Executive Summary

Nearly a decade ago, Louisiana launched a novel experiment to increase college access by requiring its public high school seniors to either apply for financial aid or expressly opt out. Today, 44 percent of public high school seniors are enrolled in a state with a similar policy, intended to increase the number of students who access financial aid through the Free Application for Federal Student Aid (FAFSA).

States often deploy new policies in the hopes of changing student outcomes. Such change is usually slow, but not so with FAFSA mandates: most of the states enacting mandatory FAFSA policies saw immediate impact, with three in seven states in their first year of implementation chalking up year-over-year increases of more than 23 percent in the number of public high school seniors who complete the form.

In 2020, The Century Foundation (TCF) found that Louisiana’s increase in FAFSA completions closed the gap between high-income school districts and low-income school districts.1 Today, half a dozen more states—Alabama, California, Illinois, Indiana, New Hampshire, and Texas—have now implemented some form of a mandatory FAFSA policy that has been in effect for a year or longer, allowing for comparisons across a wider array of states.2 Do the trends observed in Louisiana extend to these other states?

This report updates TCF’s prior research to guide policymakers in states considering adopting a mandatory FAFSA policy as well as states that have already implemented one. Data from the seven states that have implemented a mandatory FAFSA policy for the Class of 2024 or earlier indicates that:

  • All seven states outperformed the rest of the country in terms of year-over-year change in public high school FAFSA completions for the year examined: the median state, Illinois, outperformed the rest of the country by 10.6 percentage points. Across these seven states, this translates to 86,700 new FAFSA completions over expectation in one year.
  • In five of the seven states, the FAFSA completion gap between high- and low-income districts narrowed after the policy’s implementation, and in Texas, low-income districts took the lead.
  • In four of the five states for which data is available, increases in the number of Pell Grant recipients outperformed increases in the rest of the country. Across these five states, this translates to 27,500 new annual Pell Grant recipients over expectation in one year.
  • In three of the five states for which data is available, increases in first-time undergraduate enrollment (that is, freshman) outperformed increases in the rest of the country. Across these five states, this translates to 21,900 new annual first-time undergraduates over expectation in one year.

Table 1, below, highlights how each of these states immediately overperformed relative to what would be expected based on national trends. In the first year after implementation, every state overperformed in terms of its public high school FAFSA completions, and most also overperformed in terms of Pell Grant recipients and first-time undergraduates.

Table 1: Public High School FAFSA Completions, Pell Grant Recipients, and First-Time Undergraduates Over Expectation in First Year of Policy
State First high school class  Public high school FAFSA completions over expectation Pell Grant recipients over expectation First-time undergraduates over expectation
Louisiana Class of 2018 5,917 7,075 1,453
Illinois Class of 2021 9,312 4,601 3,261
Alabama Class of 2022 4,561 –186 –607
Texas Class of 2022 40,763 7,631 –1,452
California Class of 2023 22,401 8,379 19,244
Indiana Class of 2024 3,650 Data not yet available Data not yet available
New Hampshire Class of 2024 106 Data not yet available Data not yet available
Total Various years 86,711 27,500 21,899
Source: Author’s analysis of datasets from the Federal Student Aid Data Center and Integrated Postsecondary Education Data System (IPEDS). See Tables A1 to A9, D1a, and E1 in Appendix 1.  

These findings are encouraging for states and families who see college as a path to greater opportunity, though challenges remain in building and maintaining buy-in from key stakeholders. Administrators in states with an active policy frequently cite the challenge of juggling increased demand for FAFSA form completion assistance that comes with mandatory FAFSA policies with students’ other needs.3 Last spring, lawmakers in Louisiana and New Hampshire repealed their state’s policies, citing concerns such as privacy and the role of graduation requirements.

Across states with mandatory FAFSA policies, legislation is often similar but implementation varies significantly. It is not enough to pass a new graduation requirement without also deploying additional resources to help students fill out the form, and ideally, also provide additional resources to help students navigate the college application and enrollment process. This report highlights successful efforts in California and Illinois to bring direct support to schools, drawing from interviews with stakeholders in these two states. Other states can follow their example to ensure that high-need communities receive sufficient assistance with the form—and, more broadly, the college application and enrollment process.

Clear communication to schools and families is vital, especially under the specter of deportation threats. Analysis for this report estimates that half a million high school seniors would likely need a noncitizen family member to submit information, if they decided to complete the FAFSA. As this report discusses in-depth, states must be conscientious of the high stakes for families and enable them to make informed decisions.

A state’s mandatory FAFSA law, which turns the FAFSA into an opt-out process instead of an opt-in one, can generate conversations about pursuing higher education that may not have happened otherwise and therefore help a student along the path to college. Higher education is plagued by information asymmetry: families whose members would benefit from attending college the most also struggle the most in navigating the complex process of obtaining aid. After several years, evidence is mounting that mandatory FAFSA policies can help close crucial information gaps, increasing enrollment and take-up of financial aid.

Introduction: A Growing Movement

Most families depend on financial aid to afford college, and access to federal, state, and institutional financial aid largely runs through the Free Application for Federal Student Aid (FAFSA). Yet every year, barely half of high school students complete the FAFSA before they graduate, meaning nearly half of seniors exit without knowing how much financial aid they qualify for.4 While a person can take a break from school and apply for financial aid later, long-term outcomes in education and earnings favor those who enroll in college right after high school.5

Recognizing the strong association between a community’s education attainment levels and economic prosperity, state and local leaders have tried many strategies to boost FAFSA completion for their students.6 Starting with its Class of 2018, Louisiana adopted a novel approach to promoting FAFSA completion: as a graduation requirement, Louisiana public high school students would have to either apply for financial aid for college or voluntarily opt out, using a short form.7

Behavioral economics has a name for rules like Louisiana’s graduation requirement: “nudge” policies. Nudge policies present the option that delivers more social benefits as the default, without imposing any consequences for choosing another option.8 They perform a nudge, not a shove or a yank. By and large, the designers of nudge policies want individuals to make decisions that contain a short-term cost but support their community’s goals. For example, requiring government employees to make a phone call to opt out of monthly pension contributions, as opposed to opting into their monthly contributions, may reduce the typical employee’s take-home pay in the short-term but has the benefit of increasing their financial security in retirement, reducing their reliance on social services.9

Changing the “choice infrastructure” for high school seniors in Louisiana led to thousands of more FAFSA completions every year, and by making it easy to opt out, it did not cause students to fail to graduate.10 Following success in Louisiana, other states have adopted the same approach. In the six years since Louisiana’s implementation, five more states—Illinois, Alabama, Texas, Indiana, and New Hampshire—implemented policies that mirror Louisiana’s.11

Because they place a state-based requirement on the student, these policies are often called “mandatory FAFSA” policies. While most students comply by submitting the FAFSA, a family that does not want to provide personal information to the federal government can opt out of submitting the form. For example, students who are undocumented or who have an undocumented parent may be hesitant to submit personal information to the federal government. In some states, students can apply for state aid in lieu of the FAFSA, which may offer a pathway to financial aid for undocumented students, depending on the state.12

California, Colorado, and Maryland have implemented laws with similar goals that differ in at least one key way from Louisiana’s mandatory FAFSA model.13

  • California technically places the requirement on school districts to confirm that every senior applies for aid, opts out, or receives an exemption.
  • Colorado offers school districts financial incentives to enact their own local mandates.
  • Maryland requires school districts to provide their students with information about the FAFSA but does not mandate any student action.

Inclusive of state policies that differ from Louisiana’s model, the term “universal FAFSA” has emerged to describe the broader array of policy designs.

