The Department of Education (ED) on Tuesday opened a 30-day comment period for its proposed information collection request (ICR) to collect individual student Federal Work-Study (FWS) annual earnings data from institutions.
Notably, ED added a new burden estimate to account for institutions having to create an initial startup process for reporting this data, estimating an average burden of 200 hours, with a range of 100-300 hours depending on individual institutional factors.
In comments submitted during the initial 60-day comment period, NASFAA described ED’s initial burden estimate of four hours as “woefully inadequate.” We appreciate that ED has offered a more realistic estimate of the institutional burden, because institutions should now have a clearer sense of the amount of work they have ahead of them in relatively short time, since ED indicated in its supporting materials that annual FWS reporting will align with FISAP reporting, meaning institutions should be prepared to report 2022 FWS annual earnings by Sept. 30, 2023.
NASFAA plans to ask ED to give schools more time during this initial year of data reporting given the 2024-25 FAFSA will not be released until sometime in December 2023.
ED has promised an additional Electronic Announcement (EA) to be published this summer with more operational guidance on reporting annual FWS earnings, including how reporting would work for federally-recognized work colleges.
Understanding institutional reporting of student-level annual FWS wages is statutory, meaning only Congress could lift this requirement, ED is seeking to collect significantly more data than it needs to comply with the FAFSA Simplification Act. Fortunately, for the upcoming award year, ED has clarified that it will only seek the data it needs to comply with the law.
However, NASFAA remains concerned about items marked “For Future Use Only” in the 2023-24 Common Origination and Disbursement (COD) Technical Reference. Those items include a breakdown of individual student FWS earnings by institutional share and federal share, whether the student’s job was classified as community service, annual student-level Federal Supplemental Educational Opportunity Grant (FSEOG), and more. NASFAA will continue to press ED to drop these additional data reporting requirements in future years.
Comments are due July 12, 2023. We encourage members to comment, especially to request as much time as possible to comply with the initial year of reporting when startup burden will be significant, and on the additional reporting items marked for future use. NASFAA asks that members planning to submit their own comments share them with us at [email protected].
Publication Date: 6/14/2023