NCAN Comments On Draft 2017-18 FAFSA Form

June 9, 2016

NCAN submitted the following comments to the U.S. Department of Education and Office of Federal Student Aid on the draft 2017-18 FAFSA form:

The National College Access Network (NCAN) applauds the move to using prior prior income year data for the 2017-18 FAFSA form and its availability in October instead of January. This change will provide great benefits for students as they can now enter their college search knowing their likely federal financial aid eligibility. In addition, more families will be able to use the IRS Data Retrieval Tool, decreasing FAFSA completion time and the likelihood of being selected for verification. With these changes, even more can be done to simplify the process of applying for Federal Student Aid, both as part of the FAFSA and for the verification process. Outlined below you will find proposed changes NCAN supports as well as recommendations for further improvement.  Thank you for this important opportunity to suggest advancements for students. 

1) The following changes to the FAFSA for 2017-18 are all improvements for NCAN’s population of low-income, first generation students and students of color access to federal financial aid

a. The move to “Early FAFSA” allowing for both the use of prior prior year income data for financial questions and moving the application availability date from January 1 to October 1 of the previous year will both help students more accurately and quickly complete the FAFSA as well as gain more time to explore their college options. 

b. On question 97, adding Medicaid recipients to the group of students who qualify for the simplified needs test will allow another group of students who have already demonstrated their need to have a streamlined pathway through the FAFSA form. 

c. United States Digital Services and Federal Student Aid partnership to review and streamline the FSA ID process will simplify the completion process. The current process is burdensome to students and NCAN encourages these two agencies to work together to improve it.

d. On the related topic of FAFSA verification, the April 1, 2016 Federal Register (Vol 83, No 63), states that students will no longer need to verify how they live on a very low income, the receipt of SNAP, or that they made child care payments. Taking away this additional paperwork burden for students will prevent students from getting waylaid in the verification process right before the semester begins. 

2) The following changes to the FAFSA for 2017-18 are detrimental to NCAN’s population of students as they increase the burden on the student to be able to access federal financial aid:

a. Eliminating state student grant agency access to the school list on the FAFSA is harmful to students because it will increase their burden in applying for state financial aid. The directions under “Step Six” of the draft FAFSA state that “All of the information you included on your FAFSA, with the exception of the list of colleges, will be sent to each of the colleges you list as well as your state student grant agency.” NCAN was a strong advocate of removing institutional access to the school list provided on the FAFSA, however believes that the unintended consequences of removing state student grant agency access will cause far more harm than good. This change will force many state agencies to create an additional state aid form or process, and every additional step decreases the chance that a student will access financial aid and continue on with their education. The original goal of the FAFSA in 1992 was to streamline the process and remove the need for duplicate forms. While NCAN does not agree with how many state legislatures choose to distribute their state aid dollars, the agencies tasked with distributing those dollars must follow their state requirements and are aiming to do so with as little burden to students as possible. Any action that would create additional state forms would be harmful to students.

b. Requiring a 4506-T causes an unnecessary and duplicative burden on students and does not provide any additional information to agencies or institutions providing financial aid. On the related topic of FAFSA verification, the April 1, 2016 Federal Register (Vol 83, No 63), states that:

For an individual who has not filed and, under IRS or other relevant taxing authority rules is not required to file a 2015 income tax return—
(1) A signed statement certifying—
(a) That the individual has not filed and is not required to file a 2015 income tax return; and
(b) The sources of 2015 income earned from work and the amount of income from each source;
(2) A copy of IRS Form W–2 2 for each source of 2015 employment income received or an equivalent document; and
(3) Confirmation of non-filing from the IRS or other relevant taxing authority dated on or after October 1, 2016.

Step 3 of the above process is a new requirement which will force students to provide a 4506-T during verification to prove that they did not file taxes, rather than only the signed statement confirming that they did not file. The 4506-T form simply says that taxes were not filed, but it does not verify that taxes did not need to be filed, so the federal government, states and institutions are gaining no additional information about students while making them acquire an additional form, particularly one that cannot be quickly accessed. As it can take up to 10 business days to retrieve this form, students who are flagged for verification near the beginning of classes may not be able to retrieve it and deliver to their school in time. Further, students who were flagged for verification during the 2016-17 season, who are then flagged for verification again in 2017-18 are currently exempt from having to re-verify given the repeat of financial information. However, non-tax filers in this category would still need to provide the 4506-T because it was not requirement for the 2016-17 year. Overall, this new requirement provides undue burden on students without providing any additional information to those awarding aid. 

3) NCAN proposes the following suggestion to improve the FAFSA completion experience for all students and families: expand the information available and populations able to use the IRS Data Retrieval Tool to further reduce the burden of completing the FAFSA. 

a. With the move to using prior prior year income data, NCAN strongly encourages the U.S. Department of Education to work with their partners at the Internal Revenue Service to see what additional fields could be added to the IRS Data Retrieval Tool now that taxes will be filed a full six months before the FAFSA process starts. Suggestions for expansion include transferring the data for questions about financial assets from tax schedules and making information from W2s available from the DRT for families who do not need to file tax forms. Additionally, ED and IRS should also explore if it is possible to add more categories of tax filers, such as married filing separately, to those who are able to use the Data Retrieval Tool.

b. With respect to the verification changes mentioned above in 2b, if additional document must be required for families who did not file taxes, NCAN supports the suggestion from the National Association of Student Financial Aid Administrators to incorporate this field into the IRS Data Retrieval Tool:

i. “Confirm for the student, parent or spouse that there is no record of a tax return on file, rather than forcing the applicant to obtain this information from the IRS. Currently, students and/or parents who do not file a tax return may be required to provide documentation of such status. The IRS filing deadline for PPY is more than a year before the FAFSA becomes available, and providing this information via the IRS-DRT would reduce administrative burden for both students and schools.” – NASFAA FAFSA 2017-18 Comments, 26 May 2016.


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