Map 1


In states with a Louisiana-style mandatory FAFSA policy, the effects could be seen within the first year. Table 2 below shows the year-over-year change in the FAFSA completion rate of public high school seniors before and after the implementation of each universal FAFSA policy, compared to the rest of the United States in the same year.

Table 2: Change in Public High School FAFSA Completions after Policy Implementation
State School year of implementation Year-over-year change in FAFSA completions: 

Selected state before/after policy 

 Year-over-year change in FAFSA completions: 

Rest of U.S. over same period

 Percentage point difference 
Student must apply for aid or opt out in order to graduate (“mandatory FAFSA”) 
Louisiana 2017–18* +23.9% +1.5% +22.5 pp
Illinois 2020–21 +5.1% –5.5% +10.6 pp
Alabama 2021–22 +23.3% +4.4% +18.8 pp
Texas 2021–22 +24.0% +2.5% +21.5 pp
Indiana 2023–24 –0.9% –10.4% +9.4 pp
New Hampshire 2023–24* –8.7% –10.2% +1.5 pp
District must confirm the student applies for aid or opts out
California 2022–23 +10.4% +2.3% +8.1 pp
District may opt to create its own local mandate
Colorado 2021–22** +1.7% +4.7% –3.0 pp
District required to provide information about the FAFSA
Maryland 2022–23 +4.7% +3.4% +1.3 pp
Source: Author’s analysis of data from the Federal Student Aid Data Center, reflecting high school seniors’ completions as of July 31 each year. Only public schools are included. See Tables A1 to A9 in Appendix 1.

*Policies with an asterisk have been repealed. New Hampshire’s policy was repealed within the first year of implementation. 

**Colorado’s policy started in the 2021–22 state fiscal year. We use the Class of 2022 as the comparison point, but due to low take-up at the district level, using subsequent years’ data do not show meaningful improvement. 

Nearly all the traditional “mandatory FAFSA” states saw their year-over-year increases rise at least 9 percentage points higher than the rest of the nation. Three southern states—Alabama, Louisiana, and Texas—all outperformed the nation by more than 18 percentage points in their first year of implementation. Though California’s policy is not a graduation requirement per se, its performance is closer to that of Illinois and Indiana, which are bona fide mandatory FAFSA states, than Colorado and Maryland, which significantly depart from the Louisiana model.

New Hampshire is an outlier among states with a mandatory FAFSA policy, having only performed 1.5 percentage points better than the rest of the United States during its first year. This may be attributable to the fact that, within the first year, the state legislature repealed the policy, potentially reducing momentum.14

The past year was turbulent for students and families completing the FAFSA, as well as those tracking state-level FAFSA policies. Delays and technical glitches marred the rollout of the 2024–25 FAFSA,15 resulting in roughly 200,000 fewer FAFSA completions among high school seniors, with shortfalls disproportionately concentrated in low-income communities and communities with a high number of mixed-status families.16 Yet mandatory FAFSA states arguably performed the best under the challenging circumstances, showing some of the lowest year-over-year declines and closing demographic gaps by the end of the spring even while gaps persisted in the rest of the country.17

More States Add Policies, Even As Others Repeal Them

Nebraska, New Jersey, New York, and Oklahoma will see their policies take effect in the 2024–25 school year, and Connecticut’s will take effect in the 2025–26 school year.18 As it stands, 44 percent of public high school seniors are enrolled in a state with a universal FAFSA policy.19

At the same time, Louisiana—following seven years as a national leader in FAFSA completion—repealed its graduation requirement in March 2024, motivated by concerns about families’ privacy and the role of graduation requirements.20 Lawmakers in New Hampshire repealed their policy last session during the policy’s first year,21 and Kansas appears poised to repeal its policy before it reaches a single high school senior.22 Others have raised concerns about potential increases in the number of students who accumulate student debt and no degree.23

Whiplash aside, it is evident lawmakers across the country are seriously weighing the pros and cons of introducing new mandatory FAFSA completion requirements. In all likelihood, the current session will feature policymakers from across the political spectrum considering such policies. The remainder of this report provides new analysis examining the effectiveness of FAFSA completion requirements at helping more students obtain information about financial aid and college costs through the FAFSA, including a detailed understanding of who these policies reach and whether Pell Grant uptake and enrollment rise after FAFSA completion rates do.

A Rising Tide: Changes to FAFSA Completion Under FAFSA Mandates

This section of the report focuses on states that adopted mandatory FAFSA policies; that is, statewide graduation requirements for student action to either apply for aid or opt out, over the past seven years. The list of states includes Louisiana, Illinois, Alabama, Texas, Indiana, and New Hampshire. The report also looks at California: while its policy is not a graduation requirement per se, student action is required, and the action presumably happens before the student graduates. The report excludes Colorado and Maryland, whose policies feature much more significant deviations from the policies of the other states.24

The National College Attainment Network’s FAFSA Tracker has shown, year over year, that mandatory FAFSA states boast some of the country’s highest FAFSA completion rates.25 As Table 2 shows, the seven mandatory FAFSA states (including California) all outperformed the rest of the nation in FAFSA completion in their first year with the policy. Across all states, this translates to 86,700 new FAFSA completions over expectation in one year.

Given longstanding gaps in college access and completion, it also matters who completes the FAFSA. Studies on mandatory FAFSA policies have revealed the following:

  • In 2020, when only Louisiana’s policy was implemented, TCF found that the policy closed a FAFSA completion gap between high-income and low-income school districts, as measured by the share of students who are eligible for free or reduced-price lunch (FRPL).26
  • Research published by the Urban Institute found that schools with the largest shares of students living in poverty and schools with the largest shares of Black or Hispanic students showed the highest increases in FAFSA completion under Texas’s policy, first implemented for the Class of 2022.27
  • Recent research by the Public Policy Institute of California found using administrative data that low-income students saw the largest increase in FAFSA completion under California’s policy, first implemented for the Class of 2023.28
  • Recent research by TCF focused on the Class of 2024—which was adversely affected by the rollout of the updated FAFSA—found that, over the course of the spring, demographic gaps closed in states with active mandatory FAFSA policies but not in others.29

While a picture has been emerging that FAFSA mandates may disproportionately benefit low-income students, no study has thus far aggregated insights from all the existing states with active policies, using the same methods. Any individual state’s results may be affected by other policies, such as changes to state financial aid, but the full picture tells a story of one policy movement spanning various states.

Building on TCF’s research on the Class of 2024, this study harnesses public high schools’ FAFSA data from 2017 to 2024 alongside demographic data from the Census Bureau and other information from the Common Core of Data.30 By merging data from these sources, this section compares all of these states separately and in the aggregate, using the rest of the U.S. for comparison.31

Are Increases in FAFSA Completion Widely Distributed?

States that enact mandatory FAFSA policies have generally seen their changes in FAFSA completion outperform the nation by at least 8 percentage points, even as high as 22 percentage points. To explore whether gains came from schools with historically higher or lower FAFSA completion rates, Table 3 examines the percentage point change in public high schools’ aggregate FAFSA completion rates, broken out by their pre-policy completion rate.

Table 3: Change in Public High School FAFSA Completions, Before and After Policy Implementation, By Pre-Policy Completion Rate 
High school’s pre-policy completion rate State
Louisiana (2018) Illinois (2021) Alabama (2022) Texas (2022) California (2023) Indiana (2024) New Hampshire (2024)
0–45% +17.0 pp +3.9 pp +14.3 pp +15.4 pp +10.0 pp +2.3 pp –0.5 pp
45–55% +12.2 pp +0.5 pp +9.7 pp +11.3 pp +8.5 pp –1.3 pp –5.1 pp
55–65% +9.4 pp +0.1 pp +4.4 pp  +11.1 pp +6.3 pp –3.9 pp –5.7 pp
65–100% +6.2 pp –5.0 pp +3.1 pp +6.1 pp +3.4 pp –2.9 pp –8.6 pp
Change in rest of U.S., same year  +0.0 pp –3.0 pp +2.1 pp +1.2 pp  +1.2 pp –6.1 pp –5.9 pp
Source: Author’s analysis of data from the Federal Student Aid Data Center, reflecting public high school seniors’ completions as of July 31 each year, combined with grade 12 enrollment data from the Common Core of Data. See Tables C1 to C7 in Appendix 1. 

