On December 30, just before the Congressionally-mandated deadline of midnight on December 31, the Department of Education soft launched the newly simplified 2024-2025 Free Application for Federal Student Aid (FAFSA). Despite numerous technical issues and limited availability plaguing the first week of its rollout, the FAFSA is now available 24/7 and the Department has reported that over a million students have successfully submitted their forms.

Through the first few days, the form was only available to students and families for about an hour a day. Since then, the availability of the form has slowly increased to the all-day availability being reported now. 

However, two significant concerns persist.

The first is that there is at least a month-long delay until the Department sends Institutional Student Information Records (ISIRs) to schools. When a student completes their FAFSA, they receive a confirmation page and an email that assures the student that their data has been successfully submitted and provides their estimated Student Aid Index (SAI). The confirmation page also includes disclosure language that explains that the Department will not send a student’s ISIR to their selected schools until late January. With the form itself already delayed by three months, the addition of at least another month before ISIRs make it to schools and states to determine students’ aid eligibility further strains the system, with a disproportionate impact on lower-income students who rely on financial aid to access higher education.

The second concern is the Department has still not determined whether or when it will update the income protection allowance tables for the current award year – essentially updating them to reflect inflationary trends – a decision that reduces the amount of aid for which some students are eligible. This uncertainty is why students’ confirmation pages only provide an estimated SAI. Schools that have sought workarounds to the FAFSA delays, such as using the SAI estimator tool from the Department or asking the students and parents to complete the FAFSA and send over their SAI in the confirmation email, are still not receiving the final numbers they need to finalize aid packages.

It remains unclear what impact updating these tables will ultimately have on students’ aid eligibility, as well as the timeline for the delivery of ISIRs to schools, though it is safe to assume that further delays will occur.

While it is good to see the form’s availability progress so quickly after launch, the overarching concerns that remain are NAICU’s top priorities during weekly conversations with the Department. The Department is aware of the anxiety its rollout has caused students, parents, and schools, and has communicated consistently throughout the rollout period on the status of improvements.