SEPTEMBER 26, 2013

Fearing the Federal FAFSA Form:
The U.S. government's financial aid application process was
designed for traditional families. How do New York City's
unconventional families manage?

For students who manage to get through the college application process, the government's Free Application for Federal Student Aid, or FAFSA as it is better known, is the next--and, for many, the biggest--stumbling block. For some students, it's simply insurmountable.

Take the case of a young woman who graduated from the Brooklyn School for Collaborative Studies a few years ago. At the time, she was living with her aunt in New York. But FAFSA required information about the income of her father, who lived in Jamaica. "Because of the distance, she couldn't get any of his documentation," recalls Joshua Steckel, who had joined the school as a college counselor late in the FAFSA process. The alternative would have been to establish the young woman's independence by proving that the family had been dissolved. But obtaining a "dependency override" can be time consuming, and by that point the school year was drawing to a close. "It didn't work," laments Steckel. The last he heard, she never enrolled in college.

The student's struggles are a worst-case scenario for what can happen when the constraints of FAFSA run up against the complexities of the lives of New York City public school students, many of whom live in nontraditional families with ever-changing housing and custody arrangements. Many students feel overwhelmed by the form, which includes questions about household finances, a sensitive subject for most families. Even reporting the number of people in the household--a factor that affects the amount of money a family is expected to contribute to tuition--can be complicated when there are step- and half-siblings, and living arrangements are fluid. Counselors often have a difficult time assembling all the data that must be entered and keeping up-to-date with changing requirements and deadlines. In fact, there's so much confusion and anxiety about the form that it's easy to see how some students and their parents get beguiled into going online and paying $80 to a private service to complete what is explicitly a "Free" Application for Federal Student Aid.

Nonetheless, the FAFSA is a critical document. It is the main application that colleges and universities in the United States use to determine a student's EFC (Expected Family Contribution) and, on that basis, how much should be awarded in grants, work-study funds and loans. For New York residents attending school in-state, it is also the form that must be completed to get access to TAP (New York State's Tuition Assistance Program). And it is a necessary first step for students who are applying to the "opportunity" programs at CUNY (SEEK and CD, or College Discovery), SUNY (EOP, Educational Opportunity Program) and New York State's private schools (HEOP, Higher Education Opportunity Program), which provide financial aid to academically and economically disadvantaged students who might otherwise be denied admission.

In fact, the FAFSA is both a vehicle that enables students to attend college and a predictor of whether or not they will attend. According to the U.S. Department of Education (U.S. DOE), research indicates that 90 percent of those who complete the form will enter college. On the other hand, anecdotal evidence suggests that many high school graduates are so daunted by the FAFSA that they even give up applying to college. College financial aid expert Mark Kantrowitz has estimated that in 2007-08, students in New York State who would have qualified for a needs-based Pell Grant but did not file the FAFSA left the equivalent of about $300 million on the table. Nationally, nearly onequarter of the 6.5 million students eligible for Pell Grants failed to apply for the money, according to recent government figures.

FAFSA DESIGNED FOR TRADITIONAL FAMILIES

Why would students--least of all those who really needs the funds--let that kind of money slip through their hands? There are many reasons, starting, literally, with the first line of the form. Students must enter their names exactly as it appears on their Social Security card or FAFSA will send them a message that their application cannot be processed until the discrepancy is corrected. The Social Security number is itself an important issue.

If students are undocumented, they won't have a valid Social Security number. They cannot and should not apply for federal aid. Yet colleges may still want these students to complete and submit a paper version to the college directly, so these students can apply for private aid.

If the student is here legally but his parents are not, the parent can sign a signature page and mail it in. While the U.S. DOE maintains that their identities will be protected, many undocumented people are understandably afraid that immigration officials might be alerted.

However, the two most problematic areas of the form, particularly for many New York City public school students, concern the often interconnected issues of household income and dependency. For a start, "the most basic problem is getting hold of tax forms," says Jeanine Boulay, a college counselor at High School of Telecommunication Arts and Technology in Brooklyn. "A lot of families are reluctant to release them, or are reluctant to give us their Social Security number, even if they're legal, so we'll sometimes have to send emails to parents or talk on the phone and tell them it is secure information. We have very complicated situations, noncustodial parents, where, for example, the student lives with the grandmother and has no interaction with either parent. I often have to remind students and parents that, just because the parent provides financial information, it doesn't mean they're responsible."

