MEFA Institute^™: How to Execute FAFSA Simplification at Your College

  Okay, welcome everyone. Good afternoon and thank you for joining us. Um, this is MIFA's webinar, How to Execute FAFSA Simplification at Your College, and we have, um, I'm Julie Shields Rutina, and I am the Director of College Planning, Education, and Training here at MIFA, and I'm joined by my colleague, Stephanie Wells, Who's the director of college relations.

Thank you for joining us. And thank you, Jill and, uh, Gail for, uh, helping out today. It's great information. Thank you. I'll be helping out answering questions behind the scenes and throwing questions to Gail and Jill. Thank you, Steph. And yes, we're so fortunate to have two wonderful presenters today. We have Jill Dajon, who is Senior Policy Analyst at NASFA, and Gail Holt, who's Dean of Financial Aid at Amherst College, and we are not, we have a large group today, and there's a lot to talk about.

So I am going to turn it right over to you. I'm going to share the to you. The presentation on screen, and I will also be helping out behind the scenes and moderating. So let me share my screen.

All right. And I guess I will turn it over to you, Jill. Thank you so much, Julie and Stephanie. I'll start us off with our agenda. Could you go to that slide, please, Julie. So I guess I'll start things off with maybe a little bit of expectation setting. We are assuming in this webinar, since we are inching closer to full implementation of the FAFSA Simplification Act, we're assuming a basic level of familiarity with the FAFSA Simplification Act.

So we won't spend a lot of time going over every little detail. We want to kind of focus on the things that are the most relevant to now. So we'll be talking a lot about the FAFSA. Um, and other things that are relevant for the 24 25 year, assuming that, um, the basics are already sort of in your heads. Um, of course, as questions come up, feel free to ask them.

And I'd also like to just share that, of course, um, there are still a lot of unknowns, things that the Department of Education hasn't even decided, so. We don't know them as presenters because the department doesn't know them, or maybe the department knows them, but they haven't shared them with us. So please bear with us.

Um, if we don't know an answer, um, I can almost assure you that if you have a question, we have it too. And we've probably already put it out to the department and we're waiting, um, and the department's just kind of plugging away and making sure that they're ready for December. So with all that said, um, what we're going to talk about today is just sort of a quick overview of the key provisions of FAFSA simplification.

Then we'll talk about the changes to the FAFSA form and experience and Department of Education and FAFSA simplification resources, and then Gail will speak to us. about FAFSA simplification, um, implementation guidance we've received to date, focusing on some of the weedier items that may have escaped your notice earlier.

She'll follow that up with a discussion about special and unusual circumstances and preparing others on campus for FAFSA simplification. Since this is Mainly a financial aid office effort, but certainly does involve many, um, many partners on your campuses. And I will wrap things up with some NASPR resources on FAFSA simplification.

Can we go to the 2425 FAFSA concept slide? There we go. Already there. Thank you, Julie. Um, so first up. We have some new concepts in the federal student aid application process. I think it's important to sort of cover those first. So if those of you, if anyone here was able to attend the Department of Education's demonstration of the online FAFSA this summer, that webinar is recorded if you haven't seen it yet, um, but, um, you should have been able to see from there or are able to see there, um, that the applicant experience is going to be much, much different from the current online experience for completing the FAFSA.

So the first and the biggest, I think, is with respect to this new roles based process. So where there used to be sort of this, you know, one FAFSA that the applicant and the parents or spouse were working from, there are sort of, you know, it's not exactly the, you know, this isn't exactly what's happening, but it's almost like three distinct Applications that get all merged together.

So everyone has a role. The student, if they're dependent, their parents, if they're independent and married, their spouse, um, an independent student, of course, they're the only person who has a role, but the process is a roles based process, which is new, and what the Department of Education envisions is a flow Where the applicant starts the process, they go in, they log into the FAFSA, they start answering all of their questions, and then they're inviting their other people to complete their roles.

The other people are called contributors. And so if you're a dependent student, again, your parents are a contributor. If you're a married independent student, your spouse may be a contributor. So you invite whoever's relevant, um, and you're instructed through the FAFSA to identify whose information needs to be on the FAFSA.

And an invitation goes out to them by email. They get that email, they accept the invitation, they go in, they complete their piece. And as each contributor completes their piece, it gets all merged together into the student's FAFSA. Once everyone's role is complete, the FAFSA is processed, sent off to the schools, the student lists on the FAFSA, um, and then you get the, um, the ICERF the way that you would get it now.

The other big thing, of course, is that because income information is now going to come from the Internal Revenue Service instead of being manually entered or transferred via the data retrieval tool like it is now, All these contributors have to give their approval or their consent for the IRS data transfer, right?

Your income information is held by the IRS. They take that very seriously, and they protect it pretty tightly. We should all be grateful for that as taxpayers. So if they're going to share that outside of the IRS, they need you to say that it's okay. So there's this new concept as well, where you give consent to authorize the IRS to share information with the Department of Education.

And if any contributor is married and filing a joint tax return, consent just has to come from one of those joint filers, and the tax information would come from there. But if you've got people filing individually, they each need to give their own consent. All contributors will be required to have an FSA ID, even those who don't have a social security number, if they want to complete their contributor role online.

So paper FAFSA, you don't have to have one, but to complete online, everyone has to have an FSA ID. They don't need to have an FSA ID to be invited. By the students, so the student can start the process, invite someone, and then once that person accepts the invitation, they can start the FSA ID process, but they have to have an FSA ID to actually complete their part of the FAFSA.

And a question I've heard come up before is what information a student actually needs to have to invite somebody to contribute to their FAFSA. And so what they need to have is the contributors name, their social security number. Their date of birth and their email address. And if the person does not have a social security number, they can still be invited to be a contributor.

There's a checkbox. So they'll say, you know, name, SSN, date of birth, email address. Next to SSN, there'll be a box that says, my contributor doesn't have a social security number. You can check that off and they can still be invited to complete the FAFSA and they would be able to complete the FAFSA without a social security number.

