As FAFSA, or Free Application for Federal Student Aid, completion season is well underway, the National College Attainment Network (NCAN) continues to hear questions about how best to support students from mixed-status families. We know questions remain
about the privacy protections that are in place for FAFSA contributors without Social Security numbers (SSN). Although the Higher Education Act prohibits the use of data for any purpose other than
determining and awarding federal financial assistance, NCAN cannot assure mixed-status students and families that data submitted to US Department of Education (ED), as part of the FAFSA process, will continue to be protected. We encourage our members
and the field at large to advise students whose parents (aka FAFSA Contributor) may not have an SSN about the risks and benefits of submitting a FAFSA on a case-by-case basis. While the Office of Federal Student Aid (FSA) has confirmed that ED has
not and will not share information that breaks the law, we understand many families’ confidence in this statement may not be as certain under the current administration.
This guidance covers two topics: first, it explains the changes to the 2026-27 FAFSA. Second, we share a few additional resources for supporting families with mixed-status backgrounds. Read on to ensure you feel fully equipped to support families through
this year’s FAFSA process for the 2026-27 award year.
What’s different in the FAFSA process this year?
Students only need to enter an email address in order to invite a contributor, regardless of whether the contributor has an SSN or not. There is no more need for a student to match their contributor’s information (DOB, street address, etc.) exactly as
appears in their StudentAid.gov account or on any official document. This change matters because a student can now invite their contributor more easily - with a simple email address and without matching any other information - especially when an SSN
does not exist for said contributor.
Recommendations:
Students should begin the form and invite their FAFSA contributor with an email address. Remember to check spam/junk mail in case the invitation email with the code ends up there.
The code will also remain in the student’s studentaid.gov account where they can access it and give it to their parent, guardian or spouse at any time.
FAFSA nights should include both the student and contributor, if possible. There is no longer a need for separate FSA ID creation workshops or sessions.
What’s not different?
Even though there is now instant, real-time matching for contributors who do enter their SSN, those without an SSN must still answer a set of unique questions to verify their identity. Also, as in previous years, all contributors without an SSN, including
those with an Individual Taxpayer Identification Number (ITIN) will need to manually enter their financial information.
Recommendations:
Clarify to families of mixed-status backgrounds what information they will need to have, such as their filed income tax paperwork, or information they may need to start thinking about that could be on their credit report, such as previous addresses
or employers, or vehicles they may own or have previously owned.
Assure families they may also need to confirm the statement “I’m a parent or spouse of a student who is applying for aid, and I don’t have an SSN.” Assure them that the form is to see if the student is eligible for aid.
NCAN believes mixed-status families should make a thoughtful, well-informed personal decision about whether to submit identifying information to the federal government through the FAFSA. This guidance may be particularly relevant to mixed-status families
who would be participating in the federal aid application process for the first time and have not otherwise submitted personal identifying information through any other federal agency such as the IRS We are confident that our members are equipped to have responsible and sensitive conversations and guidance for these families. Every family is unique, and we are proud of the work of all the knowledgeable and caring adults working to advise students
through the financial aid process.
Finally, NCAN member ContigoEd has shared this resource we have found extremely relevant. While the context addresses the admission process as a whole, we found the framework can be
applied to any advising/guidance process with mixed-status families.
NCAN believes in the transformative power of education and the incredible potential of these students who are US citizens and fully entitled to federal student aid. We will continue to seek out and advocate for policy alternatives that support higher
education for all students.
Q: Can my or my contributor’s information be used for immigration enforcement? A: ED is permitted by law to share information with other federal agencies for both civil and criminal law enforcement purposes. For example, if under
one scenario a federal agency follows required processes to request information from ED (such as providing the request in writing from the head of the agency, specifying the information being requested, and specifying the law enforcement purpose for
the request), ED may provide the information. ED reviews any such request to ensure it complies with all legal requirements.
While we cannot speak to changes that another administration might make, the Biden administration has prioritized protecting the privacy and data of those that create a StudentAid.gov account or fill out the FAFSA form, and we have not provided information
for immigration enforcement purposes.
Q: Should I fill out my FAFSA? A: Whether or not you should fill out a FAFSA is a decision that you should make with your family. It is important to note that, to the extent that you or a contributor has already provided ED with
information when creating a StudentAid.gov account or previously filling out the FAFSA, ED likely still has that information. In such an instance, ED would only be adding updated information to the ED's systems (e.g., income information, change in
address) were you to submit a new FAFSA. Moreover, any future changes to how ED's data are used or shared could apply to data already in its possession, as well as data it collects after the changes.
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