By Maria Carrasco, NASFAA Staff Reporter

Over a year ago, in March 2023, federal officials revealed publicly for the first time that due to its massive overhaul and redesign, the FAFSA application for the 2024-25 school year would not launch on October 1, as it has in past years. In the months leading up to the public launch, confusion and a lack of guidance left schools scrambling to prepare, while delays, glitches, and errors have continued to complicate the process in the last several weeks. 

Now, over a year later and four months after the 2024-25 FAFSA officially launched, financial aid offices are still grappling with the avalanche of repercussions of those errors and delays — all the while new ones continue to surface. 

The FAFSA Simplification Act, which was signed into law in December 2020, aimed to overhaul and simplify the application process with fewer questions, a revamped website, a new, more generous Student Aid Index (SAI) formula to replace Expected Family Contribution, and more. Meanwhile, the enactment of the FUTURE Act allowed for direct data sharing between the IRS and the Department of Education (ED), which would aid in reducing the number of questions, reducing the need for verification, and strengthening program integrity. 

But the process of implementing those changes has been anything but simple, financial aid administrators argue. Initially, many financial aid administrators were already apprehensive of the implementation of FAFSA simplification – even before federal officials would not commit to an October 1 launch date. That apprehension only grew in the months to come, as ED repeatedly gave vague guidance on when and how implementation would work. 

For instance, even for the much smaller provisions of the FAFSA Simplification Act that were put into place for the 2023-24 aid cycle, ED did not issue implementing guidance until a month after that year’s FAFSA launch. The Office of Federal Student Aid (FSA)t also failed to release a project plan with key milestone dates until March 2023, after confirming that the new FAFSA would not be released until sometime in December. FSA used the same type of messaging — giving date ranges rather than specific dates — in November 2023, when it announced the ​​FAFSA would go live by December 31, 2023, meeting the statutory requirement that the form must be available by January 1. 

ED never specified an exact launch date, but instead opted for a “soft launch,” which came with frequent maintenance outages and reported glitches. NASFAA President and CEO Justin Draeger called the soft launch “challenging” at the time and noted that students and aid offices were understandably frustrated. 

Delays, Glitches, and Broken Trust

Now, almost four months after the FAFSA’s rocky launch, Draeger is still ringing alarm bells on issues that keep appearing with the 2024-25 FAFSA. At times, it feels like every week there are new issues financial aid professionals are working on, Draeger said, that have been either identified by other aid professionals or the department itself. 

And that’s created a strong sense of uncertainty and concern for a lot of financial aid professionals. 

“There's the theme of fear, that there's always going to be yet another thing that prevents administrators from being able to get aid offers out, knowing that everything they have is correct — that the student and FAFSA applicant information is correct,” Draeger said.

The issues weren’t limited to the FAFSA form itself. In November 2023, ED confirmed that institutions will not begin receiving Institutional Student Information Records (ISIRs) until the end of January 2024. However, ED would later backtrack that statement the very day institutions were supposed to start receiving applicant information. 

On January 30, 2024, ED announced that institutions and states would begin receiving ISIRs in the “first half of March.” This announcement came a week after ED had publicly acknowledged another issue and said that it would be updating data tables used in the Student Aid Index (SAI) calculation to account for inflation for the 2024-25 award year, which it had mistakenly left untouched with outdated information.

For Draeger, this was one of the lowest points of the 2024-25 FAFSA rollout. 

“When ED did acknowledge [the ISIR delay] it was often buried in a lot of words of positivity,” he said. “When you're starting to do that in electronic announcements on what is clearly bad news, it starts to break down the trust between working professionals and the Department of Education on what are some of the biggest changes in federal methodology in decades. What I'm hearing from our professionals is that these sorts of communication lapses really set the stage for what ends up being a relationship of distrust in the months that followed.”

Most of all, financial aid administrators are worried about how these delays will impact students. Brenda Buzynski, assistant provost and director of student financial aid at the University of Iowa, says she’s concerned that these delays could add to the stress students feel when  deciding where to enroll in college. At the same time, Buzynski says there’s a feeling of distrust among those in the financial aid community, as some worry that priorities have been misplaced.

“Our confidence with the Department of Education is wavering,” Buzynski said. “I'm very concerned. And from a larger perspective, I'm very concerned that politics is getting in the way of serving students. I think we're losing sight of what everyone's role is in this entire FAFSA process.”

Joshua North, director of financial aid at Bridgewater College, shared a similar sentiment and argued that the FAFSA rollout could have gone more smoothly if ED was more forthcoming about delays.

“It would be nice to be able to see what is going on behind the scenes and to get an update from ED, instead of sitting on months of radio silence and not knowing when the next news drop is going to be,” North said. “That's not how you foster trust within a relationship. We need to have trust coming from both directions.”

Delays haven’t been the only issue with the rollout of the 2024-25 FAFSA, though. There have been technical issues, too. That includes, notably, issues for FAFSA contributors without Social Security numbers not being able to complete their sections of the FAFSA in the first two-and-a-half months of it being live, which ED said in the middle of March it has resolved. A full list of technical issues can be found via FSA’s online guide, along with the status of these issues. 

North says he and his colleagues fear that these issues could result in students giving up on the FAFSA process altogether. 