So FSA IDs are still taking about three days to be verified and created, um, as you're all probably well familiar with the FSA ID process. Um, there's actually a step. The student fills out the relevant information. It actually gets sent out to the Social Security Administration to compare name, date of birth, and Social Security number against those records to make sure that the person who is saying they're filling out the FAFSA is actually that person, and then your FSA ID is issued within three days.

That won't change. It'll still take the same amount of time. Um, schools can encourage students and their parents to create FSA IDs. Now, if they haven't, if they don't have one from past years, your old one works just because the fast is changing. The FSA ID is not so you can still use your FSA ID that you created in a prior year.

But for new students, new parents They can create an FSA ID anytime. Um, there will also be a new process for the FSA ID to allow individuals who don't have a social security number to create an FSA ID. That process isn't yet finalized with the Department of Education. So, um, our understanding is that there's all that identity verification piece that takes place through the Social Security Administration.

Would take place instead through one of the credit reporting bureaus. The details haven't yet been finalized there so the department is working on it. They have said the process is expected to be up in time for the release of the online FAFSA in December. But that's all we we know for now in terms of people without SSNs getting FSA IDs but that's new for this year.

Previously you couldn't get an FSA ID if you didn't have a social security number. Can we go to the next slide, please?

There we go. Um, so one of the most significant changes for the 2425 FAFSA is this direct data sharing of tax information between the IRS and the Department of Education, thanks to authority that was granted in the Future Act, which actually went into law in 2019. So applicants and contributors, as I mentioned before, must consent to have their taxpayer information, their federal taxpayer information, or FTI, sent to the Department of Education by the IRS.

Not only does the IRS need to have your permission to share that information, but also the Department of Education is requiring Everyone to provide their consent. So that is a really critical component of the new FAFSA. Everyone must say it's okay for the Department of Education to ask for tax information from the IRS.

If you don't consent, you are not eligible for federal student aid. If you're a dependent student and your parent doesn't consent, you are not, the dependent student is not eligible for federal student aid. There isn't a way around this consent process. If you do give consent, and the Department of Ed for some reason cannot get your information from the IRS, in that case, you can manually enter your income information.

So there are going to be situations where, for instance, um, marital status has changed from the time the, um, you know, the prior prior year tax return was filed and the FAFSA was filed. And so there's a mismatch between the type of tax return that's on record with the IRS and what the FAFSA's. Marital status says in those cases that apartments not going to be able to get taxpayer information from the IRS because you might have a situation where parents have divorced and the IRS wouldn't have authorization to be able to get the other parents.

joint tax return with the custodial parent. So in those cases, the department will still collect consent, go to the IRS, try to get that information, and when they identify that mismatch, then ask for manual information about income. But there's no way around applicants, their parents, their spouses, anyone who's a required contributor on the FAFSA from giving their consent for the Department of Education to at least try to get income information from the IRS.

Then there's this workaround for when they can't get it for you to be able to provide it in a different way.

Next up, um, you can advance two slides. Julie will be talking about the 24 25 FAFSA and resources that the Department of Education has. FAFSA FAFSA simplification. So here we are draft FAFSA. Um, we're still waiting, of course, for the 24 25 online FAFSA, but we have seen now two drafts of the paper FAFSA.

The department released the first draft back in March, and the second draft was just released last month, and there is a 30 day public comment period on that second draft that is open now. Both the paper FAFSA and the FAFSA submission summary, which replaces the student aid report, are included in this package, as well as the incarcerated applicant form for students enrolled in prison education programs.

NASFA submitted comments back in the summer during that first round of public comments. And several of those are addressed in the second draft that was released last month, which was good news. Uh, the department has indicated that they were not able to get all the changes that they planned to implement into this second draft.

They were sort of in a race against time between reading all those public comments, getting the second draft updated, and then getting it out there for public comment. And they have things they know that they need to change. That are not shown in this second draft. So it's frustrating because, of course, we'd like to see a second draft that is as close as possible to the final that it could be.

But it is a little reassuring and that if there is something that's really blatantly wrong that you didn't see changed between the first draft and the second draft. It doesn't necessarily mean that the department isn't working on it. It might just mean that they are literally still working on it couldn't get it into the second draft.

Next slide please. We're already there. Thank you. Some notable changes to the second FAFSA draft from the first iteration are some language changes. If you've taken a look at this, you may have noticed that before, when you were talking about you had sort of a student section, you had a parent section, and then you had what was called other parent, and that was meant for someone else in the student's household who is a parent.

So either. Parents biological or legal parents are married to each other. Um, remarried with a parent and a stepparent. Um, or student has two legal parents who live together who aren't married. Um, the department changed that from other parent to parent spouse or partner. And the rationale behind that was that, um, there were a lot of concerns from the first round of comments that they got that many people confused other parent with non custodial parent.

And we're asking why is the department now collecting non custodial parent information when they never did before. They are not that was not the intention. Um, the law is still very much the same. The student has a custodial parent and, you know, whichever other parent is in that household, their information is on the FAFSA, but non custodial information is still not collected on the FAFSA.

They wanted to eliminate the possibility of confusion, so they changed it from other parent to parent, spouse, or partner to better reflect whose information goes on the FAFSA. It's also possibly prone to confusion. Um, we've heard some from people already saying, well, that's not super clear either. Um, I don't, I can't think of something that would be exceptionally clear.

This seems a little clearer in my opinion. Um, and we should keep in mind this is the paper form. This is something that point one 5 percent of applicants actually fill out the rest of students 99 percent plus fill out the online FAFSA. The parent wizard will be on the parent FAFSA, which should hopefully guide people a lot better through figuring out whose information goes here.

So, of course, we want to have the best instructions possible on the paper FAFSA, but we might have to live with the fact that there isn't a great solution for how to identify the other parent whose information needs to be on the FAFSA.

The forms also pretty significantly reorganized from the last draft. The department took a good deal of instruction text and actually moved it from the end of the FAFSA in a note section to a more prominent place way up top on the FAFSA. Um, so things like, um, who should complete the FAFSA, whose information should be on the FAFSA.

is now in this new section that they've moved up top called completing the FAFSA form. So you sort of get the instructions about whose information goes on the FAFSA before you encounter those questions, as opposed to encountering those questions and then having to refer back to the notes section. So hopefully that'll sort of prepare people a little bit better for the questions that are coming, or at least when they see those questions they'll be like, Oh, I just saw that.

