Last week, we asked you to share your thoughts on what processes and procedures throughout the campus will be affected, what consumer information will need to be updated, and how this will affect our financial aid management systems. We noticed some common themes across the comments we have received so far:
Scroll down to read through all the comments your peers have left so far.
To learn more about the move to prior-prior year, visit our PPY resources center, which includes links to our press release, our quick and simple video schools can share to help students and families better understand how PPY will benefit them, and our more in-depth video explaining why this move to PPY will not only allow students to have earlier information in order to make enrollment decisions, but will also give financial aid administrators some relief from mounting administrative burden and ensure they have more time to spend counseling students.
NASFAA is committed to doing all we can to ensure a smooth transition to PPY for schools and students. In addition to beginning work with schools, Federal Student Aid (FSA), state grant agencies, and others to align practices, we are currently seeking volunteers to serve on a PPY Implementation Task Force to work with members and FSA in identifying implementation issues. Among other things, the task force will review all the questions and concerns we receive via online channels, and via email.
We hope you'll continue to share your thoughts on PPY via Twitter (using #PPY), Facebook, and in the comments section below.
Publication Date: 9/15/2015
Amanda K | 9/24/2015 8:49:12 AM
I'm not opposed to PPY but why can't the FAFSA still become available on January 1? I, like another person commented, never thought of the FAFSA timeline being moved with PPY. I assumed the FAFSA would still be available starting January 1 but students could complete the FAFSA right away because they wouldn't have to wait for taxes to be filed. My concern is for the financial aid administrators and software vendors who will probably not be ready if the FAFSA becomes available October 1. Even with the current timeline, software vendors are rushed to provide data ASAP and many times, there are problems discovered after the fact. Also, will the Pell schedule be released in time? Will state grant agencies comply with the earlier timeline? How are schools supposed to determine a COA that far in advance? Again, I think PPY is a good idea but I think the timeline is not realistic.
Elaine N | 9/23/2015 11:36:17 AM
To make this work, software vendors need to be brought to the table at the earliest possible point. The traditional reactive, here's-what-you-need-to-solve punt means rushed development based on ambiguous guidance because the questions technology needs to have answered hasn't had a forum. Get the vendors collaboratively working with NASFAA and USED now. I reached out to NASFAA and USED the day of the announcement and haven't heard from anyone.
Sherri S | 9/23/2015 9:40:04 AM
We should be careful not to reflect on comments as an unwillingness to change but an opportunity to take a look at the challenges we will face as aid administrators. I am in favor of PPY but would agree that the timeframe is very limiting. We have started to lay out the timeline utilizing our prior year calendar. Many of our processes/planning will be pushed into July 2016. For an office like mine which manages both the financial aid and billing this will be difficult to be successful both with implementation and continued customer service. I would agree, "the devil is in the details" and if we don't take this opportunity to raise questions then we do nothing to create a successful atmosphere for all involved.
Susan J | 9/22/2015 1:1:05 PM
Perhaps I'm naive, but I never thought the FAFSA timeline would move 3 months backwards if PPY came about. I thought about it in terms of the same processing schedule, but having the benefit of using available tax data starting Jan 1. Personally, I like PPY, I'm glad it's coming, but I don't like this new schedule of Oct 1. I would prefer a little more breathing room between aid years. Or at least a gradual movement of the timeline, such as using PPY as of Jan 1, 2017 for 17-18, Dec 1, 2017 for 18-19, and Nov 1, 2018 for 19-20.
David S | 9/22/2015 11:46:09 AM
When some of these comments were first made, I was disappointed to see some colleagues posting complaints that PPY would change things...different timing, maybe more PJ calls, inexact need analysis. Folks, you want a job that's never going to change...really? Software vendors, states...all have no choice but to fall in line. Same for us.
PPY is going to help students and families by giving them more time to make what may be the biggest financial decision of their lives. Many now must make that decision in no more than 2-3 weeks, which is absurd. Yes, there will be some roadbumps. We all have a whole year to plan for year 1, then by year 2, it will feel more like the norm. Everyone - and I mean everyone - outside the FA world loves this. Let's not be the only group complaining...lest we (once again) make people wonder whose side we're really on. Embrace the change, help our students understand it, and then get ready for more changes.
Lauren S | 9/22/2015 11:17:21 AM
Has anyone addressed whether Title VII ad programs will go along with PPY or not? Currently we are required to collect parent tax returns/W2s to confirm eligibility for Title VII... We need to be sure Dept of ED is working with DHHS so we are not collecting different aid year information.