In every state, the greatest percentage point increases occurred at high schools with lower baseline FAFSA completion rates, signifying that FAFSA completion gaps across high schools narrowed under the policies. At high schools in Louisiana, Alabama, Texas, and California with historically lower FAFSA completion rates, at least one out of every ten students newly completed a FAFSA who, absent the change in completion rates, would not have.

Put another way, in terms of a percentage increase in FAFSA completions, high schools with low completion rates (that is, below 45 percent, the first row in Table 3) before policy implementation increased their completions by mostly high percentages: by 1 percent in New Hampshire, by 7 percent in Indiana, by 14 percent in Illinois, by 32 percent in California, by 36 percent in Alabama and in Texas,and by a whopping 67 percent in Louisiana.32

Across these states, the policy had its greatest impacts on schools where previously most students did not complete the FAFSA, potentially creating new conversations about college that may not have occurred otherwise.

How Do FAFSA Completion Rate Changes Vary by Demographics?

Not all communities have the same access to college, which makes it important to examine demographic trends in FAFSA completion, the key pathway to financial aid. High-income communities already have high FAFSA completion rates, and communities with high levels of educational attainment do not need state intervention in order to help their children reach college.33 Rather, low- and middle-income communities, and those with lower degree attainment, are the most likely to leave money for college on the table by not completing the FAFSA. Longstanding gaps in degree attainment by race and ethnicity also point to the potential importance of FAFSA completion policies in the context of promoting equal outcomes.34

Though student-level FAFSA data are not publicly available, the demographics of school districts can be used as a substitute. As TCF’s report on Louisiana’s policy had done, this report combines school districts’ data on student demographics and free and reduced-price lunch (FRPL) enrollment with public high schools’ FAFSA completion data, from the Class of 2017 to the Class of 2024.35

Table 4, below, examines how FAFSA completion in each state’s lowest-income districts (top one-fifth by FRPL rate) compares to FAFSA completion in its highest-income districts (bottom one-fifth by FRPL rate), before and after policy enactment.

Table 4: Change in Public High School FAFSA Completions, Before and After Policy Implementation, By School Districts’ FRPL Rate Quintile
State Highest-income districts, last year pre-policy Lowest-income districts, last year pre-policy Gap, last year pre-policy (percentage points) Highest-income districts, first year with policy Lowest-income districts, first year with policy Gap, first year with policy (percentage points)
Louisiana 60.8% 54.6% 6.2 68.2% 66.8% 1.4 
Illinois 62.2% 56.8% 5.4 63.1% 54.6% 8.5 
Alabama 51.0% 42.5% 8.5 58.8% 58.6% 0.2 
Texas 50.7% 50.1% 0.5 59.3% 66.8% –7.5 
California 56.9% 56.0% 0.9 63.5% 63.5% 0.0 
Indiana 57.0% 39.5% 17.6 53.6% 41.1% 12.5 
New Hampshire 59.5% 45.8% 13.7 55.3% 41.7% 13.6 
Source: Author’s analysis of data from the Federal Student Aid Data Center, reflecting public high school seniors’ completions as of July 31 each year. Free and reduced-price lunch rates derived from data from the Common Core of Data. See Figures G1 to G7 in Appendix 1. 

In five of the seven states in Table 4, the gap between high- and low-income districts narrowed after the policy’s implementation or flipped in favor of low-income districts (Illinois saw the gap increase, while New Hampshire saw its gap stay pretty much the same). Some states saw significant change: in Alabama, the gap shrunk from 8.5 percentage points to 0.2 percentage points, and in Texas, the gap flipped, such that low-income communities outperformed high-income communities by 7.5 percentage points.

By leveraging Census Bureau data on community demographics, research for this report reveals similar trends in communities that traditionally have less college access. In five of the seven states, low-attainment communities (that is, top one-fifth by the share of adults without a college degree) saw disproportionate gains.36 For example, in New Hampshire, a 13.5-percentage-point gap between communities with low degree attainment and high degree attainment reduced to 8.7 percentage points, even in a challenging year for FAFSA completion among communities where fewer adults have college degrees.37

Trends by race and ethnicity are more mixed: in three of the seven states, communities with high shares of residents who are Black or Latino saw disproportionately large gains, but the opposite was true in another three, and in one there was virtually no difference.38 This suggests trends by race may be less consistent than those by income or educational attainment. However, overall FAFSA completion gains in California, Texas, and Illinois—large states that are more racially diverse than the nation overall—contribute to national trends showing that communities with a higher share of Black or Latino residents now complete the FAFSA at higher rates, compared to those with a lower share.39

Downstream Effects: College-Level Trends

Do Mandatory FAFSA Policies Increase the Uptake of Pell Grants?

A key goal of mandatory FAFSA policies is to enable students to enroll in college more affordably. Because roughly four in five undergraduate students enroll in college within their home state, one way to measure success towards this goal is to track changes in the number of Pell Grant recipients at the institutions in each state.40

Table 5 below compares each state’s growth in Pell Grant recipients after the first year of implementation versus the rest of the county over the same period. (Since Indiana and New Hampshire are still in their first year after policy implementation, comparable data for these states are not yet available.) For example, Louisiana’s colleges saw its Pell Grant recipients increase by 3.3 percent in a year when the rest of the nation saw its Pell Grant recipients decrease by 3.4 percent, resulting in a 6.7 percentage point overperformance by Louisiana.

Table 5: Change in Institutions’ Pell Recipients, Before and After Policy Implementation
State School year of implementation Year-over-year change in Pell recipients: 

Selected state before/after policy 

 Year-over-year change in Pell recipients: 

Rest of U.S. over same period

 Percentage point difference 
Louisiana 2017–18 +3.3% –3.4% +6.7 pp
Illinois 2020–21 +0.1% –2.2% +2.2 pp
Alabama 2021–22 –0.9% –0.7% –0.2 pp
Texas 2021–22 +0.6% –0.8% +1.4 pp
California 2022–23 +5.5% +4.5% +1.0 pp
Source: Author’s analysis of data from the Federal Student Aid Data Center, representing total recipients in the award year of first policy implementation and the subsequent year. Rounding errors may occur. See Tables D1 to D6 in Appendix 1.

Table 5 shows that these five states’ performance in Pell Grant recipients after policy enactment, relative to the rest of the nation, ranges from –0.2 percentage points to +6.7 percentage points. Across all five states, this translates to 27,500 new annual Pell Grant recipients over expectation in one year. (See Table 1.) While causation is difficult to prove, this may be encouraging for lawmakers considering enacting a mandatory FAFSA policy in another state.

Taking a wider window for Louisiana, comparing 2017–18 with 2023–24, we find the state outperformed the nation by 11.9 percentage points in change in Pell Grant recipients.41 Comparing 2020–21 to 2023–24, Illinois outperformed the state by 5.2 percentage points.42 Comparing 2021–22 to 2023–24, Alabama (–0.9 percentage points) and Texas (+0.4 percentage points) show roughly equal performance with the rest of the nation.43

Not all institutions may be affected equally: the data reveal particularly strong increases for public institutions and colleges that predominantly focus on sub-baccalaureate education, such as community colleges.44 Policymakers may find encouragement in seeing an overall trend of increased Pell recipiency in states with these policies, particularly at institutions that are a common entry point for lower-income students.

