Action Plan

1. Delay state and institutional financial aid and commitment deadlines

States and postsecondary institutions with financial aid deadlines that fall before April 1, 2024, should delay the statewide financial aid deadline until then to give enough time for students and families to complete the form. Even states with priority deadlines should consider pushing them back until March 15 or later to avoid even the perception that students have missed the deadline. Colleges should also push back their commitment deadlines until at least June 1, 2024, to allow students enough time to receive and consider their options.

2. Align state budget and appropriation processes

Higher education appropriators need to be informed about the potential impact of the revised formula for determining financial aid awards. The changes to the federal process and formula will impact state spending level where state awards are connected to the federal student aid index and timing. Appropriators should be made aware of the potential disruption, that FAFSA forms (and many state applications for financial aid) will arrive later than usual, and that supplemental appropriations may be needed to meet the demand.

3. Adjust high school counseling processes

K-12 state agencies should be encouraged to extend their financial aid counseling plans to later this spring , especially in states that have universal FAFSA policies. FAFSA completion nights and dedicated time during the school day for supporting students in completing the form, including when delivered in partnership with community-based organizations, should be built into the schedule for February, March, April, and even beyond.

4. Encourage institutions to limit school-selected verification

Colleges have discretion to require a student to verify any information that is on the FAFSA or included in state or institutional aid calculations. When schools choose to verify an item other than those the Department of Education (ED) selects, they may delay disbursement of Title IV aid to students, even though they are prohibited from doing so when the item has no bearing on Title IV aid. State leaders should encourage postsecondary institutions to limit verification to what is required by ED to ensure that Title IV funds are disbursed as soon as possible.

5. Launch an outreach and communications plan to key stakeholders

Deliver targeted messages through multiple avenues to the people who will implement and be impacted by this policy change. Counselors, state and local education agency staff, college administrators, college counselors, families, and students should receive timely, clear messages to make them aware of the changes that are coming and help them prepare.