Kimberly L | 9/22/2015 11:16:34 AM
Two quotes come to mind: "Every rose has it's thorns" and "The devil is in the details." I have been a financial aid administrator for more than 25 years. Unfortunately, we do need to consider the "what ifs", because in the past we have seen the "what ifs" occur to real students and families. I think implementation is far too soon. We have so many details that need to be addressed. In all honesty, I believe the comments of concern here come from people who do want to give good customer service. I am probably going to be stoned to death, but I see bureaucratic gridlock on the horizon if we proceed too quickly.
David H | 9/22/2015 8:57:10 AM
The key to making this change less painful is for the FAFSA web site to still allow users to choose to use Prior Year if their tax data is already available for retrieval. Students shouldn't be forced into a Professional Judgement process with the schools when a robust FAFSA web site could handle both scenarios.
Regina H | 9/22/2015 8:43:47 AM
The Department of Education will have to give us new guidance on how to handle students who are unemployed. Guidance hasn't changed since 2008-09 (GEN-09-05). Will unemployed students continue to get notified they may qualify for Pell with their unemployment letter?
Matthew S | 9/22/2015 8:41:45 AM
If life has taught us anything, it is that change is never easy! Although we can all come up with scenarios and "what if" situations that may raise legitimate objections to PPY, the bottom line is that this is a change that will ultimately benefit students and their families. In the end, isn't this why we do what we do?
William H | 9/21/2015 4:38:55 PM
For 32 years I have been a Financial Aid Director. Other than FAFSA on the Web, this is the most positive thing that I have ever seen for students. I applaud President Obama and the U.S. Department of Education for making this a reality. We in the Financial Aid Community need to make this a success by fully supporting this initiative.
Steven M | 9/18/2015 10:34:19 AM
Attend a Department of Ed session at any conference and you won't hear much about increasing access and making things easier for students, but you will hear a lot about safeguarding funds and ensuring compliance. I'm not tying to insinuate that both can't be achieved, but this is hardly a big win for students or aid offices. It may be easier to enter the front end of the store, but the back end is still full of obstacles red tape.
George J | 9/16/2015 11:54:28 AM
This will sound at best like questionable customer service, and at worst like heresy, but I think that part of the success of using PPY efficiently and effectively will be to make it clear to applicants that the EFC (which now even more desperately needs to be renamed) is an index of aid eligibility that is far, far removed from a measure of ability to pay - even though it uses reported income and other financial measures. Larger schools in particular could experience an unmanageable increase in special circumstance requests as a result of PPY. While I would hate to see our ability to react to those circumstances limited in statute, I think we will have to find a way to limit them in practice.
Maureen M | 9/15/2015 10:11:50 PM
So many headaches to consider, but we are aid administrators and we will do this for our students. In reading through these comments, there is no mention of how this will actually improve things. What we have now is a nightmare. Even if this is a different nightmare, it seems more logical. I have a gazillion implementation questions and concerns, but for just a moment can we bask in the thought that something has been done that might actually help parents and students. I was around when we went from the FAF to the FAFSA. It was hard, but we made the changes and went on. And timelines? What about the implementation of the SMART and Academic Competitive Grants and the sorry roll out of those programs. I know this is going to be a lot of work, but for the first time in a very long time, I actually feel we are making progress. Now if only the feds didn’t think they were the ONLY ones awarding financial aid!!! They make us put "Federal" in front of their awards, they should have to put "federal" when they use the term financial aid.
Jessica H | 9/15/2015 2:56:43 PM
It would be beneficial if the IRS Data Retrieval Tool was "more friendly" in that it wouldn't require an address to be successful. Students applying in 2017-18 with a 2015 tax year may not remember or have access to the address used on the tax year from 2-3 years ago. This currently would render them unable to use the IRS DRT. Also, I would hope that the IRS DRT would automatically select the correct year for verification depending on what FAFSA year application they were completing.
Linda T | 9/15/2015 2:39:07 PM
Would the Feds consider identifiying potential conflicts for example flagging a student for verification when the 1617 FAFSA filing status, AGI or taxes paid do not equal the 1718 FAFSA values?
Catherine G | 9/15/2015 1:39:17 PM
We will be using 2015 taxes fpr both 16-17 and 17-18. So if our office receives a 2015 tax return for a verified 17-18 ISIR when 16-17 wasn't selected, does that mean we have to go back to verify 16-17 then too?
