2022 Year in Review: NASFAA’s Policy, Grant, and Advocacy Efforts

By Hugh T. Ferguson, NASFAA Senior Staff Reporter

NASFAA continued to adapt in its policy, research, and advocacy efforts in 2022. By continuing to hold both virtual and in-person events, such as the Advocacy Pipeline with Capitol Hill staffers, the policy and federal relations team made strides in influencing key policy decisions regarding college access, affordability, simplification, transparency, and federal aid for higher education institutions and students in the rapidly evolving landscape. NASFAA engaged in several advocacy, grant-funded, and public policy undertakings to support its mission of promoting programs that remove financial barriers and ensure student access to postsecondary education.

NASFAA hosted six Advocacy Pipeline events with Capitol Hill staffers, enabling financial aid administrators from across the country to make their voices heard despite the challenges brought by the pandemic. NASFAA also hosted a number of timely webinars highlighting the latest administrative policies and financial aid topics like Fresh Start and Debt Cancellation: What You Need To Know, FAFSA Simplification, and Cash Management: Late Versus Retroactive Disbursement. Additionally, NASFAA worked to further analyze the impact of staffing shortages in financial aid offices, updated the Department of Education’s FAFSA simplification roadmap, explored new initiatives to improve aid delivery, and published an updated salary brief as part of our regular benchmarking surveys.

Read on for a comprehensive list of other actions NASFAA and its members took in 2022.

Advocacy Activities and Materials

NASFAA’s Advocacy Pipeline

NASFAA continued its Advocacy Pipeline efforts amid the ongoing pandemic, hosting six separate events for financial aid directors to connect with lawmakers and their staff to discuss how COVID-19 has impacted operations and highlight the importance of federal relief to provide students with emergency aid grants.


NASFAA advocated on behalf of the financial aid community on several major pieces of legislation over the past year, including on the administration's Build Back Better agenda, the 2022 appropriations bill to advocate on behalf of student financial aid administrators for healthy funding for the federal student aid programs, as well as the 2023 appropriations package, which began making its way through Congress during the waning days of the calendar year.

Student Loan Debt Cancellation Web Center

As the Biden administration continues to reshape the landscape for the student loan portfolio, through executive action and rulemaking, NASFAA has compiled a number of resources for members detailing how they can best keep track of new initiatives related to debt cancellation. NASFAA will continue to update this page as more guidance becomes available.

Negotiated Rulemaking 

Throughout 2022, NASFAA covered the latest stages of the negotiated rulemaking process with recaps of the final rulemaking sessions, and followed the ongoing rollout of final rules from ED. With daily committee recaps and deep dive articles, NASFAA provided guidance and additional context for the finalized rules coming from the work of both negotiated rulemaking committees (Institutional and Programmatic Eligibility and Affordability and Student Loans).

Continuation of the Double Pell Campaign

Marking the 50th anniversary of the Pell Grant program, NASFAA continued with its commitment to the Double Pell campaign, and called on Congress to make key investments in the program. Throughout the year NASFAA participated in a number of events with members and federal officials to continue highlighting how federal aid has served as a lifeline to generations of students seeking to pursue higher education.

FAFSA Simplification

The FAFSA Simplification web center was put together following the 2021 Consolidated Appropriations Act, which contained significant changes to federal student aid policy, including simplifying the FAFSA, expanding Pell Grant eligibility to incarcerated students, and the repeal of limitations on subsidized loan eligibility for undergraduate Direct Loans. The web center includes new resources including the FAFSA Simplification Case Studies, a series of case studies demonstrating how changes to the Pell Grant eligibility and Federal Methodology formulas will impact students and families under different circumstances and compares outcomes to the current methodology for comparison.The center also includes a FAFSA Simplification Implementation Checklist for Schools, which seeks to help institutions plan for implementation of the FAFSA Simplification Act in 2024-25.

