Mandatory FAFSA Policies

by Dr. Ellie Bruecker, Senior Research Associate, SHSF

Yesterday, Inside Higher Ed reported that lawmakers in at least 6 states (Florida, Hawaii, Indiana, Nebraska, New York, and South Carolina) are currently considering legislation to require FAFSA completion for high school graduation. Since Louisiana implemented the first statewide requirement for FAFSA completion, states around the country have followed suit, or thought about it. Illinois, Texas, California, and Alabama have all implemented state-level mandatory FAFSA policies, while Colorado has established a grant program for school districts that choose to opt-in to a FAFSA completion requirement. Another 13 states and Washington, D.C. have considered mandatory FAFSA legislation or are considering it in their current legislative sessions. A few states have proposed the idea in their legislatures multiple times.

Last summer, I defended my doctoral dissertation exploring school-level FAFSA completion across the country, interventions to help students complete the FAFSA, and the effects of the mandatory FAFSA policy in Louisiana. Given the number of states putting mandatory FAFSA policies on the books or considering legislation to do so, I think it’s important to talk through the nuances of these policies.

Don’t worry, I’ll keep it a bit shorter than 131 pages this time. But maybe a little longer than the original Twitter thread.

Before we start, it’s important to me that I clarify: these are just my personal reflections. There are people and organizations that I deeply respect who enthusiastically support mandatory FAFSA policies, and I’ve learned a lot from talking about this policy idea with them. After studying the FAFSA for several years, my conclusion is that mandatory FAFSA policies are not necessarily bad — but I also don’t think they’re very good.

First, I have concerns about privacy with these policies, especially with regard to how they might affect students who are undocumented and students who have undocumented parents. Requiring the FAFSA — or an alternate opt-out form, or separate state financial aid form — puts these students in a position where they have to (implicitly or explicitly) disclose their family’s status and their current addresses.

While this data should be protected by FERPA and we have not seen evidence that it has been used to target students or their families, we can’t be sure that it never will be. Perhaps that sounds a little paranoid, but in the current political environment, I think it’s easy to see why undocumented students might be afraid to submit their information. In California, Colorado, Illinois, and Texas, undocumented students are eligible for state financial aid and can complete an alternative form. In Alabama and Louisiana, there is no alternative form, and undocumented students would need to complete an opt-out form to satisfy the graduation requirement. Those opt-out forms don’t require an explanation and it’s absolutely a good idea to offer state financial aid to resident students whose citizenship status makes them ineligible for federal aid. However, I’m still troubled by the idea of requiring undocumented students to complete an alternative application or report their home address on an opt-out form. Currently, there’s no research or public disclosure about what happens to all of these forms after submission that I’m aware of. (Note: I did some research on this for SHSF, and I’m happy to share additional details with folks who may be interested.)

Do I think it’s better that undocumented students in states that offer them financial aid simply don’t apply? Definitely not! Undocumented students deserve financial aid, and they already face additional barriers to college enrollment even when aid is available to them. I’m not an expert on immigration, nor on the laws surrounding data like this; I can’t offer a better solution here, and I’m not entirely sure there is one. But I think any conversation around mandatory FAFSA policies must address the potential obstacles for undocumented students and families and other vulnerable populations who will face additional hurdles to meet the requirement.

Second, I am very much opposed to state FAFSA mandates that don’t come with additional funding or assistance to schools. High school counselors are already swamped, and getting more students to complete will likely require the greatest lift in schools with the fewest resources. My analysis found that, on average, schools serving the highest proportion of low-income students had FAFSA completion rates 9 percentage points lower than schools serving the fewest low-income students; in some states that gap was higher than 20 percentage points. And school districts with the highest rates of poverty often receive less in local and state funding than districts with the lowest rates of poverty. I think Colorado has created a policy that does this most efficiently, offering grant aid to schools that choose to enforce a FAFSA requirement for graduation. And I know that Louisiana more than doubled the number of FAFSA completion events statewide, where volunteering financial aid officers provided one-on-one assistance to students and families completing the FAFSA. It’s critical that states considering mandatory FAFSA policies now ensure that they’re providing additional funding and supports to help schools meet the new requirement. States simply cannot ask schools to do more without offering the necessary assistance — especially during this period of educator burn-out and high turnover.