Do Mandatory FAFSA Policies Increase Undergraduate Enrollment?

Mandatory FAFSA policies may not simply help students receive Pell who wouldn’t otherwise; students may enroll in college who wouldn’t have otherwise. For some states that have recently enacted policies, such as Indiana and New Hampshire, public post-policy enrollment data are not yet available. For the states that enacted their policies earlier—Louisiana, Illinois, Alabama, Texas, and California—the appendix to this report contains an analysis of enrollment data, comparing the latest year that would not be affected by the policy with the earliest year that would be.45 Similarly, as in the previous section, the analysis below compares states’ changes in enrollment to the comparable rate of change in the rest of the country. This analysis focuses on first-time undergraduate enrollment, i.e. freshman enrollment.

Three states—Louisiana, Illinois, and California—show overperformance relative to the rest of the country of 3.5 percentage points, 3.8 percentage points, and 5.1 percentage points, respectively, while Texas runs roughly equal to the rest of the country and Alabama trailed behind the rest of the country the same year. (See Table 6.)

Table 6: Change in Institutions’ Undergraduate Enrollment, Before and After Policy Implementation
State School year of implementation Year-over-year change in undergraduates: 

Selected state before/after policy 

 Year-over-year change in undergraduates: 

Rest of United States over same period

 Percentage point difference 
Louisiana 2017–18 +3.8% +0.3% +3.5
Illinois 2020–21 +6.5% +2.7% +3.8
Alabama 2021–22 +2.7% +3.9% –1.3
Texas 2021–22 +3.4% +4.0% –0.6
California 2022–23 +7.7% +2.6% +5.1
Source: Author’s analysis of data from the Integrated Postsecondary Education Data System (IPEDS), representing change in first-time undergraduate enrollments from the final fall term not affected by the policy to the first fall term after the first high school class subject to the policy graduates. Rounding errors may occur. 

Across all states, this translates to 21,900 new annual first-time undergraduates over expectation in one year. First-time undergraduate enrollment trends appear especially strong for public institutions,46 full-time students,47 Black students,48 and Hispanic students.49 Overall, this may be a sign that FAFSA requirements can have a positive impact on enrollment, though experience may vary by state. Other research has found moderately positive effects on enrollment. One study using longitudinal data in Louisiana found a modest increase in college enrollment of 1 to 2 percentage points that is attributable to the state’s policy and is stronger at low-income schools.50 Similarly, research finds that Texas’s policy increased college enrollment rates by students at high schools with historically lower FAFSA completion rates.51

It may take states like Alabama and Texas time to translate increased FAFSAs into increased enrollments statewide. Educational interventions are often slow to bear fruit; mandatory FAFSA policies’ increases in completions are an exception to the rule. While these states’ increases in FAFSA completions have been dramatic, there is more to college enrollment than financial aid eligibility awareness.

To improve the pipeline from high school to college, states need comprehensive plans to connect students to timely guidance about college. The next section of this report offers a model approach used by two states.

State Models for Student and School Support

Mandatory FAFSA is an example of a state policy that seeks to connect a family to federal resources through school action. It is a state policy, but its success depends on how well schools implement it.52

How well schools implement the policy depends on the resources that they have available to them, in terms of money and personnel. In many communities, student–counselor ratios are woefully high, meaning counselors already have little breathing room amid student needs even before demand for FAFSA assistance rises with the introduction of the mandate.

The gold standard for increasing FAFSA completions, and for increasing college enrollment as a result, is hands-on professional support with the form. States implementing mandatory FAFSA policies should deploy new, long-term resources to ensure a family’s ability to complete the FAFSA is not simply a function of their school’s funding.

Below, the report highlights examples from two states that show strong results in college enrollment after enacting their policies, California and Illinois. This section highlights their approaches to filling vital needs for hands-on support. The analysis below draws from nearly two dozen interviews with stakeholders across these two states, including agency officials, program administrators, school leaders, and students.53

The Challenge

Like other states with FAFSA requirements, California and Illinois contain many school districts that would be ill-equipped to meet a rise in demand for FAFSA completion support on their own.54 While the American School Counselor Association recommends a student–counselor ratio 250-to-1, California’s ratio is 464-to-1 and Illinois’s is 501-to-1, both sizably worse than the national average.55 Some school districts within these states may have more favorable staffing levels, but in others, there are more than 1,000 students for every guidance counselor.56 Moreover, not all counselors are trained in the FAFSA.

Much like in other states, the legislatures in California and Illinois did not include major new investments in funding for school staff when they passed the new FAFSA requirement. Given that state policymakers cannot wave a magic wand and give existing counselors more free time to focus on the FAFSA, these states had to deliver assistance to strained high schools and their families. And even if students receive help with the FAFSA, they also need assistance with the full process of enrolling in college, from initial information-gathering to matriculation.

In both states, the answer to these challenges has been to deploy programs that connect students and families to trained support with the FAFSA and college enrollment. States considering passing mandatory FAFSA policies can learn from these examples.

Fundamentals of Cal-SOAP and ISACorps

The California Student Opportunity and Access Program (Cal-SOAP) and the Illinois Student Assistance Commission Corps (ISACorps) are two programs that have been fundamental to the success of their respective states’ FAFSA completion initiatives.57 Though they both originated long before their states’ FAFSA requirements debuted, they have been instrumental in supporting lower-resourced schools and families amidst a new state requirement.58

In California, Cal-SOAP operates through sixteen regional consortia composed of K–12 schools, local colleges, and community-based organizations, serving over 400 middle schools and high schools across California.59 Cal-SOAP staffing levels vary by location, but typically consist of full-time staff and part-time college student workers who collaborate with school personnel to assist students through the financial aid and college admissions process. Cal-SOAP staff, regarded as financial aid experts by stakeholders, receive year-round professional training from organizations such as CSAC, uAspire, and the U.S. Department of Education Office of Federal Student Aid, ensuring they deliver up-to-date, high-quality assistance.

In Illinois, ISACorps operates as a state-wide peer-to-peer mentorship program that assists first-generation, low-income, and underrepresented youth to enroll and complete a postsecondary credential.60 ISACorps is composed of roughly eighty recent college graduates who are typically placed in a similar area to where they originally graduated in the state. ISACorps members focus their efforts on the highest need schools, completing over 450 hours directly in schools within their two-year term, and a total of 3,000 hours of experience working directly with students on post-high school pathways. ISACorps members undergo rigorous training in FAFSA completion, financial aid processes, and college applications.

Multiple Channels of FAFSA Assistance

Both programs expand access to financial aid and postsecondary education through direct services to schools and families. Through these programs, the implementation of FAFSA mandates does not have to be solely on any individual school’s shoulders.

Cal-SOAP services are tailored to meet local community needs and often feature an on-site presence, in-class presentations, small group advising, and financial aid workshops for students and families. Cal-SOAP services operate at multiple levels, including both community-wide events and school-based programming. For example, interviewees stated that Cal-SOAP staff often collaborate with schools to access senior English or government classes to deliver in-class presentations and hands-on support with FSA IDs and completing the FAFSA or the California Dream Act Application (CADAA), the state’s alternative financial aid form. Individualized support is also available through Cal-SOAP success coaches who offer one-on-one assistance.

Similarly, ISACorps hosts workshops where students can complete their FAFSA with the immediate assistance of an ISACorps member: in total, ISACorps hosts over 2,000 outreach events annually. Beyond events, ISACorps facilitates one-on-one mentoring, helping to reach families beyond school grounds. ISACorps provides a key service by disseminating information directly to families, and ISACorps’ capacity to engage with families one-on-one, outside of the classroom, often exceeds the capacities that counselors are confined to within the standard school day.