“The major problem that I have, with the concerns of the delay, is how many students don't exactly know what's going on,” North said. “They don't know how much in financial aid they could possibly get. We don't know how many of those students will just give up because they don't understand the financial aid process.”

As NASFAA and other higher education organizations have said, delays with the FAFSA critically impact low-income students who depend on accurate and timely financial aid offers to make decisions about where they’ll attend college. 

And we’re seeing the results of these delays and errors in real time. Bill DeBaun, the National College Attainment Network’s (NCAN) senior director of data and strategic initiatives, shared his concerns about how these FAFSA delays are impacting students on NASFAA’s “Off The Cuff” podcast. NCAN is currently tracking FAFSA submission and completion rates from high school seniors. As of March 29, there was a 40% decrease in FAFSA completions compared to the last academic year.

In a recent op-ed in Inside Higher Ed, DeBaun stressed that there’s still time to help students who have not yet submitted the FAFSA, but the window is quickly closing. He added that this is an “emergency for high school seniors,” especially seniors from low-income families and first-generation backgrounds – many of whom are students of color.

“This isn’t the time for retrospective recriminations about who did what, or what could have been different,” DeBaun wrote. “There will be plenty of time for that later. What’s needed now is a concerted ‘complete the FAFSA’ message to echo from every available channel and bully pulpit.”.

Advocacy in Action

With all the unresolved issues of the 2024-25 FAFSA, NASFAA and other organizations have urged ED to take several steps to make the process easier for students, and to ease the burden on financial aid offices across the country as they prepare to package aid offers.

That includes multiple letters sent beginning in 2021 urging ED to swiftly implement changes to the FAFSA and clarify exactly when the new FAFSA would officially launch, and calling on ED to provide temporary relief from burdensome requirements on students and institutions, including lowering verification selection rates, and delaying reporting requirements for gainful employment (GE) and financial value transparency (FVT). NASFAA created a full timeline of its advocacy during this time. 

In February, ED confirmed it would “significantly” reduce verification requirements, suspend all new program reviews through June of 2024 except in instances where there are “serious issues” stemming from suspected fraud, and waiving the 90-day recertification window for schools whose Program Participation Agreement (PPA) expires in March, June, or September 2024. 

Additionally, in late March the department confirmed it would delay the institutional reporting deadline for GE and FVT from July 31 until October 1, 2024. Along with those actions, ED in February announced a new FAFSA support strategy to support financial aid offices.

Just last week, Draeger testified in front of the House Subcommittee on Higher Education and Workforce Development, outlining the failures of the 2024-25 FAFSA rollout. In his opening remarks, Draeger noted that this year’s rollout is “so far behind a normal schedule” that the delay in delivering financial aid offers could cascade into additional delays impacting student aid disbursements for the 2024-25 aid year. 

“Financial aid professionals are witnessing the real impact of bureaucratic missteps on our most vulnerable students,” Draeger wrote in his testimony. “We need better communication and answers, not excuses. It's not about politics; it's about accountability and improvement.”

NASFAA, along with other higher education organizations, has also called on institutions to provide flexibility to students and families as they consider their offers of admission and financial aid. And many institutions across the country have already extended their decision deadlines.

Where We Stand Now

Now, as institutions continue to receive ISIRs, aid offices are still dealing with technical errors. That includes three issues ED identified earlier this month concerning tax data provided by the IRS on ISIRs, and another at the end of March impacting how student assets are factored into the SAI calculation — all of which will require the reprocessing of hundreds of thousands of applicant records. 

“I think a lot of aid offices’ heads are spinning right now trying to figure out the implications of the latest policy guidance and how they're going to be able to implement this on their campuses,” Draeger said. “And we're seeing, hearing, and feeling a lot of raw emotion, frustration, and confusion.”

Additionally, institutions are still waiting for the department to allow students to make corrections on their FAFSAs, which ED said should be available in April. On Tuesday, April 9, ED announced that it was aiming to make FAFSA student corrections available broadly this week. However, on Friday, ED also posted four issue alerts on FAFSA student corrections, with only one workaround solution. 

As of now, ED has not given institutions a timeline of when schools will be able to make corrections. 

At NASFAA, members have gathered in our communities to discuss and problem-solve errors and issues they’re seeing with ISIRs. Draeger noted a positive outcome of this rollout is the collaboration between financial aid professionals across the country, either through NASFAA communities or different listservs.

Draeger noted that while it's hard right now for most financial aid professionals to see the positive, he hopes this year’s challenges will bring a better FAFSA process in the future, saying it would be “shameful for us to go all the way through this and not look backwards and have some lessons learned so that we can improve the federal government’s processes on the other side of this.”

“I still hold on to the promise that this is going to be a better process for students on the other side of this, and that more applicants will qualify for Pell Grants,” Draeger said. “I just don't know how much of that will have been diminished by this rollout. How many students will have decided not to attend? How many institutions will bear permanent enrollment and financial scars from this rollout?”

Publication Date: 4/15/2024

Comments Disclaimer: NASFAA welcomes and encourages readers to comment and engage in respectful conversation about the content posted here. We value thoughtful, polite, and concise comments that reflect a variety of views. Comments are not moderated by NASFAA but are reviewed periodically by staff. Users should not expect real-time responses from NASFAA. To learn more, please view NASFAA’s complete Comments Policy.