The FAFSA form "is written for traditional families, and so many of our families don't fit into those little boxes," notes Cassie Magesis, who counseled students directly and trained counselors for years at Options Center at Goddard Riverside Community Center. She is now at Urban Assembly, a NYC school support organization.

Applicants, for instance, are required to report the income only of "parents," defined as biological parents, legally adoptive parents, or stepparents. A peculiarity of FAFSA is that it cares only about the student's custodial parents, so if the parents are divorced or separated and the student lives with his mother, it's the mother's income that gets reported even if the father, say, claims the child as a dependent. Curiously, this can actually work to the student's advantage, as Dzelika Daniel, an associate director of student financial aid at CUNY, points out, because the smaller income may be used to calculate Expected Family Contribution. The situation gets muddier when it involves a child of samesex parents. Because the federal government doesn't recognize same-sex marriage, the student must fill out the FAFSA as if his parents were divorced even when they live together, and follow a maze of other rules regarding additional support and family members.

Students who are orphans, in foster care or homeless are automatically considered independent (although they may need documentation from a caseworker). The situation is more complicated for a student who is living with a grandparent, sibling, aunt or uncle, or family friends. In such cases, the student may apply for a dependency override, which may require multiple visits to the NYC Administration for Children's Services (which places children in and out of foster care) or other bureaucracies. And the student is still expected to report parental income, even when the parent is estranged, lives in another country or is serving time in jail. What's more, any money received from any source other than a parent must be reported as income and may reduce a student's eligibility for aid.


TAX CALENDAR OFTEN REQUIRES FAMILIES TO FILE TWICE

In recent years, it's become possible to "link" the online FAFSA to the latest tax return, a step designed to simplify the process and ensure that applicants' answers are honest (or, at least, conform to what they've told the IRS). But there's a crucial disconnect: Students are urged to submit their FAFSA as early as possible--preferably by February 1--to have a better shot at getting college scholarships. However, many people won't have filed their taxes by that time. "It's an unnatural calendar," says Steckel. "The FAFSA and myriad other forms from more selective colleges are asking for the current year's tax returns, but taxes aren't due until April 15. So for families, it's pretty confusing."

Many applicants simply estimate their previous year's income, hit "send" and think their task is complete. If they have reported a very low household income, they may even be overjoyed to get a message from FAFSA estimating their Expected Family Contribution at zero. "What happens is, once you submit it, you get a message, 'Congratulations, you've completed the FAFSA,'" says Omar Morris, a longtime college and career pathways program officer for New Visions, a NYC school support organization, who is now at CollegeBound Initiative. "We'll say to the student, 'You have to go back in and update it.' And that's a problem."

For a great many students, that is where the process breaks down. FAFSA typically communicates with the student through emails, an obsolete medium for large numbers of young people who prefer texting and Facebook. As a result, reminders that their FAFSA is still incomplete--that, for example, it must be linked to the last year's tax return, or that other information is missing--often go overlooked. "We lose a lot of kids to red tape, especially the CUNY-bound, during the summer," says Bouley of Telecommunication High School. One summer she contacted students to check on their registration status, but "I didn't have a very good response. I don't think they check their email." Now, she says, the school is trying to work through Facebook.

One program that could help prevent this breakdown is being piloted by the U.S. Department of Education in about 20 school districts across the country, including New York City. Each district sends the U.S. DOE a list of its 12th-grade students, and the U.S. DOE tells the district--which, in turn, tells the individual schools--whether those students have completed their FAFSA application, have started but not yet completed it or haven't even started it.

Potentially, it's a great tool for counselors who are struggling to keep track of all the moving parts but are out of the loop because FAFSA communicates with the students directly. Still, many counselors express reservations because they're afraid that it will eventually be used as an accountability tool--a way to hold guidance counselors accountable for the quality of college hand-holding they do. Other counselors wonder how they will fit quality FAFSA advisement into their already crowded schedules. "I was shocked at the level of hesitancy among the counselors," says Magesis. "I think it's because of the fear that this will be a metric added to the [city's] report card." Officials in New York City, however, maintain that there are no plans to use FAFSA completion numbers in the all-important Progress Report. They say the data has too many limitations at this point to be a useful accountability tool.


LOW-INCOME STUDENTS MUST DEAL WITH "VERIFICATION"

All of this is unfortunate, as students who fail to complete their forms properly are much likelier to be flagged for a process called "verification." In the past, the U.S. government required colleges to verify about one in three FAFSA applications. While this requirement has recently been abandoned, the government will likely seek to verify the application of any student who fails to "link" to his parents' tax return. And college financial aid officers may also seek verification independently if they find discrepancies or inconsistencies on a student's FAFSA, such as the number of people in the home.