Let me go back and read those instructions again.

I mentioned before that several of NASFA's suggestions are reflected in this second draft of the FAFSA. Some big ones that we were happy to see in there were some clarifying language around the new student gender and student race and ethnicity questions. The department was clear in those questions that they would not be used in determining eligibility and that they were for research purposes only.

We really wanted to see stronger language that assured students. that schools wouldn't even see their answers to these questions. We thought that that information was really important so that students knew that there wasn't any possible way for a school to be able to use their answers to those questions to make an admissions decision or a financial aid decision.

And the department took that advice and added that language. So we're really happy to see that. Um, the other question that we, um, we managed our suggestions resulted in some changes, um, had to do with the wording of a question that gets at whether a student is a first generation college student or not.

The original language only asked about whether either parent had attended college. And our understanding from hearing from our members was that many institutions and states have different definitions. There isn't a single definition of our first generation students. So some based on whether either parent attended college, some base it whether either parent graduated from college.

So we got some language changes in there to sort of address every potential scenario where both parents may have attended and not completed. At least one parent may have completed. Nobody ever attended or completed. So Hopefully, however you define first generation status, you'll be able to get that information from the FAFSA with those language changes.

The comments on the second draft of the 2425 FAFSA are due on October 16th. So week after next, uh, NASPA will be sharing next week in our today's news, um, a draft of our comments. We're trying to do that more whenever we have comments putting them out to the membership about a week or so before they're due, so that if you're interested in drafting your own comments, you can Copy those or borrow heavily from them to inform your own comments.

Um, or also you can read them and give us some feedback and tell us what we missed so we can make sure that all of our comments are really thorough and cover everything. And we strongly encourage members to either let us know what you'd like to see in our comments or to comment yourselves. In either way, you can send those to our policy mailbox at policy at nasdaq.

org.

Can we go to the next slide? Outstanding FAFSA issues. Let's see. 24, 25. Sorry. Yeah. All right. That's the next one. That's the next one. Um, I mentioned at the front, I'll say it again. We continue to have A number of unanswered questions related to the FAFSA for 2425, the Department of Ed is very much in the process of making this thing.

They have not answered every question. And so as they come up from us, we send them over to them. Many of them. They already knew about and said we're working on it every once in a while. They say, oh, that's not what we thought of. But thanks for bringing it up. So we're just going to keep doing that. You all know we've all known for some time the FAFSA would be delayed.

No updates there. Um, from the December date, the department has said in December. Um, we don't have a range of dates. We don't know if it will be the beginning or the end. Um, I would bank on the end. Um, you know, certainly make plans if your campus is going to be closed during the winter holidays. Um, and you think that you'll need.

Staff there, you know, making plans. I know NASF is doing that just in case. Hopefully we don't need to have those contingency plans in place, but it's probably smart to be doing that. Luckily, we didn't have a government shutdown this week, which could have potentially delayed the release more so. Glad we don't have to talk about that today.

You may have seen or heard from your students that the department has started communicating with them about the delay. The reason they timed it around now at the beginning of October was in part because they worried that students would on October 1 if they were used to filling out their FAFSA then.

Go out to the FAFSA website, see the 23 24 application, fill that out again, um, or fill it out for the first time and think they were done for next year. So they wanted to make sure that students knew you can't get the 24 25 application yet. It's coming out in December. Don't fill out the 23 24 one and assume that you've done what you need to do.

The department also just, um, last week released a 24 25 FAFSA prototype website. So, um, hopefully you saw that. We announced it in our today's newsletter, um, one day this week. The only place I saw it announced from the Department of Ed was actually on the FSA tech list serve, so some of you may have missed it if you're not there.

Um, this is somewhere in between a demo site and the a static thing. Um, you know, a little better than something static, a little worse than an actual demo. Um, they've been very clear that it is not a demonstration site. So, um, you know, I think it's important to sort of set your expectations. I've gone and played around in it, and I think it's actually pretty nice to use.

I think it does accurately sort of simulate the online FAFSA experience, especially if you're going to be helping people to fill out the FAFSA, to be able to click through and just see what choosing different options. You know what path that takes you down. Um, as I mentioned, this isn't the demo. The demo is what we saw this summer and the Department of Education's webinar.

That was the way they described it to us. That was a copy of their production coding. So that was actually what they're working in right now. Um, this is different. They referred to this as fully decoupled. From the demo. So they just sort of made a separate product that is mimicking the online experience, but it's it's not meant to be robust.

So it may not have all the help text that you want to see the drop down options for like I know, like, um, college choices. And I think high school choice options. They're not all there. They didn't bother to put that all in here because It's not a copy of what they're working on. They just wanted to make a quick sort of replica of what they're working on.

And you know, it's the pro here is you can look at something now. The department had been saying all along, listen, we're developing the FAFSA for December. It's going to be ready in December. The demo is going to come out when the product comes out. This prototype allows us to play around in something a little sooner.

The con to that is that it might be a little buggier. Um, so, and I say all this just because, and I think that apartment did a good job when they rolled this out to of saying it, if you're finding issues with this prototype, it doesn't mean, oh, the fast is doomed. Oh my god, they're not, they're, they're way behind.

They haven't even done this, you know, whatever it might be. It's not meant to be, you know, an indication of their progress with the FAFSA. And I think that they don't want to hear us reporting like, Oh, hey, I think you got this wrong. And certainly if you're finding language that doesn't match up, that makes sense.

But, you know, if you can't pull down every possible title for eligible school, that was that was on purpose. Jill, I just wanted to make sure. I just wanted to make sure that. I showed the right slide. I feel like I maybe was a little behind. Oh, I'm sorry. I'm still on outstanding FAFSA issues. So we're, yeah, slide 10.

