Racial Equity Considerations in FAFSA Completion Policies

Postsecondary & Workforce

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This guest post comes from Brittani Shaw-Williams, senior policy analyst in higher education at Ed Trust. This is the third post in our FAFSA for Graduation Series where experts share experiences on considering or implementing state FAFSA graduation requirements. All views in guest posts are those of the author. To learn more about state financial aid programs, check out our 50-State Comparison on Need- and Merit-Based Financial Aid.

In an effort to support students’ transition to postsecondary education, many states are considering  policies that would make FAFSA completion mandatory to graduate high school.  As states are considering FAFSA policies, it is important to center equity in the bill drafting and implementation plans to ensure policy and student success.

To center equity in FAFSA policy and implementation, policymakers can target strategies and supports for underrepresented students, including students of color, students from low-income backgrounds, undocumented students and mixed-status families, and students who are currently or formerly incarcerated and not typically included in this scope of FAFSA support services. Additionally, with recent legislation in place, states can broaden the lens of who and where to provide FAFSA completion support.

Every state can begin determining best practices that fit their students’ needs by using disaggregated statewide data on current high school students. State staff can focus on engaging stakeholders like college financial aid office directors, district superintendents, and college access community-based organizations to target strategies based on student and family circumstances. For example, because many students and families work varying hours, it is important that states conduct targeted outreach initiatives and have session availability during nontraditional hours and weekends, including virtual options. Arizona, Indiana, Louisiana, Mississippi, Virginia and other states have noted success with these family-centered events.

How to support undocumented students and mixed-status families

When states move to require FAFSA for high school graduation, policymakers can consider how the requirement impacts undocumented students and students from mixed-status families where the students are documented but one or more family members is not.

For context, all undocumented students — including those with Deferred Action for Childhood Arrival (DACA) or Temporary Protective Status (TPS) — do not qualify for federal aid, including federal work study and Pell Grants. Access to in-state aid and state grants varies widely. That considered, if a state requires all students to submit a FAFSA to graduate, it puts undocumented students in a bind, since they do not have a social security number to complete the application and feel they must disclose their status in an unsafe setting.

To support undocumented and mixed-status students, states can:

    • Include opt-out options for undocumented students that protect student data and privacy.
    • Use state-institution partnerships to provide guided individual support on how to submit the FAFSA for students with family status apprehensions.
    • Consider support at the federal level for undocumented students to become eligible for federal aid.

How to support people impacted by the justice system

Lastly, states can consider FAFSA access and support for justice-impacted individuals. In December 2020, the FAFSA Simplification Act lifted the ban on Pell Grants for students who are currently incarcerated and removed the restriction that people with certain drug-related convictions could not qualify for Pell Grants. This act also eliminated the requirement to register with the Selective Service System to receive financial aid, which was a significant barrier for students who may not have registered for selective service because they were incarcerated prior to age 26. This was a huge step in supporting this underserved population of students.

However, students who are incarcerated still face huge hurdles with navigating FAFSA completion. A few examples of the barriers most students encounter include little or no internet access, a lack of support in filling out paper applications and little or no postsecondary transition support.

State policymakers can support justice-impacted individuals by:

    • Creating working groups to plan FAFSA support for students who are incarcerated, including state department of justice staff, counselors and faculty who work in prison programs, and coalitions such as Unlock Higher Ed and Underground Scholars.
    • Creating state-institution partnerships that make justice-impacted students eligible for in-state tuition and need-based aid. This may be supported by removing questions about criminal history in the college admissions process. This has been passed in California, Louisiana, Maryland and other states.

Each state’s student demographic is different and may require additional points that support equitable policies and implementation. These are just a few considerations to support FAFSA policy for undocumented and justice-impacted students. Racial equity considerations in FAFSA completion policies gives these mentioned student populations access to postsecondary opportunities and continues to be a significant focus area for states considering the requirement.

Stay tuned for the next post in this series for an inside look at implementation strategies from the state that ranked highest in high school FAFSA completion in 2021.

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