ED's Problems with FAFSA Timeline Started in 2021

Pretending that the initiative is or soon will be under control helps no one

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Two articles at Inside Higher Ed in the past few days start to describe what we have described on our podcast as an under-explored topic. Too many discussions about the FAFSA mess start with the recent problems over the past few months, but a cursory review shows that the timeline was broken in early 2021, just months after the bill authorizing the initiative was signed into law.

Last week’s article showed that the impact of the FAFSA rollout could be bigger than that from Covid.

Nashville is no outlier. As of March 22, only 33.7 percent of high school seniors had completed a FAFSA, down 28.8 percent from last year, according to data from the National College Attainment Network (NCAN), which has been tracking completion rates throughout this tumultuous financial aid cycle. The network estimates that at the going rate, about half a million fewer students in the class of 2024 will submit a FAFSA compared to last year.

And that’s probably an optimistic estimate, said Bill DeBaun, NCAN’s senior director of data and strategic initiatives; if the pace of completion doesn’t pick up, the decline could be closer to 700,000 students. That could translate to up to a 4 percent drop in college-goers come fall, DeBaun said, which would be the largest enrollment drop since the COVID-19 pandemic—and one that’s likely to be made up primarily of low-income and first-generation students.

But the problem runs deeper.

[President of the National Association of College Admissions Counselors] Perez said the completion crisis could have as serious an impact on higher ed enrollments—and colleges’ finances—as the pandemic did.

“It’s just as bad as Covid,” Perez said. “Maybe worse. Because the difference between Covid and now is, there was an influx of funding to offset the impact of the pandemic. I’m not seeing any talk about that now.”

Today’s article showed the impact on higher education institutions - not just with enrollment, but in trust and credibility with the US Department of Education (ED).

Barnett, like others, said the department’s communications through the FAFSA roll-out have made the situation seem rosier than the reality, which has also undermined trust. Transparency and helpful solutions would be better, he said. “And work on solutions that we feel are really within the letter of the way that financial aid rules were intended to be,” he added.

For these reasons, we plan to expand our coverage at On EdTech to include the FAFSA rollout and its likely implications. Unfortunately, it is impossible to understand what is and will be happening in EdTech and related fields without dealing with the driving issue that the FAFSA fiasco is becoming.

Problems Didn’t Start in the Fall

There tends to be an oversimplified description of the FAFSA Simplification delays starting in the fall of 2023. That is when the new FAFSA form was not available to prospective students as in a typical year (October 1st), but the issues around expected completion of the initiative started far earlier. This is important in terms of forecasting how likely it is that the ongoing processing errors for federal financial aid will be resolved soon.

This is an initiative that had no solid plan from the moment it started. To get started with our analysis, let’s look at a historical timeline showing the initiation of the new FAFSA initiative and the key moments when dates have changed. Normally FAFSA forms are available October 1 of each academic year, and data is submitted back from ED to the institutions that each student is applying to by January 31, leading to award letters and decision dates typically on May 1.

For the following view, the three primary sources (and in particular, by following the references and links of each) are:

Visualizing the Timeline

Virtually from Day 1, the schedule was unrealistic. In early 2021, ED staff chose to redesign the entire system rather than update the application form and underlying formulas, as assumed by legislators. Further, ED asked for half of the project extension that staff said they needed, according to the Washington Post.

Staffers said they tried to convince senior officials of the need for more time to complete the technology upgrades necessary to finish the new financial aid application. The student aid office wanted two extra years. Department officials asked Congress for one.

Lawmakers granted the request in June 2021 after learning for the first time that the department was remodeling the entire FAFSA system infrastructure, said McKibben, now the senior director of policy and advocacy at the Hope Center at Temple University.

By 2022, with the primary contract in place, ED continued to publicly stick with the new October 2023 completion date estimate despite staff’s earlier requests and despite a lack of additional funding. By February 2023, it was obvious that the 2024-25 award year was in jeopardy.

Hopefully this view helps readers to orient where we are in this important, developing story. At the very least, it helps me keep track of so much coverage over the past year.


Note that this high-level view does not include most of the myriad errors and recalculations that are currently causing such confusion.

This initiative was never under control and well-planned, as described in the GAO report [emphasis added].

With regard to the schedule, GAO found that project officials developed a schedule for AED and kept it updated. However, the officials did not document the assumptions, such as resource availability, that informed the schedule. In addition, the schedule did not provide rationales for constraints that limit the movement of activities. For example, the AED schedule did not identify the rationales for why 43 activities could not start any earlier than a specific date. These gaps limit the reliability of the schedule.

Developing a life cycle cost estimate to inform the budget and establishing a reliable schedule are critical steps to ensuring the project does not overrun costs or delay the schedule. Until project officials take these steps, the project is at risk of cost increases and schedule delays.

I do not believe that either of these steps has been taken, and the key point is that even today, we are likely to see even more schedule delays.

In US higher education, the impact of the FAFSA fiasco could become the defining story at least for the 2024-25 academic year, and possibly into future years.

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