This Electronic Announcement, posted to the IFAP website, provides reminders to institutions on three important provisions relating to a student’s application for federal student financial assistance under Title IV of the Higher Education Act (the Title IV HEA programs).
FAFSA – Only Form Required
The Free Application for Federal Student Aid (FAFSA) is the only form that a student is required to complete to be considered for student assistance from any of the Title IV, HEA programs. No additional application or other request for information can be required by an institution in support of the student’s request for Title IV, HEA program assistance, except for information needed to ensure the student’s eligibility for such assistance (e.g., information needed to complete verification or to demonstrate compliance with the student eligibility provisions of the HEA and the regulations).
While institutions and states may require other applications or additional information for the administration of their non-Title IV programs, they cannot require such information for the determination of a student’s eligibility for Title IV, HEA student assistance. Thus, it must be clear in all of an institution’s printed and electronic materials that no other application or information is required for consideration by the institution of the student’s eligibility for assistance under the Title IV, HEA programs.
To ensure compliance with the above, schools are urged to perform a thorough review of all of their financial aid information, as well as admissions, registration, and other general or promotional materials. Institutions should be sure to examine materials, including web sites that have been developed by offices other than the financial aid office (e.g., outreach, admissions, public affairs, academic departments).
Fees, Assessments, and Discounts
Schools are reminded that consistent with section 483(a)(1) of the HEA and the regulations at 34 CFR 668.14(b)(3), a student cannot be charged any fee for completing a FAFSA or for any other activity or process related to determining the student’s eligibility for assistance from any of the Title IV, HEA programs. This includes any fee that might be charged for expedited processing.
Recently, USDE has been asked whether an institution can provide a reduction or discount to its regular tuition and fee schedule based upon advance or timely payment of those charges. For example, a school seeks to offer a certain percentage reduction in its regular tuition charges if those charges are paid early.
In addition to regulatory provisions at 34 CFR 668.14(b)(3) and (b)(21), section 472(1) of the HEA states, in the provision for establishing the tuition and fee component of Title IV, HEA applicants, that the institution must use an amount that is “required for all students in the same course of study”. Therefore, a recipient of Title IV, HEA student assistance cannot be assessed charges that are higher than what is charged to a student not receiving aid under the Title IV, HEA programs. Offering a discount to students who pay early is not permitted because, in general, Title IV, HEA program recipients may not be able to, and should not be required to, meet that requirement and would, therefore, in effect be assessed higher amounts than other students. Of course, it would be permissible for the institution to provide the discount to all Title IV eligible students without regard to when their charges are paid. However, doing so would require an adjustment to the students’ cost of attendance.
PINs and Electronic Signatures
We remind institutions that section 483(a)(7) of the HEA states that, “No person, commercial entity, or other entity may request, obtain, or utilize an applicant’s personal identification number [PIN] . . .”. Therefore, institutions and other entities or individuals may not ask or allow students to provide their PIN to any other person or entity, including institutional staff. Nor may a student authorize another person to apply for an FSA PIN on the student’s behalf.