Student Aid Index Modeling Tool (NASFAA members only)

This downloadable tool allows users to import their students' data to calculate estimated Pell Grant eligibility and estimated SAIs under the new methodology. It allows for comparison to current Pell Grants and EFCs so institutions can prepare for the impacts of FAFSA simplification on their campuses.

Detailed Summary of Non-Pell/Federal Methodology Changes from the FAFSA Simplification Act and FAFSA Simplification Act Technical Corrections Act 

This chart summarizes changes from the FAFSA Simplification Act that are unrelated to the FM formula and Pell grant eligibility.

Timeline of Effective Dates from the 2021-22 Consolidated Appropriations Acts 

This timeline provides effective dates for provisions of the FAFSA Simplification Act and subsequent technical corrections.

Legislative Changes to Federal Methodology and the Pell Grant Program

The financial aid community is gearing up for big changes to the Federal Methodology formula and the Pell Grant program. To help in the process, NASFAA created a chart summarizing legislative changes from 2021 through the 2024-25 award year, and a flowchart that shows how applicant data will flow through the new Pell Grant formula and Federal Methodology formula to determine a student's Pell Grant award and Student Aid Index.

Grant & Research Initiatives

NASFAA Survey: Financial Aid Offices Face Intensifying Staffing Challenges Amid Pandemic

Prior to the pandemic, financial aid offices across the country reported ongoing challenges with employee retention and staffing. For example, NASFAA’s previous work on Administrative Burden found that pre-pandemic, staffing levels were not keeping up with increased regulations, work levels, and record levels of financial aid. At best, schools were treading water, but for many schools the inability to keep and replace staff was challenging. To learn what impacts the pandemic has had on financial aid staffing, NASFAA conducted a brief online survey in March 2022 to NASFAA member institutions and a follow-up survey to non-completers in May 2022. What we learned is simple: What was once a challenge — albeit a manageable one — has become a crisis for many institutional financial aid offices that are struggling to remain administratively capable and adequately serve students, whose own needs have increased in the last two years.

NASFAA's National Student Aid Profile: Overview of 2022 Federal Programs

NASFAA’s National Student Aid Profile is an annual publication designed to give a high-level overview of the federal student financial aid programs that provide funding to millions of students each year. The profile provides an overview of: the Federal Pell Grant Program; the Federal Supplemental Educational Opportunity Grant (FSEOG) Program; the Federal Work-Study Program; the Federal Direct Subsidized and Unsubsidized Loan Programs; the Federal Direct PLUS Loan Program. Additionally, the profile outlines the most up-to-date data and information on the number of recipients, total volume of awards, federal funding levels, and distribution by family income for each program, as well as an appropriations update on Title IV program funding for the 2022-23 award year. 

Evaluating Student and Institutional Experiences with HEERF

NASFAA, in collaboration with NASPA—Student Affairs Administrators in Higher Education and HCM Strategists, produced a report evaluating student and institutional experiences with the three rounds of Higher Education Emergency Relief Fund (HEERF) grants. This research builds upon work conducted in 2021 on the CARES Act HEERF program, but it adds the student perspective and specifically examines differences among students and practitioners at minority-serving institutions (MSIs) relative to non-MSIs.

Protecting Borrowers & Advancing Equity

Through this grant-funded work, NASFAA developed thoughtful, systemic, targeted policy solutions to treat the underlying flaws in the current student loan repayment and servicing systems that lead borrowers into financial hardship, while underscoring the benefits of a strong federal loan program. Read the full report to learn more about the work NASFAA and coalition members, as noted in each individual section, put forth for recommendations on student loan servicing, student loan repayment, and student loan default.

NASFAA On the Record


NASFAA Signs Letter Urging Congress to Pass the Student Veteran Emergency Relief Act

December 1, 2022 - NASFAA, along with other higher education organizations, signed a letter urging Congress to pass the Student Veteran Emergency Relief Act.