Whitney A | 9/15/2015 1:33:03 PM
With this change I'd like to see some expansion of the availablity of the DRT. It would be most helpful if students/parents information could all be pulled in regardless of the filing status used or amendments. Also, I'm thinking that it has to be possible for some techy to write a forumla that could pull any return's information by SSN and combine it with another's information ( for those 'married filing seperately' and newlyweds) Additionally, for student populations like ours that have so many non-filers it would be AWESOME if it could also confirm for a student/parent that there is no record of a tax return on file for them. While we're at it... Because in FA we always dream big... could the wage informtion for parent1/parent2/student not be pulled directly in as well? Way too many skip that information now that they are using DRT.
Gary B | 9/15/2015 1:4:37 PM
What about those students/parents filing "married, filing separately" who can't use DRT. Does ED/IRS work out a way to use DRT for two separate returns? And what about those whose marital status does not match their tax filing status, which becomes more likely using current marital status, but prior, prior year for income. I can foresee having to troubleshoot a slew of those c-codes.
Karen S | 9/15/2015 12:45:32 PM
I agree with all of the prior comments and would like to see definitive guidance on "PJ's" for schools. I would also like to see multi-year verification worksheets or better yet the elimination of the verification process.
Tracy H | 9/15/2015 12:5:41 PM
I'm going to try and not repeat what others have said, but the timeline for this implementation just isn't long enough, and doesn't give schools or anyone else the necessary time to prepare. This is a fundamental change in how and when students and families apply for aid. As you can see by the all the comments, this change has a snowball effect on so many of our operations. I doubt all of the software providers are going to be ready in less than 12 months for this change...not to mention CPS! The reality is that public colleges and universities are going to know very little, if anything in October about cost of attendance due to the state legislative cycle. Yet we're going to be pressured to put out estimated packages to students based on historical costs and award amounts earlier, and then will likely have to re-package once we know actual costs.
While I support the premise behind PPY in regards to verification, this tight timeline is going to lead to even more confusion and frustration and will likely only allow us to put out bad information earlier.
Bruce D | 9/15/2015 11:41:03 AM
We are a quarter school that begins in late September. This change means that we will be opening our fall term, finishing year-end federal and state reporting, and bringing up the new cycle all at once. This will also shift the outreach expectations back several months and it is likely the high schools will want us to start showing up in September. And while it mitigates much of the verification burden, it puts the federal cycle even further out of sync with our state legislative cycle, which will result in a high degree of "churn" with regard to packaging and repackaging. On the positive side, I am looking forward to finally being able to take a vacation in April!
Cristi M | 9/15/2015 11:33:18 AM
Letting students know what this means and what they can now do is crucial. I've even had people at my school say, "Oh, now they can choose the year to use." So there is still a lot of confusion and misunderstanding about what this actually means. Also, I think the schools need to keep track of requests for professional judgment to help gauge the accuracy of using PPY data. When talking with my colleagues, this was one of the major concerns I often heard. I think it can be a useful tool for students to be able to use the IRS DRT, but it will be important to keep track of this information.
Tony T | 9/15/2015 11:13:45 AM
Has anyone considered the impact on FAO's as it pertains to the overall impact on the yearly calendar? Traditionally, after submitting FISAP on October 1, the Oct-Nov-Dec time frame is used for cleaning up from Fall move-in and preparing everything that will be needed for the new crop of recruits being targeted by Admissions. Making FAFSA available on October 1 means that having time to be able to prepare all of our new year's requirements will go away. We will be going directly from one cohort into the next with no prep time. Don't forget that the last 3 months of the year are targeted times for conferences/training (State/Regional/FSA), so this will impact time availability. It appears that while the stresses of "verification" may be going away, but keep in mind that the stresses of having to get things done sooner is on the horizon.
Zach G | 9/15/2015 10:54:07 AM
We'll have to look at how and when we survey students for constructing our 17-18 COAs. There isn't a lot of trend data to pull from in the limited time between the next two award years. Some indices we use as secondary sources are only updated annually, so we'd expect to leave most components the same as 16-17. Institutional components (tuition/fees/room & board for on-campus) aren't usually approved by trustees until February before the next year. To really support this effort, our administrations will need to be on board with earlier cost-setting, but enrollment trend data will not be actionable to set costs prior to Oct. 1.
Brian W | 9/15/2015 10:45:34 AM
How does the FAFSA becoming available Oct 1 impact state deadlines for state aid? Will/should states move their deadlines back in order to be able to notify students of their eligibility earlier? Then how does this impact non-traditional students who tend to file later in the year and their eligibility for state aid programs that move their deadline earlier. Should we move financial aid nights into spring of the junior year in high school as FAFSA filing season will be in the fall?
