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How to Trim FAFSA’s Fat

The complexity of the federal financial aid process is among the more obvious, and ostensibly, fixable reasons cited to explain why low-income students are far less likely to attend college than their peers. So far, despite efforts on multiple fronts, the system has proven to be somewhat intractable.

But on Tuesday, the movement to simplify the process — jump-started in September when Secretary of Education Margaret Spellings performed a stunt unfavorably showcasing the length of the Free Application for Federal Student Aid relative to the standard tax form — gained new momentum.

Rep. George Miller (D-Calif.), chairman of the House Committee on Education and Labor, and Rep. Rahm Emanuel (D-Ill.), announced new legislation that would cut the form’s length from five pages to two, while increasing Web access, allowing high school juniors to file a “Pre-FAFSA” for planning purposes and encouraging coordination between the Internal Revenue Service and the Department of Education. Similar legislation was also introduced in the Senate. Meanwhile, Sen. Edward M. Kennedy (D-Mass.), chairman of the Senate Committee on Health, Education, Labor and Pensions lauded the Education Department’s development of a new “FAFSA forecaster” as “a good first step.” (Department officials plan to unveil the new initiative today.)

The pair of Congressional announcements from the education committee chairs complemented the recommendations of a report on FAFSA simplification released Tuesday by the Institute for College Access & Success, likewise proposing a mechanism for vastly simplifying the form by “going to the source” and promoting a better exchange of information between the IRS and the Education Department.

Lauren Asher, author of “Going to the Source: A Practical Way to Simplify the FAFSA,” points out that 31 questions on the federal financial aid form — or about two-thirds of those relating to income and assets — ask for information already provided to the federal government on tax forms. Asher argues that by enabling students to easily authorize the IRS to forward that data directly to the Education Department, students would end up facing a far less intimidating form, while colleges could save millions in verification costs.

“Now is the time to really look at the question of whether families could check a box and have the IRS answer some of the toughest and some of the most important and some of the most error-prone questions automatically,” Asher, associate director of The Institute for College Access & Success, said Tuesday. She recited a FAFSA question in which students and parents are asked to consider not one, but three, different tax forms, as an example of the complexity they currently face: “It really takes a tax expert to figure it out.”

“The FAFSA was designed as the gateway to financial aid,” Miller added, speaking during an audio press conference hosted by the institute. “We now see a situation in which the form itself can deter people from applying for the aid that is necessary to go to college.”

Student advocates, lawmakers and Secretary Spellings alike have criticized the complexity of the current financial aid form as being a barrier to college access, particularly among low-income students, who, the report states, tend to have greater difficulty compiling the necessary financial information. An estimated 1.5 million low-income students who were likely eligible for Pell Grants did not apply for aid in 2004, nearly double the number in 2000, according to the report.

Often, attempts to change the federal financial aid form focus on cutting back the amount of information requested, a controversial proposition that could alter who gets aid and how much, Asher said. Tuesday’s report doesn’t delve into questions surrounding potential formula changes, but instead advocates using technology to more efficiently collect the information already being considered.

Given the advances in electronic filing and transmission, the authors argue that students should easily be able to bypass some of the most complex financial questions by authorizing the Education Department to obtain the relevant data directly from the IRS. Under the report’s recommendations, students could apply as early as October while applications and colleges are on the brain, as opposed to January, as is currently the case, since the most recent year’s tax return would be used. (The report also emphasizes a need for an improved system through which students can more easily notify the Education Department of changes in their financial circumstances).

In addition to simplifying the process for students and reducing the possibility for error, Asher argues the shift would likewise simplify the process for colleges. With data provided directly by the IRS, colleges would eliminate the need to verify the data currently provided secondhand (estimated to cost $90 per application, or more than $400 million nationally per year) – thereby also reducing the administrative paperwork burden and the corresponding privacy risks. Meanwhile, the report recommends that the IRS should also consider how other tax forms, such as the “Verification of Non-Filing” transcript for those whose incomes fall below the tax filing threshold, could be used to help students automatically qualify for federal aid.

“This is totally feasible. Every day the IRS gets requests to send tax data to all kinds of third parties,” said Asher, referring to the fact that the agency also recently began transmitting data to third parties in electronic form. “You can have your taxes sent to your sister, if you want, anyone with an address.... We’re not talking about reinventing the wheel here; the wheel’s already there.”

Elizabeth Redden

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Comments

Trim FAFSA Fat

I have been a financial aid administrator for 30 years and know the difficulties student’s face in applying for federal aid and the burden put on college financial aid offices in trying to obtain financial documents. This proposal, if implemented, would ease the burden for all concerned and makes so much sense that it probably won’t ever happen.