Yes, sorry, 10. Yeah, sorry, I got ahead and that's why, and then I, I apologize for that. Okay, we're, so this is where you can see the, the estimator and everything that was Jill, Jill was just talking about. Thank you. I'll, I'll keep up. No, all good. Yeah, it's, sadly the outstanding FAFSA issues list is A long one.

I've yet to move on. And wait, there's more. So on the FAFSA estimator, um, slight correction. This is an older slide. It was live. Um, it is now not. Um, it's been taken down. This Will be a calculator where students can enter information about their household their income and their assets and get an estimate of their essay I as well as an estimate of their Pell grant eligibility direct on eligibility and work study eligibility.

The Department of Education found some. Calculation errors. Um, Gail, I think you found some before the department did , so I'm sure some of you on this also, um, found some. So they intelligently took it down and they are working to fix it. And also, uh, Jill, just to highlight, uh, for those of you, um, who are looking for a more direct link to the prototype, it is in the question and answer, there's a question about it and I threw the link in there so you can get there if you wanna get that now.

I appreciate that. Yeah, this slide was old and I had all my notes say it's coming. Um, it's here. Okay, Julie, I am ready. I'm done with outstanding issues. Let's move on. Um, Just switching gears a little bit. I don't want to take too much more time because I know Gail has a lot of good stuff to share. Um, just, you know, the resources you've typically relied on from the department, like the ICER guide, technical references, comment codes, um, system specifications, those all used to be their own individual documents.

So the department has combined those all into a single document, um, called the FAFSA specifications guide. So it's been out for a while. Most of you have probably seen it. Um, I know we all get used to looking for things in certain places. So I'll frequently just be like googling ICER guide, you know, and you can get it that way.

But you know, just just to tuck that in your brains like they've actually kind of it's a good thing. I think we'll all get used to and it'll be great to have everything in one place. Um, but it's um, there's a lot up there. You can see I won't go through everything. But that's a list of just some of the resources that are up already.

It's getting updated pretty regularly. And has a lot of the resources that you're used to finding as like standalone documents. Um, on the next slide, um, this is about a, um, yeah, the draft SAI guide. Separate guide, also on the Department of Education's FAFSA Simplification Information website. Um, this has been developed to replace the EFC formula guide.

So, um, this is where you're going to find your hand calculation worksheets if you want a hand calc and SAI just for fun. All the tables for calculating the allowances and all the stuff you need for a hand calc. Um, there's also a crosswalk from EFC to SAI so you can see how terms have changed and how they, you know, what applied to EFC and what's it now called in referring to the SAI.

How automatic maximum and minimum Pell Grant eligibility is determined and the proration of Pell Grant eligibility, which has changed a lot to get into so we won't get into it today. But that's where you can find out how to prorate Pell Grants for less than full time enrollment. Um, and this document is still in draft form.

It's, it's, pretty complete, but it's in draft form and is expected to be finalized before the FAFSA comes out. And then, uh, last for me, um, I just wanted to point out that the 2425, uh, guidance for, um, FAFSA simplification. So you might remember from last year in the fall, they released this sort of comprehensive document of all of the Provisions of the FAFSA Simplification Act that were becoming effective for 23 24.

They did the same thing for 24 25. It's in this Dear Colleague letter, Gen 23 11, which came out in August. And the reason I'm kind of highlighting it, and the reason I put links in here, is because There's the DCL itself, which has some information, and then there's an attached Q& A, which is actually like a little hard to find in the Dear Colleague letter, and it has a ton of information.

So I put the two separate links, the DCL and the Q& A, um, just so that you can very clearly see, um, that there are two different documents, and they have a lot of, um, a lot of points of clarification that the department has made, like in all different places, you know. Someone said something in this webinar.

Someone said this at NASFA's conference. Someone told NASFA's TRA team that this was happening. This document is where a lot of those things that have been heard are actually put down in writing. So if you haven't checked out this document in the Q& A, it's going to answer a lot of the outstanding questions that you probably have.

With that, I'm going to let Gail talk about some of the especially noteworthy parts of the FAFSA Simplification Act. Great. So, uh, Julie, just advance to one slide so people can see that link, um, to all those very important things, especially the Gen 2311. So if anybody wants to do a screen grab to get that link, uh, you're welcome, or you're welcome to just, of course, Google Gen 2311 anytime you want.

So, um, I, you know, This has been just such an incredible privilege to be part of the working group. Um, I said yes to this in April of 2022. So we're, we are quickly approaching two years. Um, it didn't, I, you know, I remember it was still, it was still COVID and I was still working out of my dining room at the time.

And fortunately, lots has changed since then, but it's definitely been a great experience. Um, but there's so much. The point is that there's been so much evolution, so much to learn. Um, I have a very special folder in my web browser of FAFSA simplification links, so that, you know, really can keep all of the pieces together.

There's so many good links from NASFA. There's so many good links, uh, from the Department of Ed and Training. Um, And can, uh, National College Attainment Network is starting to promote some important things that are helpful for families and counselors. So, so there's lots of good things. So now that you've gotten a chance to get this information, Julie, go ahead.

And what we're going to talk about here in terms of these noteworthy items, you know, really. It takes, it takes all of us, um, maybe some a little bit more, a little bit less, but it takes about seven times to hear something, uh, before you really register and, and get it. So usually you need to hear it, you need to see it in order to remember it, so often if I hear something, I've forgotten it, if I see it, maybe I'll remember it half the time, um, and then for most of us, if we do it, Uh, we're going to really understand it, but we're not quite at the doing point.

We're almost there. Uh, and we're just going to touch here on some things that really feel like, uh, they're a little bit more, uh, specific than student aid index. I think we've gotten that pretty well. Um, you know, and some other key things like, uh, business assets, uh, are coming back into the calculation and farm assets.

I think people have those things. Um, but enrollment intensity and duration is, is the first thing that I will hit on. Um, the Pell Grant Annual Award, uh, we are all familiar with it being adjusted for enrollment, but now it is really going to be very specific as a percentage and the number of enrolled credits.

Um, so we're familiar with full time, we're familiar with three quarters time, we're familiar with half time and Less than halftime, but now you really need to be thinking and, and looking at how many credits is a student enrolled in of the, the 12 full-time credits, and what does that calculate as a percentage?