All that said, I don’t think mandatory FAFSA policies are necessarily bad. I haven’t seen anything that suggests these policies have negatively affected high school graduation rates, nor evidence of direct harm caused by the policies in the states that have already enacted them.

But I also don’t see them having the impact we really want on college enrollment. In Louisiana, the mandatory FAFSA policy skyrocketed FAFSA completion among public high school seniors: from 48% in 2014–15 (well below the national average) to 85% by 2018–19 (the highest in the nation). That effect was not uniform across schools, though; some schools already had high FAFSA completion rates, while others lagged behind. In evaluating Louisiana’s policy for my dissertation, I compared the high schools that experienced the biggest increase in FAFSA completion rates after mandatory FAFSA to schools that experienced somewhat smaller increases or effectively no increase. Ultimately, I found a 0.8 percentage point increase in college-going rates among schools that improved their FAFSA completion rates the most following the mandatory FAFSA policy.

Increasing enrollment to any degree is a positive outcome. No matter how small, I don’t discount that improvement in the slightest. Still, it’s critical that we interrogate whether those positive impacts are distributed equitably. My findings suggest that inequality is maintained among these schools. I found that the increase in enrollment was driven by schools serving lower proportions of Black students and low-income students. Racial and economic disparities in enrollment persisted, and some equity gaps actually grew.

There’s an important caveat here: my dissertation research was completed very early in the life of mandatory FAFSA policies! It’s entirely possible that years down the road, mandatory FAFSA policies will have increased college enrollment long-term. Personally, that’s not my hypothesis, but I want to acknowledge that I’m testing the effects of a relatively new policy here.

So why do I think that mandatory FAFSA policies have (so far) not produced the college enrollment outcomes we might have hoped for? My position on the FAFSA has always been that completing it does very little on its own. If you complete the FAFSA, but don’t apply to colleges, what information does the FAFSA really give you? Not much. If you complete the FAFSA, this is what you get:

This results page (the Student Aid Report) doesn’t tell you how much aid you’ll receive or what college will cost. Even if students have information on the value of the Pell Grant, they’ll have no sense of whether they’ll receive state or institutional aid. Most of them are likely overestimating the cost of college, too. Completing the FAFSA alone tells students very little about whether college is affordable to them. Students are able to answer that question when they receive award letters (if they’re done well!) from colleges–which they can only get if they’ve applied and been admitted. If states require students to complete the FAFSA, but don’t ensure they have the support they need to navigate the rest of the college access process, I don’t believe we’ll meaningfully improve college-going rates.

Improving FAFSA filing rates is a good thing on its own. We absolutely want more students to complete the FAFSA. Still, I think the ultimate goal is bigger than that, and mandatory FAFSA seems like a way for states to say “hey, we’re doing something!” without really doing much. I think we need to fight for mandatory FAFSA policies to come with more. Increased funding to hire additional counselors and more one-on-one FAFSA assistance events. Better access to student-level filing data for counselors so they can target direct assistance. In addition to efforts to improve FAFSA completion, states must make equal efforts to help students apply to colleges and interpret financial aid offers, and ensure that admitted students enroll, matriculate, and graduate.

Perhaps most of all, states need to invest more in financial aid and advertise the programs to students early. Tennessee had great FAFSA filing rates before mandatory FAFSA came on the scene, and I think that has a lot to do with its very well-marketed free college program.

In the end, I just can’t get excited about mandatory FAFSA. As a quote in the article says, it’s “low-hanging fruit” for states. And I think students deserve better than policies that are quick wins for lawmakers without the impact that they need.

Author’s note: In my professional capacity an employee of a private non-operating foundation, I cannot take a position on specific legislation. This post reflects on the nuances of mandatory FAFSA policies and their existing implementation in multiple states.