ED Details Implementation Plans for FAFSA Changes

By NASFAA Policy and Communications Staff

Related Topics in the Ref Desk: Student Eligibility

The Department of Education (ED) on Friday announced that it will employ a delayed, phased implementation of the changes made to federal methodology and the FAFSA as part of the Consolidated Appropriations Act, 2021. The statutory deadline for the changes is the 2023-24 award year, with several provisions having early implementation options. 

ED’s move toward a phased implementation includes early implementation of the removal of the drug conviction and Selective Service eligibility criteria for the upcoming 2021-22 award year, with the rest of the changes now set to be completed by award year 2024-25, a year late.

“As you can see, we’re already hard at work modernizing the FAFSA system. But we’re taking care to ensure you can apply for and receive federal student aid at any point. That’s why we’re breaking up this extensive work into bite-sized pieces,” Richard Cordray, chief operating officer of the Office of Federal Student Aid, said in a statement. “As early as Oct. 1 of this year, some of these improvements will begin to show, and we will add more improvements as soon as we can over time. With each step we take, we’ll always ensure that you remain at the center of our focus.”

Calling it a “significant overhaul of the federal student system,” ED cited the magnitude of the changes as a reason for not fully meeting the 2023-24 statutory deadline, including the need to upgrade the Central Processing System (CPS) prior to implementation. ED also pointed to the integration with the IRS and the need for states to have time to adapt as reasons for the delay.

“These changes cannot come soon enough. But of equal importance is that changes to the form be done in an orderly way to ensure there are no disruptions to the application cycle for students or schools,” said NASFAA President Justin Draeger. “These two objectives are not mutually exclusive, and we are pleased to see ED moving forward to implement several provisions early. We’re examining the impact and implementation of these early provisions now.”

The announcement comes as ED intends to begin a lengthy negotiated rulemaking process for 14 topics in total including borrower defense, financial responsibility, gainful employment, and public service loan forgiveness. Those hearings are slated for June 21, 23, and 24.

“We are, however, disappointed that some changes that will benefit students will be delayed for one additional year, until the 2024-25 school year,” Draeger said. “We look forward to working with ED for a smooth on-ramp for students and schools.”

Selective Service and Drug Conviction Requirements

In an Electronic Announcement, ED announced that it will implement the removal of the Selective Service and drug conviction eligibility criteria in three phases, across three award years: 2021-22, 2022-23, and 2023-24. The changes will be announced in the Federal Register in the coming days, and schools may implement the changes as early as the date the Federal Register notice publishes. Schools must implement the changes no later than 60 days after the date of the Federal Register notice (implementation date).

For the 2021-22 application cycle, which is already underway, the Selective Service and drug conviction questions (as well as the option to register with the Selective Service via the FAFSA) will remain on the FAFSA for the entire application cycle. However, failing to register with the Selective Service or having certain drug convictions will no longer impact a student’s Title IV aid eligibility.

Institutions will still see relevant Comment Codes, which will still include messaging that a resolution is required to regain eligibility for federal student aid. For Institutional Student Information Records (ISIRs) received on or after the implementation date, institutions must ignore the Comment Codes and the messaging requiring resolution and proceed to award and disburse aid to students if they are otherwise eligible. However, while recommended, institutions are not required to go back and reprocess, package, or award aid for ISIRs they received for the 2021-22 award year prior to the implementation date unless requested by the student.

Be advised that ED will be emailing applicants with 2021-22 ISIRs received prior to the implementation date and who were determined to be ineligible for reasons related to Selective Service and drug convictions informing them about the change in the law and their potential eligibility for Title IV aid. Emails will direct students to contact their institution’s financial aid office.

For the 2022-23 application cycle, ED will continue its phased implementation by including language in the Comment Codes stating that no further action is necessary on the part of the student or the school. The related questions will remain on the FAFSA and the Comment Codes will still appear, which schools must ignore.

For the 2023-24 application cycle, ED will complete the implementation by completely removing both the Selective Service and drug conviction questions from the FAFSA, as well as the option to register with the Selective Service via the FAFSA. ED will also remove any associated Comment Codes and messaging that indicates a resolution is required for federal Title IV eligibility.


Publication Date: 6/11/2021

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