So, you know, when there are six credits or nine credits, that will be the most familiar. But if you have, um, the option for students to be enrolled for seven credits, uh, that's gonna calculate too. Uh, a specific 58%. And the Pell Grant needs to be adjusted to reflect that percentage. So pay attention to that.

Refer to, as Jill pointed out, um, the guidance around some examples so that you're understanding how to do that correctly. Um, less than nine months. This is also a shift for us where we're very familiar, um, that with, um, an alternate EFC when students are only enrolled for one semester or a part of the year.

Um, but there is going to be no alternate student aid index. So, the calculated student aid index will be used. Uh, for in, in, in packaging. So, um, of course, the, the minimum and the maximum Pell grants are going to be, uh, applied, but in other situations, um, it, it could be that. Periods other than a standard nine month, uh, enrollment, um, the cost of attendance will, will be for that specific period, um, but the full calculated SAI, it's SAI, uh, will be factored to determine eligibility, uh, for, for the bonds.

All right, let's Move on to the next change. Um, family size. So, family size, you know, you can start looking, uh, at your publications and your websites, but that's really replacing the term household, uh, size on the FAFSA. And family size is going to be there to represent, uh, and capture the IRS definition of the number of family members and specifically dependents in the applicant's household.

So the guidance and suggestion is to start stepping away from the term exemptions. Exemptions aren't represented in our current. Tax filing system. So really the you know, those individuals in the household that receive more than 50 percent of support and will continue to receive that support for the aid year.

In this case, 24 25 are those that will be included in the family size. And then because it is specific to the tax filing definitions. Uh, this is where there's also a variation in the few were cases of, uh, unborn children at the time, um, of, of filing, uh, are, are not to be included. So, um, certainly if there are changes, um, so if there's, if, if there's changes from the tax return that was filed, Um, then there can, you can update the family size when you are reporting it because on the FAFSA you will be reporting, families will be reporting the family size as of the date that they are submitting the application.

So even though it's not, if it is not representative of the tax return for 2022, they can update that information.

All right, next. Um, just going to emphasize again, um, you know, the contributor piece, uh, there's a lot to digest and hear, I think, in multiple ways as it relates to parent contributors and that changing and evolving term and concept, um, but contributing parents. Uh, are those who provide the majority of financial support in the previous 12 months.

So not, not the base tax year, but the previous 12 months, uh, there was a question about the parent wizard. Uh, the parent wizard is a tool that Ed is providing to help walk student applicants through the process of determining. Which parent will be reporting information on the, on the FAFSA. So there are sort of sequencing there.

Um, if a student hasn't received financial support from either a parent in the previous 12 months, then the question goes to, you know, which parent provided more financial support in the most recently applicable 12 months. Uh, so that may apply to our returning continuing students. And then if that level of discernment can't be answered.

Um, sort of the, the tiebreaker of sorts is that, um, The parent who has the greater income or assets will, will be the parent that will be supplying information on the FAFSA, along with, of course, their current spouse, as has, remains the case. There has been, uh, a lot of question about how child support. is factored into the determination of the reporting parent.

And the Department of Education has finalized, um, and reported that child support will be attributable to the parent that paid it. So this really is only going to be applicable if the student's financial support is coming from the, the majority of that support is coming from child support, then it will be that parent that paid the child support that will need to be the contributor and the reporting parent on that form.

I'm sure that will be nice and, uh, confusing. Um, what I have told, you know, my staff is that we are gonna do everything possible not to be the arbitrators of, um, you know, that parent information. And we're gonna do the best to provide the guidance, uh, and then take what, um, families provide to us unless there's just, uh, significant, conflicting information that just doesn't make sense.

All right. Um, Jill, you know, also covered, um, consent, but it's always again good to emphasize that consent will be required, um, whether or not there's actually a link to the, the IRS for the purposes of the direct data transfer. Or they're manually entering the income, um, because that consent is required because of the laws that are linked to the IRS, um, and the control of unclassified it.

Controlled information. So the use and access and attempt for access is very highly controlled and that consent, uh, gives approval to just attempt to obtain that information. It does not require any obligation to contribute. And I will say that in the demo, uh, and you'll see this in the prototype. Um, it is clearly highlighted to parents, uh, that providing information does not commit a parent to financially contributing, um, to the student's education.

It is simply required for assessment of the family situation. So that is, you know, prominently, uh, highlighted. All right. Next slide. Um, reporting assets is also another place where there is going to be a differentiation. Um, hopefully everybody caught that there's a very significant, um, change in the education savings accounts that will only be counted and reported as a parent asset if the account is designated for the student.

So basically other dependents accounts that are designated for other dependents will. Not be counted and included. This will get a little confusing if, if, uh, applicants are also completing the profile, uh, because that does not carry over, uh, to the, the institutional methodology in the profile questions.

So our, our former, um, uh, knowledge of the simple needs test and the auto zero, those concepts, uh, as they have been in the past, uh, are now eliminated. But that doesn't mean that, you know, some applicants will still be exempt from reporting assets. It's just that it's going to look a little bit different.

Um, so receiving A benefit from means tested federal benefit programs, uh, is, is still part of that. Uh, we are, guidance is being sought to clarify free and reduced price lunch eligibility because there are some instances where That eligibility is quite, uh, broad, but generally speaking, uh, individuals who will be exempt from reporting assets is targeted toward applicants, parent applicants that have an AGI of less than 60, 000, uh, which is higher than what the simple needs test has been in the past.

And of course, the auto zero. So that's great. Um, Thank you. And in cases where those individuals are not filing any schedules. So, you know, the, the common, the common schedules, and if they are filing a schedule C, but the net gain or loss from that schedule C is within 10, 000. So it's either 10, 000 or less, or, um, a negative 10, 000, uh, or.

Um, in those cases, they will, will still be exempt, um, from, from filing, uh, their, you know, from reporting assets. Um, and then one other kind of specialty qualification is dependent students, uh, will not be exempt. If their parents are not in the US or if they're not us, um, tax filers un, unless they're not required to file tax taxes in, in their, um, country of of residence.

