yes, a driver’s license without the REAL ID indicator is still considered an Official Government Document.
Institutions may work with students who indicate they do not have an Official Government Document on a case-by-case basis. Institutions may use professional judgment to consider other documents, such as official high school or postsecondary transcripts, on a case-by-case basis.
Institutions should contact the student to determine the source of the disparity and use their professional judgment to determine appropriate action. In some cases, the Legal Name in the System of Record may need to be updated to match the Official Government Document.
The verification cannot be completed based on a birth certificate if the name on the birth certificate does not match the student’s current Legal Name in the System of Record. In cases where a Legal Name change has occurred, a court order from the court where the name change was granted may be accepted. A marriage certificate or a divorce decree may also be accepted.
Students living outside the U.S. should present a government-issued document. This could include a birth certificate, government-issued health card, driver’s license, etc. Institutions should use their professional judgment to work with students from outside the U.S. on a case-by-case basis. Institutions may also verify a student’s Legal Name based on an official high school or postsecondary transcript and/or an international credential evaluation completed by an accepted third party.
The Legal Name verification pertains to the student’s first name and last name only.
Yes, a student may be verified based on an Official Government Document showing their full first name with the System of Record showing an initial only for the first name.
Institutions may utilize a student’s preferred name when communicating and providing lists, etc. related to prospective students. The new BPM guidance applies to enrolled students and the System of Record. A CRM is not considered a System of Record.
Institutions may opt to display the Preferred Name without the Legal Name in systems other than the System of Record.
See (5)(a) in Procedure on Preferred Names within USG Systems of Record.
Institutions may contact Tim Chester and/or Todd Watson with any questions about the BPM Procedure on Preferred Names within USG Systems or Record.