By Catherine Brown, Senior Director, Policy and Advocacy
Reading time: Four minutes
Yesterday, the US Department of Education (ED) announced that
it will restore critical access to Free Application for Federal Student Aid (FAFSA) completion data for college access organizations. This guidance replaces the rules put in place in September, which eliminated the ability of “designated entities” from receiving student level FAFSA completion data as part of changes to the State Student Aid Internet Gateway (SAIG) Participation Agreement. This
change has restricted the ability of nonprofit college access, TRIO, and GEAR UP programs from receiving information on whether students they were supporting had completed the FAFSA throughout the year.
The September announcement classified FAFSA completion status as federal tax information, or FTI, even though the data does not include information about a student or family income, taxes, Social Security Numbers, or even Pell status or Student Aid Index
(SAI). FAFSA completion data includes only the student’s first and last name, date of birth, ZIP code, the date the student’s FAFSA was submitted to ED, the date ED processed the FAFSA, a selected for verification flag, and a FAFSA completion flag,
as determined by the state grant agency (e.g., FAFSA not submitted, FAFSA complete, or FAFSA incomplete).
The National College Attainment Network (NCAN) has been advocating since the September announcement for the rules to be reconsidered, and we are pleased that ED finally took this
important step.
Unfortunately, this announcement may be too late to impact this financial aid cycle. ED’s announcement requires states to sign new SAIG Agreements before sharing the data with college access programs. That process typically takes several weeks, if not
months, to complete, and we don’t know whether the updated SAIG agreement is even available yet. Given all the demands on state financial aid agencies right now, it may simply not be practical or possible for states to complete this process before
schools close for the year and most students who will complete the FAFSA, already have.
ED’s guidance lays out criteria that nonprofit college access organizations must meet to receive FAFSA completion data, the same criteria used in prior years. These entities must enter into an agreement with the state grant agency and:
Be a 501(c)(3), a non-profit organization
Have as part of their mission a stated and demonstrated commitment to promoting college access and a record of legitimacy and reliability
Provide their services primarily to economically disadvantaged clients
Not charge students, families, other clients, or schools for any of their services
Not have been formally accused of or determined to have committed fraud or otherwise materially violated any law involving federal, state, or local government funds (same for affiliates and parent organizations)
Submitted a written statement to the state higher education agency certifying that each of the above criteria has been met and that the organization will immediately notify the state higher education agency, in writing, if it does not or cannot continue
to meet any of those criteria.
These organizations also must:
Have an established relationship with the students built around services provided to support the students’ pursuit of postsecondary education; and
Not use a third party to perform any of the functions related to the receipt of FAFSA filing status information it receives from a state higher education agency.
In good news, these updated SAIG agreements should be in place in every state in the country before the 2025-26 award year commences.
Outreach About Federal Means-Tested Benefits
The newly released guidance also enables state grant agencies
to use FAFSA data to identify and reach out to students to help them access the following means-test federal benefits programs:
State grant agencies that have signed the updated SAIG Participation Agreement may use the SAI, Pell status, and other FAFSA data to identify students who might be eligible for the above programs. They can then use students’ email addresses to alert them
to programs for which they may be eligible. They may not disclose data to other state agencies to determine eligibility or for any other purpose without express written consent from the student.
According to the guidance, colleges and universities may use student data to conduct outreach to students about potential eligibility for federal means-tested benefit programs without having to sign new SAIG agreements. In coalition with national partners,
NCAN has been actively promoting a proposal to streamline and simplify the SNAP rules to make it easier to identify
college students who may be eligible to receive SNAP and other services. We welcome this development and hope state agencies and institutions of higher education will take advantage of it to address food insecurity and other basic needs.
The guidance is silent on whether institutions of higher education can use FAFSA data to identify students who might benefit from additional support, such as coaching, career counseling, childcare, housing, or other basic needs, tutoring, or other services
that have been shown to help students from low-income families persevere in college. We at NCAN hope additional guidance will be forthcoming shortly to address this issue.
As always, we welcome your questions and will keep you posted!
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