All right, moving on. Um, foreign income, uh, and exclusions of foreign income. Uh, foreign income exclusions are coming back into the formula, so you may have heard that, but what does that exactly mean? There's a little bit of a nuance here, um, that because the foreign income may not be included in the U. S.

taxes, often it's not, um, that information will be manually entered. Uh, and there are some questions that I felt the demo was pretty clear on, on how to do that. Uh, it's really just one question, but there are then options to figure out what steps someone will need to take to report their income, uh, and, and proceed.

So I think that part is pretty clear. Um, a foreign income, when a foreign income is exclusion is reported and the maximum Pell flag is present, there will be a comment code that will appear on the ICER. And so what has to happen here. Is that a financial aid administrator needs to review That situation so you need to review If there's a foreign income exclusion present and the maximum health flag is is present So you'll get those, um easily through the comment code You'll want to develop a process to make sure that you are reviewing based on those comment codes And you will have the option To move the foreign income from untaxed income to the AGI.

And should you choose to do that, that will be a professional judgment determination. Um, you also have the option in exercising your professional judgment, uh, to ask for additional information from a family. So that's a practice and a policy that you want to be, um, Discussing, uh, with your staff, although that, of course, uh, professional judgment is exercised on a case by case basis.

So discussing it, um, you know, broadly as a, as a topic. All right, next, uh, another change, um, is the Presence of emergency aid.

So I hope this for me. Anyway, I was happy to see this news This has been a challenge On campuses that i've worked for some time So emergency aid will no longer be considered other financial assistance Emergency aid must still be a cost of attendance item, so it still has to be in the category of an unexpected expense that is food or housing related, travel related, or educational supplies.

At my institution, we have an emergency aid application program, um, and students can request help and what they're requesting help with. Oftentimes, they're requesting help for travel. Uh, due to a family member who is ill or has, has passed and they need to get home at an unexpected time. So if they need to travel during our sort of two standard periods of, of travel that we budgeted for, that's not approved.

But if they need to travel during other times, then we will use emergency aid for that case. We've also had students who need emergency funding for unexpected replacement of a damaged phone or a computer or repair of a computer. Uh, and so we're able to do that. Um, it's probably advisable, uh, to be careful in how, how this information is shared.

Um, because this is not a way really for other. Areas of the college to try to get around, uh, reporting forms of support from from the institution. So, um, just follow this guidance and you can easily direct people who who push that envelope a little bit, um, back to the to the guidance. All right. Next is, um, income earned from work.

Um, this one took my brain a little bit of time to, uh, to figure out. Um, but we, you know, and I think doing the hand calcs is always a good idea. Um, but we're familiar with families, uh, Reporting, uh, parent one income and parent to income and then calculating the social security tax at the 7. 65%. You know that that probably sounds very familiar to you.

Now it is, you know, going to be calculated slightly differently in two steps. Um, and I do think it's helpful for you to do a hand calc so that you can see it. Um, again, you can refer back to as a resource, um, if you want to see it or review it with your staff, uh, the student aid index, um, training that was held, the part one training that was held on June 22nd.

So if you go into the Department of education recorded trainings. Uh, that's that's where you'll find it. Um, but basically what is, is happening is that at the lower income levels, you're going to get to the same result at the end in terms of the allowance, but at the higher incomes, you're going, there's going to be a higher allowance, um, based on how the formula works.

You're, you're combining the parents income, uh, in the new, you know, new world here. Um, and your, you're You know, factoring the the percentage against of the income slightly differently. So definitely, um, you know, definitely take a look at that so that you can digest, uh, how this will will be different for your families.

But overall, income protection allowance is higher. This is another place where the allowance is higher and this is how the calculation of student aid index is largely helpful for for families in terms of their eligibility for financial aid. All right. We're gonna take a little bit of a stop, um, uh, an exit, a, um, a pause, uh, to review special and unusual circumstances.

Um, as I say, the road to 2425 must go through 2324. Uh, I got a chuckle, um, in sharing with Jill that I'm struggling to keep up with 2425 because I'm still trying to get through 2324. And Jill, in a moment of bliss, is, is able to say that she hasn't thought about 23 24 in, she actually, I think, used the word years.

So, um, it just shows, um, we're glad that, that, that Jill is in much deeper than, than all of us, and that's why these training sessions are so important. Let's, let's hit on 23 24 for, for one quick, uh, exit. Um, really making sure that you have details. You have requirements and you have timeline on your website about the difference between special and unusual circumstances, because you really need to highlight first for students, the difference.

Um, special circumstances are really what we all know as appeals request for reconsideration, but it's good to promote this very specific language so that students have, um, information and specificity about what kinds of things they can request be reviewed in terms of special circumstances. Unusual circumstances Is what we all colloquially know as dependency overrides, where there's not access to parent information.

And I think that that being very clear on your website about what is a federal definition of an unusual circumstance, how a student goes about requesting that unusual determination. Um, and what is the timeline, there are federal guidelines about how responsive. You need to be to students regarding, um, a final determination and providing students with a final determination of their dependency status, uh, as soon as practicable.

So, you know, that needs to be taken seriously. And there, of course, are very serious situations in which You know, we are processing those dependency overrides, regardless of the kind of situation we are in, regardless of whether institutions use institutional methodology or not. There are going to be those cases.

So it's just easiest to make sure that your website is clear and thorough and encourage you to make sure that that is the case. Um, all right, unaccompanied youth. Um, this is now a separate question that comes before you get to the section of really answering the dependency questions and then being informed on the FAFSA of the special and unusual circumstances.

So, you know, this is something that is. You know, strengthened and you want to be familiar with the definitions of a, of a student who is not in physical custody of a parent and guardian as unaccompanied or, um, is, is lacking, is homeless and is, or at risk of homelessness and lacking, you know, regular and fixed and adequate nighttime residence.

Um, or a student is paying, you know, their own living expenses. Um, there's a lot of, of detail in the regulation and the guidance, uh, about the eligible authorities. And in, in the absence of an eligible authority, um, a financial aid administrator can receive a written statement and can conduct that, that interview.

