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WASHINGTON -- The top Democrat on the House of Representatives Oversight Committee on Monday asserted that more than 100 colleges may be violating federal law by either requiring students to submit fee-based forms for federal student aid or insinuating that such forms are needed to access that aid.

In a letter to Education Secretary Arne Duncan, Representative Elijah E. Cummings of Maryland wrote that the institutions “appear to be establishing additional requirements for students to complete costly additional forms” such as the CSS Profile, in order to be considered for any financial aid.

The Higher Education Act prohibits any entity from charging a fee for “the collection, processing, or delivery of financial aid through” the Free Application for Federal Student Aid, known as FAFSA. Colleges are allowed, however, to require additional information from applicants through forms like the CSS Profile before they award their own aid dollars.

The CSS Profile, which is administered by the College Board, charges an applicant for financial aid $25 for the first college and $16 for each additional institution.

Cummings said his staff reviewed 200 institutions and identified 58 colleges that explicitly state on their websites that applicants must submit the CSS Profile, which charges a fee, in order to receive any type of financial aid, including federal student aid.

In addition, he said, 53 institutions direct students to submit both the CSS Profile and FAFSA forms but “they do not clarify what each form is used to assess.”

Justin Draeger, president of the National Association of Student Financial Aid Administrators, said that any confusion over the financial aid forms may be driven by colleges’ efforts to get students to apply for the large amounts of institutional aid available to them. Cummings’s list features some the nation’s wealthiest institutions that meet students’ full financial need, he noted.

“These schools are walking the fine line of saying, ‘Yes, you can apply for federal student aid freely through the FAFSA but you can get a lot more institutional financial aid if you also fill out this additional application,’ ” such as the CSS Profile, Draeger said in an interview. “Perhaps some schools may not be wording that in the most correct way, and maybe they could be clearer if they are giving the impression that students have to pay a fee to apply for federal student aid.”

Cummings’s letter requests a meeting with Duncan to “discuss how the department can address this issue by warning schools that this conduct may violate federal law.”

An Education Department spokesman said Monday that the department had received the letter and was reviewing it.

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