Washington Update

Prior, Prior Year Continues to Pose Implementation Difficulties

Earlier this year, the Administration announced the intent to change the availability of the FAFSA from January 1, of the academic year for which it was to be used to determine aid eligibility, to October 1. At the same time, it enabled the use of “prior, prior year” (PPY) tax data in determining a student’s eligibility for federal student aid. These changes were supposed to provide students more time in which to file for aid and consider their awards.

However, in a letter sent to the presidents of several higher education presidential associations, including NAICU, twenty-six Democratic Members of Congress asked the associations to encourage their member institutions not to move up priority deadlines for institutional aid applications.

The Members of Congress argued that low-income students were often the last to apply for aid, and an earlier aid application cut-off might be harmful for them. This message was in sharp contrast to the recent push to provide information about aid as early as possible, and adds additional uncertainty to an already confusing situation.

Although there had been wide-spread support for the use of PPY for its ability to provide automated, reliable, and earlier federal income data, the Administration’s decision to also move up the filing date meant that needed information of aid available from sources, such as state grant programs, would not be available to students, primarily because of budget schedules. Pell Grant award levels will also not be known at that time, as the appropriations process will not be completed.

Now schools are confronted with missing information and contradictory advice on the timing of awards. Awarding aid will be a challenge for the coming year, and schools are trying to work through the various hurdles, often having to provide disclaimers on early aid awards that the amount is an estimate and could change. But the lawmakers’ general admonition to ensure that whatever processes are adopted are mindful of the special needs of low-income students, is a good reminder of the reason for the change in the first place.


For more information, please contact:
Maureen Budetti

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