I will also just highlight that. There's a fantastic Um, you know, resource in terms of ask regs about this. Um, and so if this is something that you'd like to learn more about, definitely check out the ask regs questions, but being in contact with the parent. Um, is not required, the absence of being in contact with the parent is not a, um, criteria for being determined as an unaccompanied youth.

Um, I think if I said that right, um, being, being in contact, let me say it the other way too, being in contact with the parent does not disqualify, um, a determination of unaccompanied youth. So, um, and if you have a determination already from an eligible authority, you must accept it certainly for the federal purposes.

Okay, I think we can keep moving on. I am paying attention to the time I want to make sure that people have time for questions, which are definitely out there. If you haven't already. You know now is a great time. Right before we start really diving into all the applications, uh, to really make sure that you're sharing all of this information with a variety of places on campus.

So you may have already shared this with your admission, uh, staff, um, and team. Um, it's probably worth a round two as they start to be off campus and talk with applicants and get new questions. Um, But institutional research, they need to be thinking about what are the points of intersectionality, um, with data and how this might affect them.

You don't need to be the person who thinks of every single thing on campus about the Ways that FASTA simplification is going to change people's worlds. What you need to do is talk about it. The more you talk about it, the more there are, you know, the resource sharing of brains, um, We'll start to generate questions and light bulbs will go on for people about, oh, wow, this is going to, you know, impact, um, this, this point of, of data, or we need to strategize on, on how we're communicating with students, or, um, I have this little section of my website in a specialty services office where I talk about, um, some of the things Um, the financial aid process or links to information about FAFSA.

So you want as many people as possible to not only understand the concepts loosely of what's coming down the road, they don't need to know how an SAI is calculated, but they do need to understand that there's some are some broad differences. They also really need to understand, um, the important responsibility that we have to protect Federal tax information and how we must control handle controlled unclassified information because that is defined by law.

So, you know, just cut it off at the pass. Uh, people often will come to us with all kinds of questions and requests for data, and this is your opportunity to really, uh, pre preempt some of that. So get out, offer to come to a staff meeting and, and share that information. There's tons of information and resources to help you.

Um, and I'm not going to go into these details. I think, um, you know, Jill may be touching on them, but I am proud of the partnership with NASFA and the collaboration that we have. The working group has come up with in terms of ideas and suggestions, and I'm proud that NASFA has gotten, you know, outside grants to really be able to have the resources necessary to build things that are going to be helpful for you, whether it's an implementation checklist, whether it's PowerPoint templates that you can use to start these conversations with your campus partners, um, and even better.

We have a community sharing, um, section on the FAFSA simplification area that is specific things that members have done. Um, and so it's great for us to use our collective brainpower, uh, in that, in that regard. So let me turn it back to Jill to close with more of those resources. Thank you, Gail. Um, I'll just echo what Gail said.

The FASTA Simplification Implementation Working Group that she's part of has, um, just given us so many great ideas for resources to create. And so I'm going to share just a really quickly because I see a lot of really good questions out there, but I want to just really quickly go over some of the resources that NASFA has available to you.

So, Julie, if we can go to the. comment codes crosswalk slide. I see a question about that. So this is one of those fun ones where will NASPA create a common codes crosswalk? Yes, we will. We are working on it now. Um, some of you may have noticed that, um, there's a really significant renumbering of the comment codes from 2324 to 2425.

Of course, your systems are all coded to look at the 23 24 ones, and maybe you make some minor updates from year to year, but this is going to require a really, um, total overhaul of, um, you know, coding your, you know, requests for information from students, messages on communications to students, and everything else.

We asked the department if they were going to create a crosswalk. They don't have plans to do that, so we have taken, um, that on. It's in the process of being created right now. Um, third week of October, maybe, as a possibility, um, just to give you a, a general sense. Um, don't, don't quote me on that, but that would be where I think we might be, um, on that.

Uh, of course, Ask Greggs should be your go to. Um, the knowledge base is just full of every question you've ever thought of and, uh, even lots of questions you've never thought of. So definitely, Check out Ask Regs for the, um, existing questions that have already been answered, and if you have one that somehow hasn't been answered yet, ask it.

Um, our Ask Regs team is amazing, um, and, uh, they, they have your answers. And I'll just, I'll just plug, um, you know, if, if Ask Regs happens to be intimidating for you, which it doesn't need to be, um, you can go to the FAFSA simplification. Uh, web center, which should already be bookmarked for, from NASFA, should already be bookmarked for you.

And there is a whole section of specifically Ask Reg, um, questions and answers. So if you're not even sure what the question is, you can see what somebody else had for a question. And you're like, Oh yeah, that's a really good question. So keep checking that out. The web center for FAFSA simplification, we just keep trying to make it as helpful as possible for you.

Thank you for that. Um, let's see NASA's SAI modeling tool. Hopefully you've had a chance to check that out. It's been out there for a while. It's gotten a lot of updates, including now we can you can enter your 2324 data. I know everyone's been looking to do that for a long time. So that's been updated. Um, this lets you estimate an SAI and estimate a student's Pell grant.

Um, I wanted to note something that's new ish is that, um, our Blue Icon Advisors, which is the consulting arm of NASPA, uh, has received some, uh, grant funding to be able to provide assistance to under resourced schools who need help using the tool, but maybe couldn't afford to hire an outside consultant.

So, um, if, um, If that's something that you feel like you could use and you would qualify for, check out the URL at the end of the page here, the last bullet. And we already talked about the FAFSA Simplification Web Center, so let's move on to questions.

Hey, thank you. Um, so I, Julie and I will probably be sending them your way, but there was one where quite a few people had the same question. Uh, for, for, for the first gen question, will it provide clarification to students with parents who earned bachelor's degrees outside of the U S? It does not. No, let's see if I can find the question.

And then, uh, Julie, do you want to batch together all the SSN questions? We had a bunch that were very similar. Yeah, so here it is. Did either of the student's parents attend or complete college? But nothing about U. S. Okay, great. Thank you. Yeah. And there were a number of questions about the social security number ranging from, you know, what if a contributor doesn't want to give their students their social security number or what if the student is starting it and they're not sure if their parent has a social security number or not?