Sharon Baldwin, Director of Finance at Concorde Career College, at 11:06 am EDT on March 21, 2007

Trim the FAFSA fat

This is a great first step but it needs to go further..Since the majority of students in college today are independent students, with limited earnings and usually no assets, now is the time to ELIMINATE the Fafsa for these persons as well as others. This change will include a significant number of persons who now need to prepare the FAFSA. In addition to the independent student, it probably would include a significant number of students from low income families.

We need to catch up with the IRS. As you know, if you have only straightt income, you only need to sign a postcar5d and the IRS calculates the tax due. Next step, let us convice IRS to do the FAFSA calculation for our college students. The result would be a great service and also improve access.

The next big step is to completely overhaul the Financial aid system. It was launched in 1965 and it needs a comprehensive overhaul- top to bottom, so this great program will better serve our country. The financial aid system, education tax peograms- all make the system too complicatyed for most of our citizens.

Leo Kornfeld.

Leo Kornfeld, at 11:06 am EDT on March 21, 2007

“Trimming Fat” makes for clever print, but a poor analogy

As someone who works with the form nearly every day, I certainly concur that the application is overly complicated — and the tax items are just one small piece of that.

In fact, I would echo Mr. Kornfeld’s sentiment that above and beyond the FAFSA, the entire process is in need of overhaul.

On that point, any proposal of this sort is not as simple as “removing fat.” A much more apt (though not as cleverly concise) analogy is to view the FAFSA like “the esophagus in the digestive system” and recognize that any changes you make to said esophagus will likely ripple down through the rest of the digestive system.

In short, it is unlikely you can carve off a piece here and there, nor tweak the form in this manner without realizing that there are potential implications and pitfalls the rest of the way through the system.

That a journalist would miss that nuance (or choose to overlook it) does not worry me near as much, however, as the fact that many in Congress is viewing the manner in a similarly superficial manner.

As one simple example, the calculation of a student’s “EFC” is dependent on (what is termed) “prior year” income. Students/parents who have not yet actually filed their prior year’s taxes are allowed to estimate their figures. Tying the calculation to actual IRS data would mean either forcing other patches such as relying on “prior-prior year” (i.e. using 2005 income to determine eligibility for fall 2007) data*, or creating ‘unforeseen’ problems such as delaying when a student could determine their eligibility for fall 2007 (especially if their parent receives an extension to the April 15 tax deadline).

If the solution is to use ‘prior-prior year’ data, as suggested, there is some advantage in terms of easing challenges with the initial application. But one consequence is that also means the data will more often NOT reflect a family’s current financial situation. Among other issues that creates, more families would then elect to seek some manner of “special circumstance” consideration from their school (unless that process is simultaneously addressed), which is often not a simple process either. If so, Congress would merely have succeeded in shifting the family’s distress in applying off of the FAFSA form and onto subsequent interactions and appeals with their school’s financial aid office (and creating a simultaneous administrative load for schools).

This points to the fact that the problem is not intractable because no one wants it changed — I would wager 99% of financial aid professionals would eagerly welcome most simplifications to the system, and I have been at several events where these conversations have taken place between school officials and Dept. of Ed officials. However, for better or worse, Congress writes the regulations and not school or ED folks.

The trick for Congress (and in IHE in reporting on the matter) is making sure they know it’s NOT as simple a matter as carving fat off a dead cow. And if they don’t understand that, they should be making every effort to bring in the folks who regularly deal with the messy reality in the entire system. And once they understand that, then they can get to the business of actually negotiating amongst themselves in the process of reshaping the law.

Financial Aid persons of all stripes should echo the call for simplifying the process, yet at the same time avoid the pitfall of implying doing so is as simple as shifting questions off the FAFSA and onto the IRS and/or schools.

On a similar note, the IHE article linked to the (glowy and hopelessly vague) press releases on the new proposals, not any clear explanation of how Rep. Miller (et al) actually imagine this change functioning. It’s a topic ripe for discussion, but also ripe for having the substantive issues reduced to soundbites.

And if that happens, what comes out of the new legislation may not work any better on the whole than the current set of laws.

Peter

* I do note that the article refers to this as the “most recent tax year’s tax return” which is either incorrect or misleading, depending on what the author meant specifically. Likewise, the prior year vs. prior-prior year issue is not the only significant snag, but lest I write all day, I’ll leave it with just the one example.

Peter, West Coast Univ., at 6:05 pm EDT on March 21, 2007

Are these really a way to improve FAFSA?

I am fairly new to financial aid being only 6 months in the field. I am a tax professional of four years, I own my own accounting firm, and I work for my local community college because I am truly dedicated in advancing education. I have a perspective that I would like to share regarding the FAFSA.

