The U.S. Education Department on Friday issued new implementation guidelines and an updated FAQ document for the upcoming changes to the Free Application for Federal Student Aid (FAFSA) process, which will take effect in the 2024-25 award year. Much of the guidance reiterates provisions from the FAFSA Simplification Act, but it also provides operational details and clarifications on various aspects.
Key points from the guidance include:
- Manual Review of Income Entry: The guidance emphasizes that income information will be transferred to the FAFSA from the IRS via the FUTURE Act Direct Data Exchange (FA-DDX). However, certain income items, such as the foreign earned income exclusion, will require manual entry by applicants or contributors (parents, stepparents, or spouses). The department is establishing a new process for financial aid administrators to assess the impact of foreign income exclusion on Pell Grant eligibility.
- Pell Grant Eligibility Changes: The FAFSA Simplification Act brings about significant shifts in Pell Grant eligibility, introducing new pathways for automatic maximum and minimum Pell Grant awards based on family income relative to federal poverty guidelines. The way Pell Grant awards are determined for less-than-full-time students also changes. The guidance confirms how Pell Grant eligibility will be determined starting in 2024-25 using the new formula detailed in the 2024-25 Draft Student Aid Index (SAI) and Pell Grant Eligibility Guide, as well as the elimination of the Pell Grant Payment and Disbursement Schedule.
- Treatment of Assets and Emergency Financial Assistance: The guidance clarifies that small businesses and family farms must now be reported as assets on the FAFSA. Institutions will need to differentiate between assets and principal residences. Emergency financial assistance, covering unexpected expenses for food, housing, materials, or transportation, will not be considered as "Other Financial Assistance."
- Limitation on Pell Grant Amount: The law now states that Pell Grants cannot exceed the cost of attendance (COA). Institutions can still award the full Pell Grant, but other Title IV aid cannot exceed the COA.
- Changes to Pell Grant Programs: Certain Pell Grant programs, such as the Iraq and Afghanistan Service Grant (IASG) and Children of Fallen Heroes (CFH) awards, are being redesignated under a Special Rule. Eligibility criteria for these programs transition, and students previously eligible under IASG or CFH criteria will still be eligible under the new rule.
- Negative Student Aid Index (SAI) and Packaging Aid: When packaging aid based on need, institutions should convert negative SAIs to zero to prevent students from receiving aid beyond the COA. However, negative SAIs can be considered for institutional or state aid.
- Multiple Family Members Enrolled: Families with more than one member in college will not receive favorable treatment in the SAI calculation. Institutions can use professional judgment to adjust COA or SAI based on individual circumstances.
- Provisional Independent Student Status: Starting from the 2024-25 award year, students indicating provisional independent status on the FAFSA will no longer face rejected Institutional Student Information Records (ISIRs). Institutions can approve a dependency override for these students to receive aid as independent students.
- Missing FAFSA Questions: The FAFSA will no longer include questions about student housing plans, interest in Federal Work-Study, or independent students' parental information. Institutions can separately ask these questions but cannot make them mandatory for awarding Title IV aid.
While the guidance addresses many aspects of the upcoming changes, some outstanding questions remain unanswered, such as specific scenarios involving divorced or separated parents. The department acknowledged the need for further updates and clarifications as institutions adapt to the new FAFSA provisions.
U.S. Education Department Dear Colleague Letter
FAFSA Simplification Questions and Answers