By Bill DeBaun, Senior Director, Data and Strategic Initiatives
Reading time: Five minutes
The National College Attainment Network (NCAN) has repeatedly highlighted universal FAFSA, or Free Application for Federal Student Aid, policies in recent years as more and more states have considered and adopted them. These policies, which generally
require high school seniors to submit or complete the FAFSA as part of high school graduation, serve to raise awareness about available financial aid, increase the salience and expectation of a key college-going milestone in high school, and improve
college enrollment rates.
Two recent studies expand the field’s knowledge of universal FAFSA policies and offer valuable insights for practitioners, policymakers, and the public alike. The first, "Mandatory FAFSA Policies Have Had Immediate Impact," comes from The Century Foundation’s (TCF) Peter Granville, Jaime Ramirez-Mendoza, and Jaden Mikoulinksii, released February 19. A week later The Education Trust’s Sayda Martinez-Alvarado
released "A Scan of State Universal FAFSA Policies." Both reports provide valuable insights into the effects of these policies.
TCF’s analysis breaks down, broadly into three main areas:
Effects of universal FAFSA on FAFSA completion and enrollment outcomes
Insights into successful implementation from California and Illinois; and
Considerations around universal FAFSA policies and undocumented students and students from mixed-status families.
Notably, TCF’s analysis focus on “mandatory” FAFSA policies, which “place a state-based requirement on the student.” California, the authors note, “technically places the requirement on school districts to confirm that every senior applies for aid, opts
out, or receives an exemption,” which for this author is a distinction without much of a practicable difference. Colorado, which unsuccessfully offered financial incentives to districts willing to adopt a FAFSA requirement, and Maryland, which “requires
school districts to provide their students with information about the FAFSA but does not mandate any student action” are clearly different.
TCF finds that states with mandatory FAFSA policies experienced notable upticks in FAFSA completion in their first year of implementation, a finding also observed by NCAN's previous analyses.
The policies were particularly effective in low-income districts and schools with previously low FAFSA completion rates. This is important because, “Across these states, the policy had its greatest impacts on schools where previously most students
did not complete the FAFSA, potentially creating new conversations about college that may not have occurred otherwise.”
Although FAFSA completion rates are often (but not always) correlated with community income, TCF further finds that, “In five of the seven states…the gap between high- and low-income districts narrowed after the policy’s implementation or flipped in favor
of low-income districts.”
“In five of the seven states…the gap between high- and low-income districts narrowed after the policy’s implementation or flipped in favor of low-income districts.”
The ultimate goal of universal FAFSA policies, however, should not be to inflate FAFSA completion rates, it should be to drive matriculation. TCF’s brief finds that across Louisiana, Illinois, Alabama, Texas, and California, states that implemented a
universal FAFSA policy prior to the class of 2024, the number of Pell Grant recipients “after policy enactment, relative to the rest of the nation, ranges from –0.2 percentage points to +6.7 percentage points. Across all five states, this translates
to 27,500 new annual Pell Grant recipients over expectation in one year.”
In terms of undergraduate enrollment, TCF finds, “Three states—Louisiana, Illinois, and California—show overperformance relative to the rest of the country of 3.5 percentage points, 3.8 percentage points, and 5.1 percentage points, respectively, while
Texas runs roughly equal to the rest of the country and Alabama trailed behind the rest of the country the same year.”
The Education Trust's report begins by lamenting, “Despite the availability of aid, a lack of clear information about the types of aid available and how the financial aid process works, and insufficient advising and guidance on how to navigate the system
and pay for college deters many students — particularly those of color and those from low-income backgrounds — from applying for financial aid and enrolling in college.” This is, unfortunately, a truth NCAN members are all too familiar with.
Ed Trust’s report analyzes 14 states with varying approaches to universal FAFSA policies, highlighting that while the core objective remains consistent, the execution differs based on state and regional contexts. Each state’s profile highlights its mechanisms,
opt out policies, state grant aid requirements, and whether the state has an alternative to FAFSA that would satisfy the policy. This is an extremely useful reference that documents the state of play and policy as of February 2025.
Sayda Martinez-Alvarado makes the following recommendations to “state legislators and state boards or departments of education”:
Publish data on alternative, state-specific financial aid application completion rates
Publish data on opt-out rates and track disparities
Address the gap between FAFSA submission and completion rates
Partner with college access organizations and local colleges and universities to boost FAFSA completion
Adopt universal FAFSA policies into statute
Make FAFSA information accessible to all families
Make FAFSA submission a graduation requirement but allow the school staff members closest to students to waive the requirement
The Education Trust brief comes to the same statistical conclusions as TCF’s: “Universal FAFSA completion policies have played an important role in boosting FAFSA submission and completion rates in the states that have implemented them. Even during the
2024-25 FAFSA cycle, which was riddled with delays, errors, and complications, states with universal FAFSA completion policies experienced a smaller decrease in submission and completion rates compared to the national average.”
These two new offerings from well-regarded policy organizations help to expand our knowledge of if, when, and how these policies make a big difference. The implementation of mandatory/universal FAFSA policies has shown immediate and positive effects on
FAFSA completion rates and postsecondary enrollment, particularly among underserved communities. Practitioners and policymakers should consider these findings when designing strategies to improve college access and affordability. By addressing both
procedural and perceptual barriers to financial aid, universal FAFSA policies can play a pivotal role in promoting educational opportunity.