NASFAA Signs Letter Urging Congress to Repeal the Tax on Pell Grants

November 29, 2022 - NASFAA signed on to a letter urging Congress to end the taxation of federal Pell Grants in order to make higher education more affordable and simplify the tax code for students and families with low and middle incomes.

NASFAA Joins Letter Urging Congress to Pass Legislation to Protect Dreamers

November 21, 2022 - NASFAA signed on to a letter sent by the American Council on Education urging congressional leaders to pass legislation to protect Dreamers after recent court decisions declared the Deferred Action for Childhood Arrivals (DACA) program illegal.

NASFAA Joins Call for Congress to Support Tax-Free Pell Grant Act

November 1, 2022 - NASFAA, along with several higher education organizations, signed on to a letter by the American Council on Education (ACE) urging leaders of the House Ways and Means Committee and the Senate Finance Committee to include the Tax-Free Pell Grant Act in any lame-duck tax legislation.

NASFAA Signs Letter Giving Feedback On Responsible Education Assistance Through Loan (REAL) Reforms Act

September 12, 2022 - NASFAA sent a letter to House Republicans that gives feedback on the Responsible Education Assistance Through Loan (REAL) Reforms Act.

NASFAA Joins in Letter Calling for Repeal of Pell Grant Taxability

June 27, 2022 - NASFAA joined other higher education organizations in a letter to congressional leadership calling for the repeal of Pell Grant taxability and restoring American Opportunity Tax Credit (AOTC) eligibility for students with prior drug convictions.

NASFAA Signs On to Letter Calling for 85-15 Rule Fix

June 23, 2022 - NASFAA signed on to a letter supporting the Ensuring the Best Schools for Veterans Act of 2022, legislation to address concerns stemming from recent policy changes to the 85-15 rule by the Department of Veterans Affairs (VA).

Comments to ED

NASFAA Letter to ED on Partnership Challenges

September 7, 2022 - NASFAA in a letter to both ED and FSA is calling on the department to meet with NASFAA’s leadership to better coordinate on partnership initiatives that will address ongoing operational challenges that are negatively impacting schools and students.

NASFAA Signs Letter Urging the Department of Education to Extend PSLF Waiver

August 18, 2022 - NASFAA signed onto a letter urging Secretary Miguel Cardona to extend the Public Service Loan Forgiveness (PSLF) waiver, which expires in October.

NASFAA Signs Brief Arguing That Race-Conscious Admissions Is Protected by the First Amendment

August 2, 2022 - NASFAA, along with 39 other higher education organizations, signed an amicus brief arguing that admissions officers considering race in college applications are protected by the First Amendment.

NASFAA Comments on ED's Datasets RFI

June 3, 2022 - NASFAA's comments on the request for information regarding datasets by the U.S. Department of Education, urging FSA to publicly share more available data at more predictable intervals.

NASFAA Joins Community Letter Raising Concerns Regarding Changes to 85-15 Rule

March 22, 2022 - NASFAA joined a letter along with more than a dozen organizations raising concerns regarding the Department of Veterans Affairs’ recent announcement of key changes to the 85-15 rule, specifically changes in the requirements for a 35% exemption.

NASFAA Submits Comments to ED on Proposed Changes to Quarterly HEERF Report

March 14, 2022 - NASFAA submitted comments to the Department of Education (ED) on Monday, March 14 on its proposed changes to the Higher Education Emergency Relief Fund (HEERF) Quarterly Budget and Expenditures Report (QBER).

NASFAA Submits Comments on FSA's Next Gen

March 9, 2022 - NASFAA submitted comments to the Office of Federal Student Aid regarding the upcoming procurement request for student loan servicers, with specific comments and questions focused on the plan for defaulted borrowers, among other topics.

NASFAA Urges Department of Education to Extend Verification Waiver

February 15, 2022 - NASFAA, NCAN, and TICAS in a letter to President Joe Biden requested that the Department of Education extend, for the 2022-23 award year, the verification waivers granted for the 2021-22 award year.


Publication Date: 12/22/2022

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