PostsecData’s Comment on Proposed 2024-25 FAFSA
Published Oct 16, 2023
Washington, DC (October 16, 2023) – The Institute for Higher Education Policy (IHEP) and 10 other members and partners of the Postsecondary Data Collaborative (PostsecData) responded to the call for comments on the Department of Education (ED)’s proposed 2024-25 Free Application for Federal Student Aid (FAFSA). The letter expresses strong support the inclusion of questions about applicants’ race, ethnicity, and gender in the revised form. While the FAFSA has not historically included questions on race and ethnicity, the FAFSA Simplification Act now requires the inclusion of these questions. In addition, the proposed form now correctly provides students with a nonbinary option for gender. Implementing these changes is critical to maintaining a streamlined and inclusive aid application for students and to identifying and addressing inequities in access to and affordability of higher education.
Read the full letter below.
—
October 16, 2023
Kun Mullan
PRA Coordinator
Strategic Collections and Clearance Governance and Strategy Division
Office of Chief Data Officer, Office of Planning, Evaluation and Policy Development.
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
Re: Docket No.: ED-2023-SCC-0053
To Whom It May Concern:
This letter is submitted on behalf of the 11 undersigned members and partners of the Postsecondary Data
Collaborative (PostsecData) in response to a call for comments on the Department of Education (ED)’s
proposed 2024-25 Free Application for Federal Student Aid (FAFSA). PostsecData is a nonpartisan coalition of organizations committed to the use of high-quality postsecondary data to improve student success and advance educational equity.
The undersigned members strongly support the inclusion of questions about applicants’ race, ethnicity,
and gender in the revised form. While the FAFSA has not historically included questions on race and
ethnicity, the FAFSA Simplification Act now requires the inclusion of these questions. In addition, the
proposed form now correctly provides students with a nonbinary option for gender. Implementing these
changes is critical to maintaining a streamlined and inclusive aid application for students and to identifying and addressing inequities in access to and affordability of higher education. Further, we encourage ED to reconsider the use of a separate FAFSA form for incarcerated applicants that is not streamlined to those individuals’ needs.
Race and Ethnicity
PostsecData strongly supports the proposed options for the race and ethnicity questions included in the
draft FAFSA and encourages ED to maintain the level of detail this question structure would provide. We
appreciate the thoughtful implementation of proposed race and ethnicity questions for the 2024-25 aid
year, which align with previous recommendations from PostsecData. In addition to asking applicants to
indicate whether they identify as White, Black or African American, Asian, American Indian or Alaska
Native, and/or Native Hawaiian or Pacific Islander, the proposed FAFSA form allows applicants to
identify racial subcategories, such as Chinese, Filipino, Nigerian, and Samoan. In the proposed form,
applicants who identify as American Indian or Alaska Native can indicate their enrolled or principal
tribe(s). PostsecData also supports the proposed use of a separate question about student ethnicity,
which aligns with existing best practices and standards used in data collection across other federal
agencies.
The inclusion of these race and ethnicity questions on the FAFSA is invaluable for research on how
different groups of students access, cover costs for, and receive value from postsecondary education.
Note that applicants’ reported race and ethnicity data will not be used to determine financial aid
eligibility or be shared with the schools to which they apply. For research purposes, the detailed
question structure in the proposed FAFSA enables disaggregation at a level sufficient to examine
variations and inequities within larger subgroups (e.g., disparities within the larger Asian American and
Pacific Islander group).
Gender
In addition, PostsecData supports ED’s proposed wording of the question collecting information about
student gender. The inclusion of a “nonbinary” category, in addition to “male” and “female”, allows for
a more accurate and inclusive reflection of students’ gender.
Incarcerated Student Form
Finally, ED’s proposed materials for the 2024-25 FAFSA include a separate form for incarcerated
students, which is identical to the standard form. As in our previous recommendations, PostsecData
urges ED to provide a separate FAFSA form for incarcerated students only if it is tailored to their
experiences and needs. The use of a separate but identical form can contribute to the stigma that many
justice-impacted students already face. If it is not possible to provide a separate, tailored form for the
2024-25 FAFSA, incarcerated applicants should be directed to complete the standard form and ED
should develop a streamlined version for incarcerated applicants in the future.
The undersigned thank ED for efforts to improve the FAFSA, while reducing the burden it places on
students and their families. We urge ED to continue to collect better, more complete data that would
allow institutions and policymakers to implement data-driven strategies to address inequities in access
to and affordability of higher education.
If you have any questions, please contact Diane Cheng, Vice President of Research and Policy at the
Institute for Higher Education Policy (dcheng@ihep.org).
Sincerely,
Aspen Institute for College Excellence
Association for Career and Technical Education
Georgetown University Center on Education and the Workforce
Higher Learning Advocates
Institute for Higher Education Policy (IHEP)
Nexus Research and Policy Center*
NCHEMS
The Education Trust
The Hope Center at Temple University*
The Institute for College Access & Success (TICAS)
uAspire
* Denotes signatory added on October 19, 2023
—
A formal copy of the letter and list of signatories is available here.