David S | 9/15/2015 10:31:33 AM
PPY should mean that the word "verification" is struck from ED's vocabulary forever. It's 2 year old data, virtually everyone who's a tax filer should be able to use IRS data retrieval. If ED wonders if that's accurate, let the IRS go audit them.
PPY also can only be a game changer if admissions moves away from the traditional April 1 answer, because we can't package applicants who haven't been admitted. Waiting until April 1 for an admission decision negates any advantage of doing the FAFSA in October.
But nice to see a big idea talked about and then happen. Most big ideas just get talked about and nothing else...like the FAFSA simplification I've been hearing about for 20 years.
Jane H | 9/15/2015 10:25:15 AM
The campus based funding cycle will need review. Currently the tentative awards are not released until February and Final in April. To be able to advise students of their eligibility, institutions need to know what they will have for campus based funding.
James C | 9/15/2015 10:18:58 AM
When will the Pell schedules be out? If the purpose is to start running aid packages in the fall of the prior year Pell schedules will need to be finalized by Oct 1. Also Erin C above makes a great point with potentially conflicting info by using the same tax returns for two years in a row.
Lyn K | 9/15/2015 9:46:20 AM
I'm curious as to how this will affect the resolution of conflicting data between the PROFILE IM and the FAFSA FM. Will the IM move to PPY as well? If not, will the possibility of conflicting data have to be monitored over multiple years?
Al D | 9/15/2015 9:28:14 AM
The implementation of PPY will need to be thought out thoroughly, primary concerns are the following:
1) Will student information systems (i.e. PeopleSoft, Banner, Datatel, etc...) be prepared to adjust to the implementation of PPY? Software products will need to be updated faster so that schools are prepared to receive and process information.
2) How will state funding agencies adapt to PPY? Most state agencies will not want to take in Prior-Prior Year information, which if not coordinated correctly will affect student award eligibility. This also can possible confuse students who provide prior-prior year information on the FAFSA, but then the state selects them for verification and request prior year information. If the student is federally and state selected, then the school is requesting prior-prior year information, but the state is requesting prior year.
Cissy Van S | 9/15/2015 9:8:33 AM
I think the burden on the schools will increase tremendously. Layoffs and retirements will create special circumstances as well as changes in marital status. What about the parent who was divorced but now remarried. The student would be at an unfair advantage. I see a verification nightmare. Not sure of why now with the IRS tax retrieval in place.
Elaine H | 9/15/2015 9:6:18 AM
With any change there will be things to overcome at implementation. We will work in two years initially, but only one after that. Special circumstances requests could increase, but things like loss of income should be easier to document with the current year tax return.
The Department of Education will need to change their schedule of verification requirements and what is needed for software changes much sooner.
We will need to change our communication regarding scholarships and it is likely we will not have state and federal allocations much earlier than we do now.
Much conversation needs to take place very quickly to ensure that we have the best implementation plan possible.
John C | 9/15/2015 9:3:12 AM
My primary concern is that PPY income will not accurately reflect the student/parent's current income situation. The likelihood of an increase in professional judgments is pretty high in my opinion. Additionally, I'm curious to hear from our software developers and state agencies how the PPY transition will take place, and what the impact on their release schedules will be.
Erin C | 9/15/2015 8:43:31 AM
There is going to be one year when students will be completing the 2016-17 FAFSA and the 2017-18 FAFSA using their 2015 tax returns for both award years. What happens when a student is not selected for verification in 2016-17 but is selected for verification in 2017-18 and after verification we find out that the student's EFC is much higher in 2017-18 and not eligible for aid they received in 16-17? Is this considered conflicting information? If a student received Pell in 2016-17 and not eligible after verification in 2017-18, do we have to return Pell from 2016-17? How much liability will be on the schools for 2017-18 in this scenario??
Paul W | 9/15/2015 8:38:54 AM
It's likely there will be more situations where PPY income/assets is not reflective of current or most recent year's income/assets. Families will want to or need to share that information with colleges and families will have more time to do so. It will place additional burden on college administrators to evaluate these potential differences.
Sandra P | 9/15/2015 8:37:36 AM
This has both good and bad implications. Good: tax information will be available early and verification of files completed early. BAD: I cannot imagine the amount of special circumstances we will receive due to a change in families' financial status from two years ago. The economy has shown loss of jobs or income in one year!
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