1
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Q.45j “Money received, or paid
on your behalf (e.g., bills), not reported elsewhere on this
form. This includes money that you received from a non-custodial
parent whose information is
not reported on this form
that is not part of a legal child support agreement. See Notes
page 2.”
By
expanding the scope to include any parent whose information is
not reported on the FAFSA, this question would encompass
financial support from parents given to independent students,
which should also be included.
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Resolved
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Question 45j will be revised to read:
“Money received, or paid on your behalf (e.g., bills), not
reported elsewhere on this form. This includes money that you
received from a parent whose financial information is not
reported on this form and that is not part of a legal child
support agreement. See Notes page 2.”
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2
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The question about having a bachelors
degree before July 1, 2014, is too vague and then also too
specific.
The question says "Will you have your
first bachelors degree". I think it should read "Will
you have completed your first bachelors degree". Then it
gives a date of July 1st, 2014. But many schools have summer
semesters that a student could be completing their Bachelors
requirements in, and have a bachelors degree completed before the
new school year begins. Shouldn't it say prior to the start of
the 2014-15 school year? So, all in all, my thought is that the
question should read:
"Will you have completed
your first Bachelors degree prior to the start of the 2014-2015
school year?" Then in the instructions, tell the student
that they should contact the school for that student's start date
for the school year.
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Resolved.
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FAFSA on the Web Help text will be
updated to clarify this information for applicants. The FAFSA on
the Web Help topic “Am I eligible to receive financial
aid?” will read:
“Many
types of federal student aid, such as the Federal Pell Grant or
subsidized loans where the government pays the interest while you
are in college, also require you to have financial need.
Additionally, once you have a bachelor’s degree or a first
professional degree, you are generally not eligible for Pell or
Federal Supplemental Educational Opportunity Grants (FSEOG).
Other requirements may apply.
Contact the financial aid office at your college for more
information.”
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3
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Regarding Revised the "Notes for
questions 42 and 43 (page 4), 45j (page 5), and 91 and 92 (page
7)," it states, "Investments include real estate (do
not include the home you live in), rental property . . ."
To
avoid a hanging participle, I would suggest you change the
wording, "do not include the home you live in" to "do
not include the home in which you live."
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Resolved.
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The Notes for questions 42 and 43
(page 4), 45j (page 5), and 91 and 92 (page 7) will be revised to
read: “Investments
include real estate (do
not include the home in which you live), rental property
(includes a unit within a family home that has its own entrance,
kitchen, and bath rented to someone other than a family member),
trust funds, UGMA and UTMA accounts, money market funds, mutual
funds, certificates of deposit, stocks, stock options, bonds,
other securities, installment and land sale contracts (including
mortgages held), commodities, etc.”
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4
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In FAFSA instruction "Notes for
Step Four, Questions 59-64....", the first bullet note
should be changed as needed to ensure proper context around the
topics involved.
Current
wording: "If your parent was never married or is widowed and
does not live with your other legal parent, answer the questions
about that parent."
Suggested
wording: "If your parent was never married and does not live
with your other legal parent, or if your parent is widowed and
not remarried, answer the question about that parent."
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Resolved.
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The first bullet under the Notes for
Step Four, Questions 59-94 (pages 6 and 7) will be revised to
read: "If your parent was never married and does not live
with your other legal parent, or if your parent is widowed and
not remarried, answer the question about that parent."
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5
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I believe that there needs to be a
clarification in the FAFSA with respect to question 59 (parent's
marital status). According to Dear Colleague letter GEN-13-12,
dependent students whose biological parents live together are
required to include both parent’s information regardless of
marital status. Every year, we get a number of students whose
parents are either divorced or legally separated that still live
together. It’s clear that if the parents are divorced, yet
still live in the same household, they should file with the new
“Unmarried and both parents living together” status,
as the instructions explicitly point out. However, it’s not
at all clear what they should do if they are legally separated,
but still live in the same household. Using the new status
wouldn’t be correct, as they are still married, but if they
choose the “separated/divorced” category, then only 1
parent’s information will be accepted by the FAFSA on the
Web logic. Married would seem to be the most correct choice, but
the way the choices are labeled, and the way the instructions are
worded, I don't believe most people in this situation would use
this. I believe that it would be clearer to include a sentence in
the "Married" section of the instructions to indicate
that persons in this situation should use this category, such as:
"If your legal parents are legally separated but living
together, select “Married”, not "Divorced or
Separated".
