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As tuition prices rise and policy makers increasingly recognize the vital importance of an educated work force and citizenry, the free-college movement has attracted widespread support from students, advocates and lawmakers from both political parties. As outlined in Ed Trust’s recent report, “A Promise Fulfilled: A Framework for Equitable Free College Programs,” those programs vary greatly in terms of who’s eligible and what benefits are provided. But most of them share a common requirement: that applicants complete the Free Application for Federal Student Aid, this year’s version of which is now available at

While this seems like a reasonable and straightforward requisite, families who have filled out the FAFSA know it’s anything but -- and that’s especially true for the students who are caught in the trap of FAFSA verification.

If you’ve never heard of FAFSA verification, count yourself lucky. It’s basically like a tax audit, requiring students to prove that the information they provided on the FAFSA (itself well over 100 questions), is accurate. For many students, their ability to go to college hinges on whether they can jump through all the hoops in time. Yet the FAFSA form is long and challenging for many students, especially those who are first in their family to attend college, and the verification process makes it all the harder. In fact, as a direct result, millions of students either never enroll in college or don’t get financial aid to pay for it -- whether through federal Pell Grants or access to statewide free college programs.

Either a postsecondary institution or the federal government can ask students to complete the process, in which case they’ll be required to do so at every institution they applied to. Those selected must provide a wide variety of documentation to prove their income, how many people live in their home or how many family members are enrolled in college. For students required to confirm tax information, they have an especially challenging step of getting a copy of their tax transcripts. That process is hard to navigate and often takes a significant amount of time. Without the ability to finish FAFSA verification, students can’t receive a financial aid award package. The delay can result in students postponing enrollment, missing the start of the semester or not making it to college at all.

The struggle of completing verification is all too real for the students of the College Forward program in Texas. Community college student Nayeli Ramos is the lucky one: even though she was not able to successfully complete verification, she has been able to scrape together the funds to pay for college on an installment payment plan while she waits for her verification process to be completed. This is after driving nearly two hours to an IRS office when she was unable to obtain a tax transcript online, over the phone or through an appointment with her local IRS office, and then waiting four weeks for her college to process her paperwork -- only to be told there was a new problem. Some of her College Forward peers have not been so fortunate, unable to enroll because they could not afford college without the financial aid to which verification troubles denied them access.

Not enrolling in college because a student can’t complete verification is known as “verification melt,” and it’s no small problem. Just over half of all Pell-eligible students were selected for verification in 2016-17, and 44 percent of them never received a Pell Grant. That’s a tremendous number of students who are losing out on the aid that might give them chance at a college degree, and it’s especially shocking when you consider that among the other half of Pell-eligible students -- those who weren’t caught in the FAFSA verification trap -- 81 percent received Pell. So while some students may delay or skip college due to other factors, it’s clear that being selected for verification greatly lowers the chances that a student will get the federal aid for which they’re eligible.

So where does free college fit in? People may perceive that free college means a move away from the FAFSA, but for the statewide programs that exist today, that’s not the case. Many states with free-college programs require students to file a FAFSA because they only provide benefits after federal aid has been awarded. In other words, students have to complete this complicated federal paperwork before they can access their state’s free-college program. So if a student fails to complete verification, they miss out not only on the Pell Grant but also on the state’s free-college award, too.

Moreover, while the federal government hasn’t revealed its method for choosing which students to verify, the data show that the lowest-income students are the most likely to be affected. Low-income students are at a significant risk of being derailed by FAFSA verification, leaving them to cover the cost of tuition out of pocket or abandon their college dreams altogether, while higher-income students are rarely asked to jump through the same hoops. This deeply inequitable reality has huge implications for the employment prospects and lifetime earnings of these students, as well as for the economic mobility of Americans and the economic competitiveness of our nation.

In short, the FAFSA verification trap isn’t just bad for the students who get caught. It also works against the programs and policies that state and institutional leaders have established to expand access to higher education and the American dream.

So what do we do about it? First, it’s clear to anyone who’s filled out a FAFSA that the federal financial aid process is in desperate need of simplification, and that’s doubly true for verification. As higher education experts and advocates have long argued, the lowest-income students should not be forced to jump through hoops to prove they are poor. The federal government can start by cutting the number of data elements on the FAFSA, thus decreasing the number of items that need to be verified, and increasing the number of elements that are automatically transferred from already verified sources, like tax returns. It can further simplify the process for families receiving means-tested benefits by creating cross-agency agreements to automatically verify income information and eliminate the need to ask any additional questions. The FAFSA Act, for example, which the U.S. Senate passed by unanimous consent late last year, is a common-sense bill that represents a move in the right direction.

While some of these changes would require legislation, or the cooperation of other federal agencies, the Department of Education can also simplify the financial aid process on its own by taking the following actions:

  1. Reinstate the 30 percent cap, which limited the share of students at a given institution who had to go through verification.
  2. Create a single hub to centralize the verification process rather than requiring students to complete verification at every institution to which they applied, or standardize the notification and resolution process across institutions.
  3. Allow students to submit a tax return rather than a tax transcript to verify income data, reducing the burden for students as well as the IRS.

At the state level, lawmakers should provide flexibility for students who are delayed during the FAFSA process and find ways to support those who are unable to access federal aid, including students who are unable to complete FAFSA verification. At the same time, advocates, policy makers and educators across the United States should continue to produce and pursue big ideas for redesigning the college financing system and alleviating the burdens on students and families. Together, we can get students out of the FAFSA verification trap and ensure that the students with the most need have access to the support they require to make college a reality.

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