Can they just say that they don't? So they can still invite them. Uh, so if you could just talk a little bit more about that process that might cover a lot of these questions again. Yeah. Yeah, um, and I think I'll step in if you know more than I do about this. I, um, my understanding of this, the flow is that, um, with the students starting, that's only, um, like the department sort of like ideal scenario where the student starts and they, uh, invite contributors, but I think a way to get around using the parent social security number if the parent doesn't want to share it is for the parent to start.

Um, although as I yeah and so then the parent would say like I'm a contributor they would put in the students or security number, and their information and get matched up to the students whenever they do it. Um, so I see Gail nodding so I think she agrees that that is probably a way to get around that because that's understandable I think you know well another way would be of course sit with your.

student and you type that in, you know, but I obviously understand like, you know, families are, you know, if your kid is already in college right now, they're maybe not home or even if they aren't in college, they might not be home. So you might not always have the opportunity to sit next to them. Um, but that might be one way to get around it.

Yeah, I'm not sure I, I would recommend, I don't know exactly what happened, but I'm not sure I would recommend saying that there isn't a social security number if in fact there is because I don't know where that information would, would go and where that could hang up something else. So I would not recommend that I, we did go through and this was where the prototype is great I went through with my staff, starting as a parent.

And so you can do that and there's some good logic in there because if you start as a parent. And you start to answer some of the questions like, um, you know, my student doesn't have contact. It actually recognizes, but wait, you said you were the parent. So what's going on here? Do you, do you want to exit the FAFSA right now?

Or do you want to change your answer? Like, so, you know, really there are some good logic steps in here and the prototype might be a way that you can kind of test out some of these scenarios that you're, you're wondering about. Great, thank you. But people did, parents did put their social security number on the FAFSA for a long time now, so I don't, I don't know how much of it, it will be an issue for some people, I'm not minimizing that, but I'm not sure how big it really has to be.

Hopefully for most it will be smooth. Great, thank you. We have a couple of questions that are similar. So if the Contributing parent. The student does not have any relationship or contact with them or if there's an abuse situation, something like that. I imagine it would be PJ would be the next step to use the other parent.

It wouldn't be the other parent, it would be PJ to do a dependency override. You can't switch parents, even through PJ. Great. And that's also, since you just mentioned abuse, Stephanie, I mean, that's one of the reasons that the, the homeless question is, and the criteria for that is not about contact, because if a student is essentially fleeing abuse, um, then maybe they have had contact, but, but that's where, you know, knowing the circumstances is, is not the criteria.

It's about, are they, United Qualifying as, uh, homeless or at risk of homeless based on the definitions and so understanding those those definitions is important,

right? We have a lot of questions. So I'm not do you want to pick one? I can pick one. Um, maybe you can just talk about this. If parents are married and both filed head of household on their tax returns, will both parents provide consent to have the information accessed from their Their tax returns.

Basically, will this be treated the same as married filing separately? I mean, I I'll jump in, but I would say the question is whether they filed correctly. Um, because I'm not sure if the implication was that they're not living together. But, you know, the obligation probably For them to, you know, for us to still confirm that they're filing correctly is still important, but determining what parents information is on the FAFSA if they're not living together and going back to the financial support question, um, is the key.

If they are living together, then there shouldn't be a married, uh, head of household for both of them. Anything you want to add to that, Jill, or am I missing a nuance there that yeah, no, I don't think you're missing a nuance. I would just kind of say like, yeah, like, there's all sorts of like, whether that's what you can do per tax code, probably not, but maybe there is.

But, you know, those would be separate tax returns. So just getting at like the concept, like, If for some reason that was a legal thing that you could do, yes, each parent would have to give their consent because they would have separate tax returns. So it would be like married filing separately in that sense.

You couldn't just have one person give consent, but you know, that's a whole separate issue from whether you can be married. I didn't both file had a file sold, which I won't touch.

This is on a different topic. Has there been any information about appeals regarding number in college? So it's a good issue to talk about, I guess. I know it won't be part of SAI, but are we able to use that as an appeal issue? And if so, are there any recommendations as to which data elements would, could be revised and can an appeal affect Pell eligibility?

So I would say there has been a lot of discussion and guidance in the sense that professional judgments, uh, Which isn't, hasn't changed, uh, can be exercised to, what I keep seeing in print is, um, it can be exercised to adjust cost of attendance and data elements. I keep saying in my brain, I can't think of a scenario in which you would be adjusting cost of attendance to account for a sibling in college.

So, um, Because it's not the students, uh, cost of attendance that you would be adjusting, but, um, in terms of data elements, um, you know, there could be examples where you're adjusting, uh, a family's adjusted gross income. based on expenses. If you have done that for other kinds of expenses then you are familiar with the professional judgment exercised to adjust a family's income based on expenses they have.

Whether they're medical expenses or Uh, you know, college expenses, so it's those kinds of things. I think really going back to what are your existing practices and policies in your office about things that you have already done and and don't get so hung up on them. Just the number in college concept. Go back to the principle of what is the expense?

What documentation do you collect to document an expense of paid So You know, items who paid it, how it was paid. And then, what do you do in those cases. So, I think the guidance is balanced in, you know, you're not going to be told it specifically. What to do it's it's a because it's professional judgment and the latitude for professional judgment.

It rests with the financial aid administrator. Thank you, Steph. I don't know if you have one you want to ask and we can take turns. Well, there was a couple, um, regarding pill. So I think we can lump those together. One was, should the school worry about more than 12 credits if 12 is full time for them?

What if they're taking 15 or 18? Is there any change to the PAL amount? Right, you can get more than 100 percent Pell, so like, uh, 15 credits would be like 12 credits, 18 credits would be like 12 credits, just full time. You can get more than 100 percent of Pell for like, you know, year round Pell, but that's a separate thing, separate from proration for enrollment intensity.

Okay, and then another Pell related question. If the student's enrolled full time but doesn't have any credits, I

don't know if the departm