An Inside Look at FAFSA Completion as a Graduation Requirement

Postsecondary & Workforce

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This is the first post in our five-part FAFSA for Graduation Series where experts share experiences on considering or implementing FAFSA completion graduation requirements in states. To learn more about state financial aid programs, check out our 50-State Comparison on Need– and Merit-Based Financial Aid.

For the past several legislative sessions, state leaders interested in increasing high school seniors’ FAFSA completion rates have considered whether completion should be a graduation requirement. Advocates suggest that a requirement sends a firm signal that completing the FAFSA is a key part of transitioning to postsecondary education, while others express concerns about privacy and question whether simply completing the FAFSA impacts students’ postsecondary enrollment decisions.

Currently, Alabama, California, Illinois, Louisiana, New Hampshire and Texas have enacted regulatory or statutory language requiring students to fill out the form as a condition of high school graduation. As the idea has diffused across states, several states have also made key iterations that focus on funding and flexibility.

For example, Colorado H.B. 21-1330 creates the Student Aid Applications Completion Grant program within the Colorado Opportunity Scholarship Initiative. A school district, charter school or local education agency can opt to apply for grants from the program. Participating schools and districts must require students to complete the FAFSA before high school graduation unless the student meets waiver requirements set by the school or local education agency.

In 2019, Indiana enacted legislation requiring the commission on higher education to prepare a model notice related to the FAFSA. Schools are also required to distribute the notice to students. Similarly, legislation in Maryland stops short of requiring students to file the FAFSA; however, it does obligate local boards of education to encourage and assist as many high school seniors as possible in completing and submitting the FAFSA.

Each of these state efforts exists in response to decreasing FAFSA completion rates across high school students and decreasing enrollment rates in postsecondary sectors. States have a key role to play in ensuring that students are aware of financial aid and postsecondary options, as evidenced by introduced and enacted legislation since the outset of the COVID-19 pandemic.

In the next posts in this series, we will hear directly from state leaders and experts involved in considering or implementing FAFSA completion graduation requirements. Each of these authors have deep expertise in how states can support increased FAFSA completion. Staff from Iowa College Aid share their intentional process for considering changing their state’s high school graduation requirements. Experts from Ed Trust show how states can approach FAFSA completion efforts while centering equity. Leaders from the Louisiana Office of Student Financial Assistance highlight lessons Louisiana has learned as the first state in the nation to enact and implement the requirement. Finally, state leaders in New Hampshire share approaches to implementation in districts with distinct characteristics.

We hope this series is helpful to understand the variety of approaches states have taken to increase FAFSA completion amid unprecedented challenges. More information about FAFSA completion can be found in a recent State Information Request and Policy Brief.

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Senior Policy Analyst at Education Commission of the States |

Sarah supports the research and analytical capacity of the policy team in her role as a senior policy analyst at Education Commission of the States. Sarah has extensive experience in student financial aid programs, and is frequently called upon as an expert in state financial aid policy and practice. A recipient of state aid herself, Sarah believes that state policy leaders have a key role to play in ensuring affordable postsecondary opportunities for students from all backgrounds.

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