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Resolved.
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The third bullet under the Notes for
Step Four, Questions 59-94 (pages 6 and 7), will be revised to
read: “If your parents are married, select “Married
or remarried.” Consistent with the Supreme Court decision
holding Section 3 of the Defense of Marriage Act (DOMA)
unconstitutional, same-sex couples must report their marital
status as married if they were legally married in a state or
other jurisdiction (foreign country) that permits same-sex
marriage, without regard to where the couple resides. If your
legal parents are divorced but living together, select “Unmarried
and both parents living together.” If your legal parents
are separated but living together, select “Married or
remarried,” not “Divorced or separated.”
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6
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There should be notes/additional
clarification for questions #74 and #96 (reporting the number of
family members in college), to state that certain military
academies as well as certain foreign colleges and universities
should not be included. Ideally, families should be be provided a
link to the list of eligible Title IV institutions that may be
counted.
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Resolved.
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FAFSA on the Web help text will be
revised for both the parent and the student to include this
information.
The
parent help topic will read: “Enter the number of people
in your parents’ household who will attend college between
July 1, 2014 and June 30, 2015.
Include:
•Yourself,
even if you will attend college less than half-time in 2014-2015.
•Other
people in your parents’ household only if they will attend
college at least half-time in 2014-2015, in a program that leads
to a college degree or certificate.
Do
not include:
•Your
parents, even if they are enrolled at least half-time in
2014-2015 in a program leading to a degree or a certificate.
•Students
at a U.S. service academy, because most of their primary
educational expenses are paid for by the federal government.”
The
student help topic will read: “You must enter the number
of people in your household who will attend college between July
1, 2014 and June 30, 2015.
Include:
•Yourself
even if you will attend college less than half-time in 2014-2015.
•Other
people in your household only if they will attend college at
least half time in 2014-2015, in a program that leads to a
college degree or certificate.
Do
not include:
•Students at a U.S. service
academy, because most of their primary educational expenses are
paid for by the federal government.”
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7
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Question 28 poses a problem with
students earning their bachelor's degree in the Fall. The
question asks the student if they will earn a bachelor's before
July 1, 2014, but makes no consideration that the student could
get their bachelor's just afterwards like in December. Unless the
transcripts are submitted a student who answers the question
correctly but earns their degree in the Fall and transfers to
another school to earn some additional credit would be
incorrectly paid pell. Could the question be worded differently
or could there be a way for schools to know when a student has
earned a bachelor's degree through the clearing house and on the
ISIR?
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Resolved.
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Refer
to comment #2 for resolution.
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8
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We recommend changing this sentence
in the Notes for Step Four section at the top of page 9:
Current
wording: Additional instructions about who is considered a
parent on this form:
Proposed
wording: Review all instructions below to determine who is
considered a parent on this form.
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Resolved.
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The paper FAFSA will be updated to
reflect this change.
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9
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a. Item # 31. on the FAFSA, I would
like to suggest that you add the work "employment"
after work-study. We believe this may assist in students
understanding that they are to work for this funding.
b.
For items #80 thru # 83, would it be helpful or necessary to
indicate parent 1 and parent 2 given the new inclusion of
unmarried parents. Also, will it make a difference as to the
order that they complete the answer, if there are two parents for
any verification documentation requested/submitted.
c.
Items #24 and 25, is this impacted by the new parent category?
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a. Resolved.
No
Change.
b.
Resolved.
No
Change.
c.
Resolved.
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a. This is a stylistic preference
that would make the question redundant. The word “work”
already indicates a form of employment.
b. Only
questions 24, 25, 61-68, 88 and 89 are specific to one parent,
and question labels were updated to reflect Parent 1 or Parent 2.