While it can be said that the FAFSA application is a tedious process, I don’t think that because the application is long its entirely undoable. I have been to many financial aid presentations with parents and students in which a serious lack of effort is put in their part. Instead of completing the FAFSA for them I have been teaching people how to fill it out. It is far too easy for people to give up when they encounter a difficult question then to seek out assistance. To be honest I don’t think I or anyone can do anything about that. In general people really need to put forth more effort.

If one wants to simplify FAFSA, is shortening the application really the answer? As of now the paper FAFSA has a set of detailed instructions and commentary for the more difficult questions. One only needs to reference the question by number and then answer the question. It is true that there are several questions that refer to a tax return however every question of this type has a line number to refer to on the tax return to get the correct answer. Anyone involved in financial aid knows that ALL the questions on the application are used to assess, and formulate a student’s financial need. Therefore, all questions are essentially necessary.

Now, there is proposal to have the Internal Revenue Service (IRS) provide the tax/financial information. For current tax year information the idea sounds great in concept but is logistically unrealistic in practice. As I mentioned, I’m a tax professional and I deal with the IRS quit a bit. I can tell you from experience the IRS can not furnish tax return information until early August when a majority of tax returns are up loaded into their system. Tax returns are up loaded as received through electronic transmission, however low income people can’t afford to have their taxes electronically filed (and often times they don’t even have the money to even have them prepared). Even if having the information available “in real time”, anyone who is applying for Federal aid would have to file their tax return before state submission deadline (for most states early March). Then there are people who file using a paper return, those returns take substantially longer to process and up load and the closer to April 15 they are filed, the longer it will take to process (up to six weeks). Lastly, there are two more groups that this would not work for: anyone who is selected for review (formerly know as an audit) will not have tax data available because they are limbo until the case is closed and people who don’t have a requirement to file either because they had little or no income or only unearned income (public assistance of any type).

In addition, the Institute for College Access & Success, issued a report where as the Other Issues section states, “If the Department of Education uses the most recent year of tax data that is available from the IRS when the FAFSA is filed…much of the complexity is eliminated.” However, if one were to use prior year tax information, the information would be much too old and inaccurate to assess student need. For example, if a student applies in February of 2007 for aid in the 07-08 academic year and the “most recent tax information” is to be used but her/his parent’s haven’t filed a 2006 tax return they would use 2005’s tax return information. 2005’s tax information could be obtained from the IRS but it also means that one and a half years have transpired between the time the student begins college (fall 2007) and the time the income reported was earned (end of December 2005). This is a doubled edged sword because if a family did very well financially in 2005 but had a drop in income in 2006; their EFC would be higher because of the 2005 income thus effectively reducing the amount of aid. On the flip side, if a family did poor in 2005 but had a rise in income in 2006 they would be over awarded because of a low EFC. Changes in income are a serious reality for many people that walk through our doors. In fact, people that previously could afford a college education for their children, seek us out because something bad happened to their finances.

In addition the report cites, “Many experts believe that the family incomes of dependent students fluctuate much less from year to year than the incomes of independent students.” While this may be a statistical truth, income fluctuation sometimes has little to do with the outcome of a tax return. For example we’ll follow a family of four for four years, they have an income of $34k for four consecutive years (2004, 05, 06, 07), and one child will begin College in the fall of 2007. I will also assume that they claim a $15,000.00 itemized deduction of $14,000 mortgage interest and $1,000.00 for real estate taxes. On their 2004 tax return they will have one set of figures but on following years the figures to be reported for: itemized deductions, taxable income, child tax credit, income tax, and Additional Tax credit can be different from one year to the other, and their income did not change. Although I am assuming a constant itemized deduction I want to point out the following: from this year forward millions of low income families that purchased a home in the hay days of low interest rates a few years back, did so with an interest only loan (in order to qualify) and many will have to refinance, thereby the amount of their itemized deduction will change, causing the amount of taxable income to change, changing the amount of the income tax liability. With that said, I will now assume that the family did not refinance but the following will undoubtedly occur. When that college bound child turns seventeen years of age, the parents can no longer use her/him as a qualifying child for the Child Tax Credit, thereby decreasing their tax liability credits. This would also affect the Additional Child Tax Credit, as the basis for the credit would decrease from $2,000.00 to 1,000.00. As one can see it is NOT a change in income that caused a different outcome in the figures that are reported on the tax return. Changes will naturally occur again when the second child turns seventeen, causing another chain reaction that will result in a completely new set of figures. There are far too many variables in the lives of ordinary people that have a direct affect on their tax reporting. It is unrealistic to believe that everything is constant for tax reporting purposes just because household income did not go up or down. (See table below)