Tackling Areas of Greatest Need

Cal-SOAP and ISACorps help solve the challenge of delivering a uniform mandate across states, where some school districts have significantly fewer financial resources. They supplement school district efforts to raise financial aid awareness, while allowing school districts to design strategies that work for their unique populations.

To bridge capacity gaps in school districts, Cal-SOAP provides direct, hands-on support, with events offered virtually, during school hours, and after school to maximize accessibility for students and parents.61 Cal-SOAP is especially valuable for school districts with staffing limitations or less familiarity with the financial aid process. Stakeholders identified Cal-SOAP as essential for bridging capacity gaps in school districts, especially in underserved and rural communities.

While ISACorps services are available to any family in the state, half of ISACorps members’ time is designated to the highest need high schools in their assigned district. Corps members provide short-term relief to overburdened schools, acting as a touchpoint for students and families who might otherwise lack assistance with the FAFSA.

Maintaining an Ecosystem of Support

This report has highlighted major ways that Cal-SOAP and ISACorps complement their states’ FAFSA requirements, but interviews conducted as part of the research also revealed some limitations.

For one, Cal-SOAP and ISACorps can only change student outcomes where they are present. In interviews, stakeholders emphasized the need for more trained staff on the ground, as resources have not entirely kept pace with the expanded responsibilities placed on school districts under California and Illinois’s policies. Some of California’s regions lack Cal-SOAP presence, such as rural northern California and densely populated Orange County. At current staffing levels, ISACorps’ eighty members cannot reach all of the state’s 144,000 grade 12 students.62 Similarly, interviewees emphasized that continued investment in programs like Cal-SOAP and ISACorps is essential.

In addition, no aspect of a state’s FAFSA completion strategy can be successful if schools themselves do not make FAFSA completion a priority. But interviewees reported that Cal-SOAP and ISACorps have helped dispel misconceptions about California and Illinois’ FAFSA requirements, increased local buy-in, and offered an alternative to pushing students towards the opt-out when demand for assistance exceeds counselors’ time.

A Model for Other States

To be sure, not all the success of California and Illinois’s FAFSA requirements are due to Cal-SOAP and ISACorps alone. Interviews also revealed the importance of the state student aid commissions’ data-sharing,63 professional development and training for counselors,64 and solicitation of ground-level feedback from students and school communities.65

FAFSA completion is one indicator of these programs’ success. Linking Cal-SOAP member districts and schools (derived from consortium websites) to public FAFSA data, it is possible to assess whether schools with Cal-SOAP presence saw outsized gains under the state’s FAFSA policy, which was introduced for the class of 2023. As Table 7 shows, high schools in Cal-SOAP consortia had higher FAFSA completion rates before the policy’s introduction and, despite the higher baseline, saw a larger gain (+7.1 percentage points) compared to all other California public high schools (+6.1 percentage points).

Table 7: Change in California Public High Schools’ FAFSA Completion Rates, Before/After Policy, by Cal-SOAP Consortium Membership 
High school category FAFSA completion rate, class of 2022 (pre-policy) FAFSA completion rate, class of 2023 (post-policy) Percentage point change
High schools in Cal-SOAP consortia (N = 243) 58.6% 65.7% +7.1
All other California public high schools (N = 1,728) 55.7% 61.8% +6.1
Source: Author’s analysis of data from the Federal Student Aid Data Center, reflecting high school seniors’ completions as of July 31 each year. Only public schools are included. List of high schools that are members of a Cal-SOAP consortium derived from Cal-SOAP consortia websites. The Solano/East Bay, San Bernardino, and San Diego/Imperial Valley consortiums were not included, as their high schools were not listed on their websites. See Table F2 in Appendix 1. 

While interviewees reported that the presence of programs like Cal-SOAP helped maintain buy-in from the states’ schools, the data also suggest that the programs deliver material benefits to students.

Any state considering introducing a mandatory FAFSA policy must account for resource gaps across schools and the need for mentoring throughout the college enrollment process. As one interviewee at a school district stated, “You cannot make a mandate like this without offering the districts support—and by that I mean manpower.” Other states can learn from California and Illinois’ approach to back up the mandate with manpower.

Mandatory FAFSA and Deportation Threats

When The Century Foundation first explored mandatory FAFSA policies in 2020, it urged states and schools to carefully handle communication with undocumented students and mixed-status families, so as to prevent outing anyone’s citizenship status.66 At the time, existing policy and practice gave little reason to doubt that submitting the FAFSA was worthwhile for families in need of aid, including for mixed-status families.

That was during the final year of President Trump’s first term, which—for all its anti-immigrant rhetoric—saw annual deportation rates that were roughly equal to67 or less than68 those under Presidents Obama and Biden. As the second Trump term begins, many expect that the federal government will deploy new tactics to achieve higher deportation rates.69 Those new tactics could include unprecedented uses of FAFSA data, with implications for the parents of students applying for financial aid through the FAFSA.

Under the Higher Education Act, any U.S. citizen is entitled to Title IV financial aid, so long as they qualify based on family income and other requirements such as Satisfactory Academic Progress. Students who are U.S. citizens can qualify even if their parents are not U.S. citizens. When completing the FAFSA, a parent (or other contributor) submits contact information such as mailing address.

Historically, FAFSA data has not been used for the purpose of targeting people for deportation.70 But for an estimated 4.7 million households nationwide that contain a mix of undocumented residents and U.S. citizens (or others with legal status), the decision whether to submit personal information that could expose undocumented family members to the federal government is a weighty one,71 with an incoming administration that has pledged to undertake the largest deportation operation in history.

Data-sharing across agencies, such as between the U.S. Department of Education (ED) and the U.S. Department of Homeland Security (DHS) requires an explicit agreement between the agencies that specifies how the agency will use the shared data. The current agreement between ED and DHS is for the verification of the legal status of noncitizens who are eligible for federal financial aid, such as refugees and green card holders.72 ED’s website states that information on FAFSA contributors is never shared with DHS.73 However, the Privacy Act of 1974 allows for agency heads to request information from other agencies for the purpose of law enforcement, leaving open the possibility that ED could enter into a new agreement to share data with DHS that could raise concerns for undocumented or mixed-status families.74 The existing layers of protection could be eroded by the new administration.75

The administration’s possible actions affect a sizable share of the population. To provide a window into the scale of the concern nationwide, analysis for this report used Census Bureau data to examine the population of young unmarried adults that hold U.S. citizenship and live with a noncitizen adult.76 The results provide estimates of the number of Grade 12 students, since they are subject to mandatory FAFSA policies, though other young adults would need to include their noncitizen household members as contributors on the FAFSA, too.77 These are intended to indicate ballpark estimates, not specific counts of individuals.

Table 8 shows that roughly half a million Grade 12 students may need a noncitizen family member to contribute to their FAFSA, and approximately three in five of these students live in states with an active mandatory FAFSA policy in 2024–25. While some of these family members have documentation, a substantial share likely do not.

Table 8: Estimated Grade 12 Students Who May Have a Noncitizen FAFSA Contributor, Nationwide and in Mandatory FAFSA States. 
State Estimate
U.S. Overall 513,000
Alabama 4,000
California 142,000
Illinois 25,000
Indiana 6,000
Nebraska 2,000
New Jersey 14,000
New York 33,000
Oklahoma 4,000
Texas 72,000
Source: Author’s analysis of data from the American Community Survey, reflecting survey year 2023. Values rounded to nearest thousand. See Table F3 in Appendix 1.

All states need to be careful how they talk about the FAFSA to families, but especially mandatory FAFSA states. It is a short game of telephone separating the real policy—the requirement that students apply for financial aid or complete an opt-out form—from an incorrect message that the state now requires every family to submit the FAFSA to the federal government and will hold their child’s diploma hostage until they do.

