Recently passed legislation in Kentucky and Virginia offer examples of how states can increase attention on Free Application for Federal Student Aid (FAFSA) completion by high school seniors without making completing the form, or opting out of doing so, a requirement for students. These two states offer an interesting model for states that are interested in increasing the salience of FAFSA completion efforts in their schools but are unwilling or uninterested in a stricter requirement.
Virginia Establishes School Boards’ Role in FAFSA Completion
Virginia’s HB1095 was signed into law by Governor Abigail Spanberger (D) on April 13. The new law involves school boards in the FAFSA completion process in a way that differs from other states. The law requires that each school board:
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Annually provide to each high school student and their parents “guidance and other informational materials on student financial aid applications for the purpose of promoting awareness of federal and state financial aid programs, resources, eligibility criteria, application deadlines, and other processes and requirements.”
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Use federally-available data to establish a five-year goal for each of their high schools, the purpose of which is for “encouraging and increasing the completion of student financial aid applications by their high school students during the students' final school year before graduation.”
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Annually post federally available data relating to student financial aid applications in a publicly accessible location on its website and submit to the Department a report on the progress toward achieving that five-year goal (both in the aggregate for all high schools under the board’s governance and for each individual high school).
Notably, the law is pointed that it is not universal FAFSA legislation and reads, “Nothing in this section shall be construed to require any school board to establish a goal of universal completion of a student financial aid application prior to graduation by each high school student in the school division.” The law is also explicit about protecting students’ personally identifiable information (PII) and says that no school board of employee thereof may share PII with any local, state, or federal entity outside of the school board’s jurisdiction.
The legislation also put some requirements on two state-level entities, the Virginia Department of Education (VDOE) and the State Council of Higher Education for Virginia (SCHEV). These agencies are charged with providing each school board with the Office of Federal Student Aid’s web site provisioning FAFSA completion data for high school seniors and “guidance or other informational materials on student financial aid applications, including alternatives to the Free Application for Federal Student Aid such as the Virginia Alternative Student Aid application” and “guidance and other informational resources designed to support school boards in making progress toward the five-year goals” that school boards will establish for their high schools.
FAFSA Completion Joins Kentucky’s Accountability Model…Eventually
Rather than a standalone piece of FAFSA legislation, the change for the Bluegrass State is baked into a larger bill on the education assessment and accountability system, HB 257. The bill adds a new metric to the state’s reporting and accountability structure for schools with 12 grade students.
This metric is “the percentage of graduating students who have: Completed the Free Application for Federal Student Aid by the student's graduation date; or a parent or legal guardian that has submitted an appropriate form to the school or district to opt out of completion of the Free Application for Federal Student Aid after completing a district-approved presentation regarding the Free Application for Federal Student Aid.
What’s particularly interesting here is that the legislation writes in an opt-out for students and parents without establishing a requirement from which to opt out. The legislation establishes a clear expectation that students will either complete the FAFSA or opt out of doing so. (What’s less clear is whether all students and parents have to participate in the approved FAFSA presentation or just those who don’t want to complete the FAFSA at all.)
Until June 30, 2030 this metric is a reporting requirement that will be included on a school’s report card that “clearly communicates with parents and the public 10 about school performance.” After June 30, 2030, this “targeted quality measure” will become part of the state’s accountability structure, and these targeted quality measures will be weighted at “not less than” 5% for accountability purposes.
(Incidentally, HB 257 also includes measures of postsecondary readiness for high school students, but that’s a blog post for another day.)
A Blip or a Pivot on the Universal FAFSA Front?
Universal FAFSA policies have been passed by 14 states, and 11 states have either implemented them presently or will do so in the future. These policies attach some requirement to students or schools to either complete a FAFSA before graduating high school or to opt out of doing so. These policies have gained momentum since Louisiana first implemented such a policy for its high school class of 2018.
Recently, states seem to be getting squeamish about incorporating a student-level high school graduation requirement. Louisiana and New Hampshire both repealed their universal FAFSA policies; Kansas abandoned plans for one before implementation.
Only time will tell whether more states will move toward approaches like Kentucky and Virginia’s or whether we will see more “traditional” universal FAFSA policies passed out of legislatures. But let’s not lose the forest for the trees. The momentum for universal FAFSA came in the first place as more states recognized the association between FAFSA completion and enrollment and the importance of connecting students with financial aid to help pay for education and training after high school. States know the value of education and training after high school and want to reap the benefits, fiscal and otherwise, of their students leveling up. These policies emphasize FAFSA completion as a key step in that process to which states want to hold their systems accountable somehow. It will be interesting to see whether, and how, the impacts on FAFSA completion and postsecondary enrollment vary across these different approaches.
The National College Attainment Network (NCAN) will continue to monitor and report on state-level developments in FAFSA completion. In the meantime, want to chat about FAFSA completion programming, practice, or policy in your state? I’d love to chat at [email protected].