Some CUNY administrators and New York City counselors assert that, in their experience, most students can expect to be verified. "Every student I've ever worked with in the South Bronx over the course of eight years has been called in for verification," says Dion Reed, a manager at CollegeBound Initiative, a program of the Young Women's Leadership Network that promotes college access for urban youth. And at the Borough of Manhattan Community College, says CUNY's Daniel, "it seems like over 50 percent get selected." Reed thinks the high rate is due to the large number of FAFSAs on which the Expected Family Contribution is zero; Daniel suggests that, given the number of applicants from the city's public schools, the forms are more likely to be chosen because they're incomplete, contain errors or raise flags on issues like income supplements.

Either way, verification represents another potential stumbling block for the would-be college freshman. The process can be relatively perfunctory--requiring the presentation of documentation to confirm date of birth or citizenship, for example--or as rigorous as an IRS audit. Students may be required to prove other sources of untaxed income, such as public assistance and food stamps. And, starting this year, students who are unable to electronically "link" to their parents' tax return will be required to get a transcript of that return from the IRS. (In the past, colleges were allowed to accept a photocopy of the return, but the U.S. DOE stiffened regulations to minimize the chance of fraud.) There are only a handful of cases where it's impossible to electronically link--for example, an amended tax return or one filed from Puerto Rico--but in those instances the process will become more complicated. The person who filed the tax return--typically, the parent, not the student--will have to contact the IRS; the return will be mailed to his address, and the student must then bring it to the college's financial aid office. "Everyone in the community, ourselves included and the colleges, are waiting to see how this will play out," says Urban Assembly's Magesis.

On the plus side, there can be a lot of flexibility in meeting the FAFSA deadline. Students can complete their FAFSA form a month before classes begin, although CUNY's Daniel cautions that a down-to-the wire application can delay funding for months. That means the student will have to meet tuition and other education expenses out-of-pocket. In general, the later the application is received, the harder it becomes to get scholarships or campus-based grants, as that money depletes quickly. But some schools are more forgiving than others. Robert Gevertzman, who works in Kingsborough Community College's financial aid office, notes that some students stroll in after the semester has begun to complain that they're being billed by the bursar because they never filed a FAFSA or filed it late. "We don't want to turn students away," says Gevertzman. "We can plug the system for a month until they bring in their documents. I tell the student, ‘This is play money. You've got to bring in your documents in a few weeks. After that, you'll owe the whole balance.'"

Annoying as it can be, it's arguable that the FAFSA is not overwhelming when it is being completed as it was designed to be--by the parents of a high school senior. But increasingly, in New York City, that doesn't happen. "If you look at our kind of low-income first-generation students, I would say probably 80 to 90 percent of them do everything themselves," says Ritu Sen, director of college readiness at Urban Assembly. "Our kids, the really high-achieving ones, are totally doing everything themselves. They're translating for their parents, they're figuring out ways to get their hands on the tax returns when their parents might not want to release them. And even in the model family, where they're really supportive but maybe not college-educated, the parents help, but I think that the kid is ultimately the one who ends up being responsible for completing the FAFSA."

In many cases, that kid turns for help to a guidance counselor. And the counselor--who is still busy pushing seniors through the college application process, helping juniors start the process and probably devoting half of his or her time to teaching or to other areas unrelated to college admissions--may be ill-prepared, unable or unwilling to provide this complicated and time-consuming level of support.

"There are a lot of guidance counselors who still believe that the financial aid piece is not their responsibility," says Morris. He attributes that attitude to counselors' own experiences as college applicants: While their own guidance counselors helped them through the college process, the financial aid application was traditionally viewed as the parents' job since many families do not want to share their financial information with school employees.

But FAFSA isn't going to go away. If anything, students' need for financial support will only continue to grow. What, then, is the best way to tackle it? Most college counselors interviewed maintain that the complicated cases need one-on-one hand-holding--and the city needs to allocate time or money to do that work well. "There's the 'workshop approach' and there's the 'parent night approach' and there's the 'single-serving, come in and sit down and get it done and go home approach,'" says Dion Reed. "Given our demographics, the single best solution is to put ownership of the process in the hands of one individual who has the resources and time to allot to it. All those other options are a lot more cost-effective and manageable. But with all of the pitfalls that can befall students who lack the confidence, or the know-how, or the support networks to get from point A to point B, it doesn't really happen unless someone is there to help them."

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