All other parent questions apply to one parent or two parents as
determined by question 59. The Department of Education believes
that to include references to Parent 1 and Parent 2 in questions
that didn’t previously reference mother or father would add
undue burden and decrease readability.
c. FAFSA question numbers 24 and
25 are impacted by the category and have been updated to read
“Highest school completed by Parent 1” and “Highest
school completed by Parent 2”.
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10
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We recommend the following revisions
to Step Four of the paper FAFSA:
a.
At the top of page 6, after the sentence that reads “Complete
this step if you (the student) answered “No” to all
questions in Step Three”, we recommend adding this
sentence: IMPORTANT - Before you continue, review all Notes on
page 9 to determine who is considered a parent on this form.
b.
Errors in answering questions 80-94 when a student’s
parents are “Unmarried and both parents living together”
may be highly likely. Therefore, we recommend bolding (in
addition to highlighting) the following sentence which
immediately precedes question 80 on page 6 to emphasize the need
to seek assistance: If your answer to question 59 was “Unmarried
and both parents living together,” contact 1-800-4-FED-AID
for assistance in answering questions 80-94.
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a. Resolved.
No
Change.
b. Resolved.
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a. The Department of Education
believes that this is repetitive. The current language reads: If
your parent was never married, widowed, divorced, separated or
remarried, see the Notes on page 9 for additional instructions.
b. The text will be bolded as
recommended.
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11
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Q.26 General Educational Development
(GED) certificate or state equivalent test.
Students
may not know what constitutes a state equivalent test in their
state. We recommend further instructions directing them to this
information.
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Forwarded to Appropriate Business
Unit
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The Department has referred this
suggestion to the appropriate business unit to review
recommendations.
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12
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I was recently informed by a
counselor that colleges use the FAFSA to deny students admission
or limit financial aid. The counselor received this information
from this article:
http://www.insidehighered.com/news/2013/10/28/colleges-use-fafsa-information-reject-students-and-potentially-lower-financial-aid
.
Is it possible to deny colleges and universities
access to the other colleges students list on their FAFSA?
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Forwarded to Appropriate Business
Unit
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The Department has referred this
suggestion to the appropriate business unit to review
recommendations.
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13
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The new answer option on parent
marital status of “unmarried and both parents living
together” should also be asked of the student’s
marital status. It seems unfair that only dependent parents get
put into this group while independent students do not.
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Resolved.
No Change.
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The family contribution for a
dependent student is defined in Section 475 of the Higher
Education Act, as amended. For each student, the expected family
contribution is equal to the parents’ contribution and
throughout this section, the parents are referenced without
regard to their marital status. It is the relationship of the
dependent student to the parents and not the marital status that
is significant.
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14
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Student 4. (Parent
Instructions)
Answer all the questions in Step Four even if
you do not live with your legal parents (your biological and/or
adoptive parents). Grandparents, foster parents, legal guardians,
aunts and uncles, or other people are not considered parents on
this form unless they have legally adopted you. If your legal
parents are married to each other or are not married to each
other and live together, answer the questions about both of them.
If you parent was never married or is remarried, divorced,
separated or widowed, see Notes page 9 for additional
instructions.
Added text expands the scope of who is
not considered a parent so the instructions aren’t
misinterpreted as allowing people other than those specifically
listed to be considered a parent in the absence of legal
adoption.
These
instructions also preclude same-sex stepparents who are legally
married to an applicant’s legal parent, but who have not
adopted the student, from being included on the FAFSA. Without
DOMA guidance from ED, we are unable to determine if this was the
intent.
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Resolved.
No Change.
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The third bullet under the Notes for
Step Four, questions 59-94 (pages 6 and 7) state: “If your
parents are married, select “Married or remarried.”
Consistent with the Supreme Court decision holding Section 3 of
the Defense of Marriage Act (DOMA) unconstitutional, same-sex
couples must report their marital status as married if they were
legally married in a state or other jurisdiction (foreign
country) that permits same-sex marriage, without regard to where
the couple resides. If your legal parents are divorced but living
together, select “Unmarried and both parents living
together.” If your legal parents are separated but living
together, select “Married or remarried,” not
“Divorced or separated.”