In reality, mandatory FAFSA policies are designed to be a light-touch intervention, where opting out is as simple as signing a one-page form.78 No family should feel, incorrectly, that they are required to send their personal information to the federal government, much less a family whose members are vulnerable to deportation. States and schools should continually assess whether their opt-out form is easy to find online and in person, available in languages spoken by students’ families, and clearly states that there are no repercussions or restrictions for opting out, while avoiding confusion about how the opt-out form data is used by schools and the state.79

At the time of our writing, it is impossible to say whether the Trump administration will, in fact, co-opt FAFSA data or state-level financial aid data for the purposes of its proposed deportation program. Such an action would earn a place among the most ignoble actions by an administration in living memory, using financial aid for college as the basis on which to deport the loved ones of U.S. citizens. On inauguration day, the administration rescinded guidance that limited immigration enforcement at schools, thus making events like FAFSA completion workshops a possible target.80

First and foremost, the administration should publicly forswear this possibility. Senators should not confirm Linda McMahon, the nominee for U.S. secretary of education, if she does not commit to reject all requests for federal FAFSA data that could then be used by DHS for deportation.81

In addition to the FAFSA, states receive information from families about citizenship status through state-based forms. Several mandatory FAFSA states, including California and Illinois, provide this pathway to state financial aid. These forms are largely used by undocumented students, but California has recently begun to encourage mixed-status families to utilize them, too, with the assurance that data is not shared with the federal government or used for immigration enforcement.82 (Colleges should similarly assure students that data submitted by them and their family members will not be shared for immigration enforcement.83) Other states may not offer the same guarantees as those of California. Undocumented and mixed-status families who believe their state governments would share information with DHS may similarly refrain from completing these forms; but if they trust their state, they could apply for aid through these FAFSA-alternatives.

As for families, the National College Attainment Network has recently said that students with undocumented immigrant parents should make a “considered decision” before submitting the FAFSA,84 and the Education Trust has shared resources about the treatment of FAFSA data.85 Whether to submit the FAFSA is every individual family’s decision to make. They may consider whether other agencies already possess the same information,86 or if they have already submitted the FAFSA for another family member,87 in which case it may be all the same for them if they submit the FAFSA now.

They can also pursue higher education without pursuing federal financial aid, such as through private scholarships or state financial aid.88 A student who is a U.S. citizen but whose parents are undocumented has the option to wait to apply until they would be deemed independent for financial aid purposes: this occurs after the student turns 24 years old or gets married (or meets other conditions).89 However, it is deeply unfortunate that a student would need to delay their college aspirations, or forgo aid such as the Pell Grant, for this reason.

Conclusion

Nearly half of public high school seniors in the class of 2025 will graduate under an opt-out FAFSA graduation requirement, a stunning increase from virtually zero just a decade ago.90

In all likelihood, that share will continue to rise. In this legislative cycle and those to come, many more states will consider passing a mandatory FAFSA policy in the mold of Louisiana’s mandate or a modified version such as California’s. The new research in this report indicates that these states can and should use policies such as these to nudge students towards FAFSA completion, given encouraging results relating to student’s FAFSA completion, Pell Grant uptake, and college enrollment.

These policies move the country closer to the ideal of every student knowing their financial aid eligibility, but first, states must confront the reality of resource disparities across schools, as well as mixed-status families’ genuine concerns about how their information will be used after they submit the FAFSA. States enacting mandatory FAFSA policies must take certain steps so that families receive hands-on support with the FAFSA and understand their options. The programs in California and Illinois highlighted in this report show how states can help less-resourced schools support families with the form; in doing so, however, state officials and school administrators must prioritize the needs of immigrant families in their communication with families about the policy, the way they conduct in-person events, and the training they provide school staff.

Mandatory FAFSA policies cannot reverse the complexity of the financial aid system, but they can reduce the information disparities that play a large role in who enrolls in college. If the nation is to ever reach a point where everyone who wants a college education can attain it, it will take policies such as these to move us closer.

Thanks to Bill DeBaun, Brendan Williams, and Alejandra Vázquez Baur for feedback on a draft of this report.

The original code for the analysis in this report can be found in this GitHub repository.

