As States Expand FAFSA Data Sharing, More Should Consider What’s Being Shared and How

Bill DeBaun, Senior Director of Data and Strategic Initiatives, and Caroline Doglio, Program Associate

Read time: Six minutes

Most states now allow K-12 practitioners like school counselors to access student-level data on Free Application for Federal Student Aid (FAFSA) completion, but the nature of that information and the process for accessing it vary widely. The past five or so years have seen a massive expansion in the availability of this data that is commensurate with increases in statewide FAFSA completion activities and campaigns more broadly. Despite this, states may not be aware of how their peers are provisioning student-level FAFSA completion data, and the National College Attainment Network (NCAN) is unaware of any broad analyses that would allow states to make comparisons.

The US Department of Education, through Federal Student Aid, allows states to access student-level FAFSA completion data through the Student Aid Internet Gateway (SAIG). Once state education agencies enter into a SAIG Participation Agreement, they are then permitted to share students’ FAFSA completion statuses with local educational agencies, secondary schools, or other entities in order to facilitate providing assistance to students in completing the FAFSA. NCAN’s current understanding is that all 50 states now have at least one agency with a signed SAIG Participation Agreement for this purpose, but what happens from there varies considerably.

“Provisioning student-level FAFSA completion data” is one of eight state-level college and career readiness policies and practices that NCAN keeps track of through an interactive dashboard. At the time of this writing, just eight states aren’t sharing student-level FAFSA completion data with school districts or don’t have a clear process for doing so. The remaining states have a process whereby districts can sign a data use agreement with the state (either on paper or online) to get the flow of student-level FAFSA completion data turned on. Here's an example of such a state-local education agency (LEA) agreement from the Alabama Commission on Higher Education. The previously-mentioned dashboard has links to all of the other state-LEA agreements we were able to find (roll over the state on the map).

States can improve their FAFSA data sharing practices by making it easier for local education agencies to opt into accessing the data (for example by having the agreement appear online), removing red tape from accessing the data, and making sure it’s updated in a timely manner.

Per usual, access to these FAFSA completion data isn’t a “data is good for its own sake” kind of thing. Student-level FAFSA completion data is useful in the actual practice of postsecondary advising. Counselors can use it for, for example, measuring progress in FAFSA completion campaigns, conducting outreach to students and families, and triaging student support. Making the process for LEAs to access and work with this data clear and easy will make it easier to increase FAFSA completion rates through more effective FAFSA completion programming and initiatives.

Once the data starts flowing from states to LEAs, though, what’s included in it? NCAN reached out to agencies in all 50 states to try to better understand that question. We asked about whether practitioners could see each of the following indicators:

• Submission date: The date on which a student first submitted the FAFSA.
• Processed date: The date on which Federal Student Aid processed a student’s FAFSA.
• Completed/submitted/not submitted flag: An indicator showing every student’s FAFSA completion status, whether they submitted or not.
• Student missing signature indicator
• Parent missing signature indicator
• Verification indicator: Student selected for further FAFSA verification.
• Other error codes on a student’s ISIR

We also asked states if they track data access by districts, schools, or individual users to get a sense of measuring the take-up rate for the data.

Through March 1, 2023, NCAN received responses from, otherwise was able to find information from, 32 states. Incidentally, if you’re from one of the remaining 18 from which we don’t have data – we’d love to hear from you. Please contact NCAN Program Associate Caroline Doglio at doglioc@ncan.org.

The counts and percentages of states who provide each of the above data points are below.

A table of state-by-state responses appears at the end of this post.

Unsurprisingly, since this is the primary use case for these data, most respondent states said they have an indicator for submission or completion status. The six who did not have such a flag used either submission or processed dates for essentially the same purpose. This is the big ticket item: district and school personnel have to have this data point so that they understand who has and hasn’t completed the FAFSA and to whom to triage additional support so FAFSA completion rates can increase.

About 60% of respondent states reported providing information about a student being selected for FAFSA verification, this is important because being selected for verification results in many eligible students not receiving federal financial aid. Practitioners being able to see who was selected for verification means those students can get the support they need to resolve that part of the process.

Just six states said that they can track who was accessing student-level FAFSA completion data in some fashion, but none said they were doing it in any systematic way or using that data for any purpose. Theoretically, states tracking access could follow up with districts who they can see are not using the data; this would increase data usage.

Another practice that would increase data usage is expanding the number of users with access to it. Although this wasn’t a question NCAN asked states about during data collection for this analysis, we’ve heard scattered reports from across the country about state policies that, for example, cap the number of users in a district or school who are authorized to view student-level FAFSA completion data.

Wisconsin is such a state, where only one user per school district is authorized as the “detail FAFSA use (a district’s homeless liaison can also be assigned as an “economic FAFSA user”). This would be tricky even in a small, single high school district, but the resulting implications and challenges represented are staggering in large districts. Milwaukee, for example, has more than a dozen high schools, and yet there is only one (or maybe two) users for the entire district authorized to see student-level FAFSA completion data. Wisconsin is hardly the only example of this kind of practice, just a prominent. Other states are no doubt putting up similar barriers and red tape that gets in the way of connecting FAFSA completion data to financial aid advising. NCAN is working to secure guidance for states about this important topic; the expansion of access to student-level FAFSA completion data has been a tremendous success, but throttling access to these data will inevitably also impede the FAFSA completion process.

As more and more states engage in FAFSA completion initiatives and encourage their districts and schools to do the same, access to student-level FAFSA completion data is critical. States should consider whether they are providing the right data points to the right practitioners in a clear, timely, accessible manner that is reasonably free of red tape (while protecting student data). States with questions, comments, or concerns about how to do this, or how their peers are doing it, or who want to make changes to the chart below capturing their data elements, are welcome to reach out to NCAN Senior Director of Data and Strategic Initiatives Bill DeBaun at debaunb@ncan.org.

Read More:

• How Will NCAN Help You Get Ready for the New Better FAFSA?
• FAFSA Fixes for Youth Experiencing Homelessness and Foster Youth
• Top 10 Changes Coming to the Better FAFSA