Tax Year 2004 2005 2006 2007 Child one age 16 17 18 19 Child two age 14 15 16 17 Form 1040 2004 2005 2006 2007 Line 7 Gross Income 34000 34000 34000 34000 line 22 total income 34000 34000 34000 34000 line 37 Adj. gross Inc 34000 34000 34000 34000 line 38 AGI 34000 34000 34000 34000 line 40 Itemized Ded. 15000 15000 15000 15000 line 41 AGI — Item. Ded. 19000 19000 19000 19000 line 42 Exemptions 12400 12800 13200 13600 line 43 Taxable Income 6600 6200 5800 5400 line 44 Tax 663 623 583 543 line 53 Child tax credit 663 623 0 0 line 57 Income Tax 0 0 583 543 line 63 Total Tax 0 0 583 583 line 66 Earned Inc. Cr. 0 0 911 911line 68 Add. Child Tax Cr. 1337 377 0 0

As one can see from this table, every year figures on the lower half of the table changed for different reasons none of which had to do with a change in income. Please note that all the figures that changed are the figures that are asked for on the FAFSA. Furthermore, I am not convinced that, “allowing high school juniors to file a “Pre-FAFSA” for planning purposes…” will achieve the desired result unless you integrate tax preparation mechanisms to accurately forecast future tax reporting. I would like to elaborate on something Secretary Spellings touched on as stated in Elizabeth Redden’s article, “Student advocates, lawmakers and Secretary Spellings alike have criticized the complexity of the current financial aid form as being a barrier to college access, particularly among low-income students, who, the report states, tend to have greater difficulty compiling the necessary financial information. An estimated 1.5 million low-income students who were likely eligible for Pell Grants did not apply for aid in 2004, nearly double the number in 2000, according to the report.” I would argue that it is not a lack of accessibility to the FAFSA application that causes students not to apply, but a lack of access to resources for “low-income students” so they can get help from somebody who can explain to them what documents they need to gather, and how to extract information from those documents to complete the FAFSA. I am not the type of person to criticize and criticize without offering a solution, so here is my proposal. I’ve heard a rumor that in the near future the Federal government will eliminate the production of paper FAFSAs. That money can be used on an education campaign that will give financial aid administrators and staffers the resources to teach high school counselors and career center directors so that they have the knowledge to assist students. I can recall several instances, in which a high school career center director ventured on their own to assist parents and students with out any assistance from a financial aid specialist. Many times these people are well intentioned but disseminate wrong information on how to fill out the FAFSA (information that later consumes time to rectify). The more “how to” education we in Financial Aid can pass on and train others like counselors and career center technicians the more access confused students will have. Secondly, I would add features to the FAFSA on the Web application that add more user interface, with additional links to difficult questions, where the link can give examples and possibly even brief instruction video. I think this is a much better use of available technologies.

Without a doubt there is no quick fix to FAFSA accessibility, but the answer does not lie in changing the road map because you don’t like the path you must take to arrive at your destination. What we need are many points of information along the path so the journey is not so difficult.

Lastly a few words about my background, I graduated from Crafton Hills College with and AS in Accounting then transferred to CSU San Bernardino. There I received a BS in Business Administration with a concentration in accounting and unofficial minors in communications and political science. I was a member of the student government holding various positions, I was a delegate to the California State Student Association, I was a member of the Outstanding Delegation at the National Model United Nations Conference hosted by the National Collegiate Conference Association, and I was awarded a fellowship at the Leon and Sylvia Panetta Institute for Public Policy where I interned for the US House of Representatives.

If anyone has access to or knows Elizabeth Ridden, please ask her to read my comments regarding her article and the legislative proposals. You can email me at framirez@craftonhills.edu Thank you.

Fermin Ramirez, Financial Aid Outreach Coordinator at Crafton Hills College, at 9:05 pm EDT on March 22, 2007

Trimming FAFSA fat...

Praise the Lord and pass the ammunition! I just hope these proposals pass. They are certainly needed and would greatly expedite the filing process. I just hope that THEY do not let the bureaucrats screw this up.

feudi pandola, at 9:21 am EDT on March 26, 2007

How to Trim FAFSA’S fAT

In an effort to reduce the number of questions found on the FAFSA to make it easier for students to apply for aid, it is my hope that we keep in mind one potential problem that may be caused by eliminating certain questions. I am referencing the fact that the FAFSA has certain questions that help students to obtain “state” financial assistance. If any of these questions are removed from the FAFSA, will that mean that states will soon require a “form” of their own that students must complete. If that is true, than simplifying the FAFSA will cause more problems than it will solve.

Ellis Salim, Vice-President for Student Services at Baker College System, at 2:35 pm EDT on April 5, 2007

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