Appendix 1: Supplementary Tables and Figures
Appendix 2: Methodology

Notes

  1. Peter Granville, “Should States Make the FAFSA Mandatory?” The Century Foundation, July 29, 2020, https://tcf.org/content/report/states-make-fafsa-mandatory/.
  2. The states that have implemented a mandatory FAFSA policy similar to Louisiana’s are Illinois, Alabama, Texas, Indiana, and New Hampshire. For simplicity of this introductory section, we refer here to California’s policy as “mandatory FAFSA,” though other sections in this report will provide nuance. Other states have introduced the policy for the class of 2025 or later.
  3. Mireya Sandoval, “Opportunities & Challenges of Universal FAFSA,” uAspire, April 27, 2023, https://www.uaspire.org/getattachment/40c4f21c-2240-4a58-998f-5832789338b5/Opportunities-Challenges-of-Universal-FAFSA.pdf.
  4. Bill DeBaun, “National FAFSA Completion Rates for High School Seniors and Graduates,” National College Attainment Network, n.d., accessed January 2025, https://www.ncan.org/page/NationalFAFSACompletionRatesforHighSchoolSeniorsandGraduates.
  5. Yuxin Lin and Vivian Yuen Ting Liu, “Timing Matters: How Delaying College Enrollment Affects Earnings Trajectories,” Community College Research Center, February 2019, https://ccrc.tc.columbia.edu/publications/delaying-college-enrollment-earnings-trajectories.html.
  6. Organisation for Economic Co-operation and Development, “Education economic and social outcomes,” n.d., accessed November 2024, https://www.oecd.org/en/topics/policy-issues/education-economic-and-social-outcomes.html.
  7. Ann Carrns, “More States Require High School Seniors to Fill Out Financial Aid Form,” New York Times, October 14, 2022, https://www.nytimes.com/2022/10/14/your-money/states-fafsa.html.
  8. Alex Verkhivker, “Why Policy Makers Should Nudge More,” Chicago Booth Review, October 9, 2017, https://www.chicagobooth.edu/review/why-policy-makers-should-nudge-more.
  9. Becky Morrison, “How a small nudge is helping people save for their retirement,” Department for Work and Pensions, October 22, 2013, https://quarterly.blog.gov.uk/2013/10/22/how-a-small-nudge-is-helping-people-save-for-their-retirement/.
  10. Peter Granville, “Should States Make the FAFSA Mandatory?” The Century Foundation, July 29, 2020, https://tcf.org/content/report/states-make-fafsa-mandatory/.
  11. National College Attainment Network, “Universal FAFSA Completion with Supports,” n.d., accessed November 2024, https://www.ncan.org/page/UniversalFAFSA.
  12. “Tuition & Financial Aid Equity for Undocumented Students,” Higher Ed Immigration Portal, n.d., accessed December 2024, https://www.higheredimmigrationportal.org/states/.
  13. “Tuition & Financial Aid Equity for Undocumented Students,” Higher Ed Immigration Portal, n.d., accessed December 2024, https://www.higheredimmigrationportal.org/states/.
  14. The General Court of New Hampshire, “House Bill 1066,” n.d., accessed November 2024, https://www.gencourt.state.nh.us/bill_Status/billinfo.aspx?id=1401&inflect=2.
  15. The 2024–25 FAFSA is the form completed by the high school graduating class of 2024 to apply for financial aid for use in the 2024–25 award year.
  16. Peter Granville, “FAFSA Fallout: Application Dropoff Threatening to Widen College Gaps,” The Century Foundation, June 27, 2024, https://tcf.org/content/report/fafsa-fallout-application-dropoff-threatening-to-widen-college-gaps/.
  17. Ibid., see Figures 14 to 16.
  18. “Universal FAFSA with Supports,” National College Attainment Network, n.d., accessed December 2024, https://www.ncan.org/page/UniversalFAFSA.
  19. Author’s analysis of data from the Common Core of Data via the National Center on Education Statistics, accessed November 2024, reflecting public high school twelfth graders in the most recent year with available data, 2023–24. The list of states with active policies in 2024–25 is Alabama, California, Colorado, Illinois, Indiana, Maryland, Nebraska, New Jersey, New York, Oklahoma, and Texas.
  20. Bill DeBaun, “Louisiana Board Rescinds State’s Universal FAFSA Policy,” National College Attainment Network, March 14, 2024, https://www.ncan.org/news/667451/Louisiana-Board-Rescinds-States-Universal-FAFSA-Policy.htm.
  21. The General Court of New Hampshire, “House Bill 1066,” n.d., accessed November 2024, https://www.gencourt.state.nh.us/bill_Status/billinfo.aspx?id=1401&inflect=2.
  22. Matt Resnick, “State ed board scraps recently implemented FAFSA requirement,” State Affairs, July 10, 2024, https://pro.stateaffairs.com/ks/education/fafsa-requirement-kansas-state-board-2; Jason Alatidd, “Here are the new Kansas high school graduation requirements, starting in fall 2024,” Topeka Capital-Journal, May 16, 2024, https://www.cjonline.com/story/news/politics/government/2024/05/15/kansas-updates-high-school-graduation-requirements-starting-next-fall/73647885007/.
  23. Adam Kissel, “Louisiana is Right to Scrap a Mandatory FAFSA,” Minding the Campus, March 6, 2024, https://www.mindingthecampus.org/2024/03/06/louisiana-is-right-to-scrap-a-mandatory-fafsa/.
  24. As noted in the section above, school districts in Colorado can choose not to participate, and Maryland’s policy only requires that districts provide information to the student.
  25. Bill DeBaun, “FAFSA Tracker,” National College Attainment Network, n.d., accessed November 2024, https://www.ncan.org/page/FAFSAtracker.
  26. Peter Granville, “Should States Make the FAFSA Mandatory?” The Century Foundation, July 29, 2020, https://tcf.org/content/report/states-make-fafsa-mandatory/.
  27. Sie Won Kim, “How a Mandatory FAFSA Completion Policy in Texas Could Improve College Access,” The Urban Institute, April 28, 2023, https://www.urban.org/research/publication/how-mandatory-fafsa-completion-policy-texas-could-improve-college-access.
  28. Kevin Cook, Jacob Jackson, and Selina Gomez, “Implementing California’s Universal Financial Aid Application Policy,” Public Policy Institute of California, October 2024, https://www.ppic.org/publication/implementing-californias-universal-financial-aid-application-policy/.
  29. Peter Granville, “FAFSA Fallout: Application Dropoff Threatening to Widen College Gaps,” The Century Foundation, June 27, 2024, https://tcf.org/content/report/fafsa-fallout-application-dropoff-threatening-to-widen-college-gaps/.
  30. Ibid.
  31. We do not have access to school-level data on state-based financial aid applications. However, a student can satisfy the policy by submitting a state-based financial aid application.
  32. These figures are calculated in the same manner as the percentage point changes in Table 3 except that they report the relative increase in FAFSA completions.
  33. Peter Granville and Bill DeBaun, “Despite Challenges, Long-Run FAFSA Trends Show Promise,” The Century Foundation, November 2024, https://tcf.org/content/commentary/despite-challenges-long-run-fafsa-trends-show-promise/.
  34. National Center on Education Statistics, “Educational Attainment of Young Adults,” U.S. Department of Education, n.d., accessed November 2024, https://nces.ed.gov/programs/coe/indicator/caa/young-adult-attainment.
  35. For more information, see Appendix 2: Methodology.
  36. See Figures B1 through B7 in Appendix 1.
  37. Peter Granville, “FAFSA Fallout: Application Dropoff Threatening to Widen College Gaps,” The Century Foundation, June 27, 2024, https://tcf.org/content/report/fafsa-fallout-application-dropoff-threatening-to-widen-college-gaps/.
  38. See Figures B1 through B7 in Appendix 1.
  39. Peter Granville and Bill DeBaun, “Despite Challenges, Long-Run FAFSA Trends Show Promise,” The Century Foundation, November 2024, https://tcf.org/content/commentary/despite-challenges-long-run-fafsa-trends-show-promise/.
  40. Excluding international students, 82 percent of undergraduate students attend college within their state of legal residence. Source: National Postsecondary Student Aid Study: 2020 Undergraduate Survey, accessed via NCES Datalab, table retrieval code jsbfzc
  41. See Table D5a in Appendix 1.
  42. See Table D5a in Appendix 1.
  43. See Table D5a in Appendix 1.
  44. See Tables D2a and D3a in Appendix 1.
  45. See Tables E1 to E7 in Appendix 1. We include breakouts by race and ethnicity, by full-time status, by institutions’ Pell share of undergraduate enrollment, by institutions’ control, and by institutions’ predominant degree awarded.
  46. See Table E4 in Appendix 1.
  47. See Table E2 in Appendix 1.
  48. See Table E6 in Appendix 1.
  49. See Table E6 in Appendix 1.
  50. Christa Deneault, “College Enrollment and Mandatory FAFSA Applications: Evidence from Louisiana,” American Economic Journal: Economic Policy 15, no. 3 (August 2023), https://www.aeaweb.org/articles?id=10.1257/pol.20210360.
  51. Sie Won Kim, “Early impacts of the FAFSA requirement in Texas,” Economics of Education Review 104 (February 2025), https://www.sciencedirect.com/science/article/abs/pii/S0272775724001122.
  52. It also depends on how well the federal government maintains the form. Mandatory FAFSA states saw disproportionately large declines in FAFSA completions when the form was plagued with technical errors in early 2024, though these states saw disproportionately strong improvement as the Department of Education made progress in resolving the technical errors. See Peter Granville, “FAFSA Fallout: Application Dropoff Threatening to Widen College Gaps,” The Century Foundation, June 27, 2024, https://tcf.org/content/report/fafsa-fallout-application-dropoff-threatening-to-widen-college-gaps/.
