UDSE provide guidance on the application process for applicants under the age of 13 in an Electronic Announcement posted to the IFAP website on July 18th. While the statutory and regulatory provisions for the Title IV programs include a number of student eligibility provisions that may be indirectly related to the age of the applicant (e.g., requirement for a high school diploma, prohibition against a student being enrolled in primary or secondary school), neither the law nor the regulations include a specific age requirement for receipt of Title IV, HEA program assistance. Therefore, a student of any age who is otherwise eligible may apply for and receive Title IV aid.


However, provisions of the Children’s Online Privacy Protection Act (COPPA) of 1998 require special procedures for very young applicants. The COPPA generally prohibits any entity, including a government agency, from conducting any business or communication electronically with a person under age 13. Thus, given the requirements of COPPA, for an applicant under the age of 13, USDE will not permit completion of a FAFSA using FAFSA on the Web (FOTW), nor will the Department communicate electronically with such a student, even if parental approval is obtained.


To ensure compliance with the COPPA, the FOTW process includes edits that block the submission of a FAFSA when the applicant’s reported birth date indicates that the applicant is under age 13. And, for technical reasons a regular paper FAFSA that is submitted for an applicant who is under age 13 will be immediately rejected. However, as noted above, since these students are eligible to apply for Federal student assistance, beginning with the 2014-2015 FAFSA a process has been developed that allows them to submit a paper COPPA

Compliant Special Handling FAFSA for special processing, which will produce ISIRs that will be transmitted to institutions and states.


For full details see the entire electronic announcement at:


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