When the reported marital status
is “Married or remarried,” information for both the
parent and the stepparent must be reported.
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15
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Question 16 on the FAFSA for 14-15.
Maritial Status. The instructions do cover the DOMA act. However,
there is no instructions regarding people who may not be married
but live together. There was an earlier notice that stated people
who live together as the parent and/or student who are
contributing to the household income should be included on the
FAFSA. So, if, for example, two parents live together but not
married and you want both incomes included on the FAFSA, wouldn't
you add that in this section so we can catch in the verification
process that they live together we will need both Tax
transcripts. Otherwise, we would have no way of knowing this.
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Resolved.
No Change
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Question 16 is specific to the
student applicant and not the parents. There is no response
option of “Unmarried and living together” for the
student; this response option exists only for the parent. There
is specific guidance contained in bullet 2 under the “Notes
for Step Four, questions 59-94 (pages 6 and 7)” on the
paper FAFSA for parents who are unmarried and living together.
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16
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Could suffix be a separate field
instead of included in the last name? This will help match ISIRs
with data in enterprise systems.
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Resolved.
No Change.
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Spacing limitations prevent this from
being included on the paper FAFSA. Each year, third party
software providers are given Federal Student Aid (FSA)
specifications for Institutional Student Information Record
(ISIR) processing.
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17
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Instructions for 80-94
If your
answer to question 59 was “Unmarried and both parents
living together,” contact 1-800-4-FED-AID for assistance
with answering questions 80-94.
Clear instructions
should be provided on how to answer questions 80-94 and then if
students need assistance, they can be directed to contact
1-800-4-FED-AID. Referring all affected students to
1-800-4-FED-AID upfront automatically adds another step for
affected applicants and precludes financial aid administrators
and other advisors from properly counseling applicants, since
they don’t know what the guidance from 1-800-4-FED-AID will
be or if it’s accurate.
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Resolved.
No Change.
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The current FAFSA instructions for
parents who are unmarried and living together state: “If
your legal parents (biological and/or adoptive) are not married
to each other and live together, select “Unmarried and both
parents living together” and provide information about both
of them
regardless
of their gender. Do not include any person who is not married to
your parent and who is not a legal or biological parent.
Contact
1-800-4-FED-AID for assistance in completing questions
80-94.”
The instructions direct applicants
to include both legal parents who are not married to each other,
and to select “Unmarried and both parents living together”.
The statement to contact 800-4-FED-AID was added to assist in
case applicants have additional questions.
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18
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We recommend the following revision
to question 26 on page 3 of the paper FAFSA:
Immediately
following the question, "When you begin college in the
2014-2015 school year, what will be your high school completion
status?", add in parentheses (“None of the above”
means you do not have a high school diploma, GED, or equivalent
and did not complete secondary school in a home school setting.)
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Resolved.
No Change.
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This is a stylistic preference that
would make the response redundant.
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19
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Based on DCL ID: GEN-13-16 Subject:
2014-2015 Award Year: FAFSA Information to be Verified and
Acceptable Documentation, and “Nontax filers-If an
institution questions a claim that the tax filer has not, will
not, and is not required to file a 2013 Internal Revenue Service
(IRS) income tax return, the institution must require the
applicant to submit a “Verification of Nonfiling”
from the IRS that the tax filer did not file a 2013 IRS income
tax return. The request for “Verification of Nonfiling”
can be obtained by the tax filer using IRS Form 4506-T and
checking box 7. IMPORTANT: According to the IRS, a response to
the request for a “Verification of Nonfiling” for the
2013 tax year will not be issued until after June 15, 2014.”
In light of the length of time that it will take in cases where
the institution needs the Verification of Nonfiling, it would be
beneficial to the student and the institution if the IRS DRT
could include an additional flag to indicate verified non-filer
status. This may only be possible after the normal tax filing
deadline of 4/15/2014, but would be a valuable addition.
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Resolved. No change.
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The IRS Data Retrieval Tool does not
currently include non-tax filer information, and to explore the
possibility of obtaining this information would be a
collaborative effort between the IRS and the Department of
Education. The Department will have conversations to explore
this issue.
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