  53. Except where noted with a footnote, interviews with stakeholders serve as the source for this section.
  54. In this section, we use phrases such as “FAFSA requirement” in reference to California’s policy, rather than ‘mandatory FAFSA’ to acknowledge that its policy is not identical to the traditional mandatory FAFSA model.
  55. “Student-to-School-Counselor Ratio 2022–2023,” American School Counselor Association, n.d., accessed December 2024, https://www.schoolcounselor.org/getmedia/a988972b-1faa-4b5f-8b9e-a73b5ac44476/ratios-22-23-alpha.pdf.
  56. n the Common Core of Data, there are sixty-nine school districts that offer grade 12 in California and Illinois with at least 1,000 students and fewer than one guidance counselor per 1,000 students, according to data reflecting the 2023–24 school year. Of these sixty-nine school districts, forty-nine are in California and twenty are in Illinois.
  57. “California Student Opportunity and Access Program (Cal-SOAP),” California Student Aid Commission, n.d., accessed February 2025, https://www.csac.ca.gov/california-student-opportunity-and-access-program-cal-soap. “About the ISACorps,” Illinois Student Assistance Commission, n.d., accessed February 2025, https://www.isac.org/students/before-college/isacorps/.
  58. The California legislature created Cal-SOAP in 1978, and the Illinois Student Assistance Commission launched ISACorps in 2009. The states’ FAFSA requirements took effect in 2022 and 2020, respectively.
  59. “California Student Opportunity and Access Program (Cal-SOAP),” Sacramento, CA: California Student Aid Commission, n.d., accessed February 2025, https://www.csac.ca.gov/california-student-opportunity-and-access-program-cal-soap.
  60. “About the ISACorps,” Deerfield, IL: Illinois Student Assistance Commission, n.d., accessed February 2025, https://www.isac.org/students/before-college/isacorps/.
  61. The same is true of California’s Cash for College workshops.
  62. Derived from the Common Core of Data, reflecting public high school grade 12 students enrolled in 2023–24, the latest year with available data.
  63. The California Student Aid Commission (CSAC) manages the WebGrants system, providing authorized school staff with access to student-level data, helping them track FAFSA/CADAA completion and identify non-completers who may need targeted follow-up support. Similarly, the Illinois Student Assistance Commission (ISAC) hosts a FAFSA tracking platform that includes students’ completion statuses for the FAFSA and alternative financial aid forms. The platform updates weekly, providing timely and accurate information. Also see Bill DeBaun, “Student-Level FAFSA Data Sharing: Policies By State,” National College Attainment Network, n.d., accessed January 2025, https://www.ncan.org/page/fafsadatasharing.
  64. CSAC offers extensive free professional development to help guide students through the FAFSA/CADAA, including annual workshops, weekly live webinars for school staff and financial aid administrators, and self-paced training videos to ensure staff were well-informed. Similarly, ISAC provides counselors with extensive training programs, including on-demand resources, webinars, and in-person training for school administrators.
  65. ISAC solicits ground-level feedback from counselors and ISACorps members to refine ISAC policies: a successful example of this is the transition of FAFSA waiver forms online to reduce administrative burdens, inspired by input from ground-level administrators. A similar example in California is CSAC’s Student Advisory Board Council, a partnership with California higher education student associations.
  66. Peter Granville, “Should States Make the FAFSA Mandatory?”, Washington, D.C.: The Century Foundation, July 29, 2020.
  67. “Table 39. Aliens Removed or Returned: Fiscal Years 1892 to 2019,” U.S. Department of Homeland Security Office of Homeland Security Statistics, n.d., accessed January 2025, https://ohss.dhs.gov/topics/immigration/yearbook/2019/table39.
  68. Brandon Drenon, “US deportations under Biden surpass Trump’s record,” BBC, December 20, 2024, https://www.bbc.com/news/articles/c36e41dx425o.
  69. Elliot Spagat, “Trump’s goal of mass deportations fell short. But he has new plans for a second term,” AP News, September 22, 2024, https://apnews.com/article/trump-mass-deportations-immigration-844f3050ba99552b900ed9f3a1dec22d.
  70. In a document dated January 17, 2025, the department wrote, “we have not provided information for immigration enforcement purposes.” See “Questions and Answers Recommended for Students on Information Collected for StudentAid.gov Account Creation and Filling-Out the FAFSA,” U.S. Department of Education, January 17, 2025, https://cdn.ymaws.com/www.ncan.org/resource/resmgr/fafsacompletion/FAFSA_data_FAQ_students_fami.pdf.
  71. Matthew Lisiecki and Gerard Apruzzese, “Proposed 2024 Mass Deportation Program Would Socially and Economically Devastate American Families,” Center for Migration Studies of New York, October 10, 2024, https://cmsny.org/publications/2024-mass-deportation-program-devastate-american-families-101024/.
  72. “Data Protections for FAFSA Information,” Presidents’ Alliance for Higher Education and Immigration, updated November 26, 2024, https://www.higheredimmigrationportal.org/wp-content/uploads/2024/11/Data-Protections-for-FAFSA-Information.pdf.
  73. “How To Submit the FAFSA® Form if Your Contributor Doesn’t Have an SSN,” U.S. Department of Education Office of Federal Student Aid, n.d., accessed January 2025, https://studentaid.gov/announcements-events/fafsa-support/contributor-social-security-number#questions.
  74. “Data Protections for FAFSA Information,” Presidents’ Alliance for Higher Education and Immigration, updated November 26, 2024, https://www.higheredimmigrationportal.org/wp-content/uploads/2024/11/Data-Protections-for-FAFSA-Information.pdf.
  75. Mikhail Zinshteyn, “Will filling out student aid form target undocumented parents for Trump’s mass deportations?” CalMatters, December 12, 2024, https://calmatters.org/education/higher-education/2024/12/fafsa-undocumented-parents/.
  76. As a caveat, using American Community Survey data to examine the population of noncitizens may lead to underestimates due to response bias. At the same time, it may overestimate due to including documented noncitizens, who we are unable to distinguish in the data from undocumented residents.
  77. The FAFSA considers anyone who is aged 24 or above or who is married independent and does not require their parents to submit information.
  78. For example, Texas’s form is only one page and does not ask for the family’s reason for opting out.
  79. For example, a report from the Public Policy Institute of California finds that “There was … confusion about what to do with the opt-out forms, as there is no mechanism to collect or monitor them. One district we spoke to was concerned with who was collecting the data, how it was being stored, and who had access to it.” Our interviews with California stakeholders uncovered similar confusion and concern. See Cook et al., “Implementing California’s Universal Financial Aid Application Policy,” San Francisco, CA: Public Policy Institute of California, October 2024.
  80. Lynn Damiano Peason, “Factsheet: Trump’s Rescission of Protected Areas Policies Undermines Safety for All,” National Immigration Law Center, January 21, 2025, https://www.nilc.org/resources/factsheet-trumps-rescission-of-protected-areas-policies-undermines-safety-for-all/.
  81. Similarly, she should commit to oppose any efforts by DHS to obtain this information through the states.
  82. Daisy Gonzales, “Executive Office Memorandum: Upholding the California Dream for All Students,” California Student Aid Commission, November 22, 2024, https://www.csac.ca.gov/sites/default/files/2024-11/eom_2024-06.pdf.
  83. For example, see guidance from the California Office of the Attorney General on how the state’s colleges and universities should respond to immigration issues. “Promoting a Safe and Secure Campus for All,” California Office of the Attorney General, December 2024, https://oag.ca.gov/sites/all/files/agweb/pdfs/immigration/higher-education-guidance.pdf.
  84. Eric Hoover, “Will Submitting the FAFSA Put Undocumented Parents at Risk? This Group Thinks It Could,” Chronicle of Higher Education, November 26, 2024, https://www.chronicle.com/article/will-submitting-the-fafsa-put-undocumented-parents-at-risk-this-group-thinks-it-could.
  85. “ETN Guidance on 2025–26 FAFSA for Students from Mixed-Status Families,” The Education Trust, n.d., accessed January 2025, https://edtrust.org/wp-content/uploads/2025/01/ETN-Public-Guidance-on-2025-26-FAFSA-for-Students-from-Mixed-Status-Families.pdf.
  86. Ibid.
  87. Zaidee Stavely, “What rights do immigrant students and families have in California schools and colleges under the coming Trump administration?”, LAist, January 7, 2025, https://laist.com/news/education/immigrant-students-families-rights-california-schools-colleges-under-trump.
  88. “ETN Guidance on 2025–26 FAFSA for Students from Mixed-Status Families,” Washington, D.C.: The Education Trust, n.d., accessed January 2025, https://edtrust.org/wp-content/uploads/2025/01/ETN-Public-Guidance-on-2025-26-FAFSA-for-Students-from-Mixed-Status-Families.pdf.
  89. “How Do I Qualify as a FAFSA Independent Student?” FinAid.org, n.d., accessed December 2024, https://finaid.org/about/contact/fafsa-independent-student/.
  90. As stated earlier in the report, the share is 44 percent.

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