Send in your comments to U.S. DOE about FAFSA college lists

The US Department of Education recently announced that it is accepting comments from the public about how to improve the Free Application for Federal Student Aid (FAFSA) process.  Some NACAC members have been concerned that some colleges use the list of colleges that students supply on their FAFSA forms in an attempt to ascertain the students’ likelihood of attending the institution if accepted.

NACAC is planning on submitting comments, which are below, with the Department encouraging them to modify the FAFSA in one of the following ways:

1.    Refrain from sending students’ college lists to the colleges; or
2.    Inform students that their lists can be sent to colleges (preferably in alphabetical or random order), and allow students to either opt-in or opt-out of such a transmission.

NACAC encourages you to submit your own comments.  If you would like to do so, please send them to ICDocketMgr@ed.gov or Director of the Information Collection Clearance Division, U.S. Department of Education, 400 Maryland Avenue SW., LBJ, Mailstop L-OM-2-2E319, Room 2E115, Washington, DC 20202.  Be sure to include the Docket Number: ED-2014-ICCD-0125.  The deadline to submit comments is October 27, 2014.

Background
As has been reported in the media, some colleges use the list of colleges that students supply on their FAFSA forms in an attempt to ascertain the students’ likelihood of attending the institution if accepted. Specifically, colleges make note of the order in which students list the institutions to which their results are to be sent and assume that the order conveys evidence of the student’s preference.   NACAC has been able to confirm independently that some colleges use the FAFSA college lists for recruitment and admission purposes. NACAC also confirmed through contact with its colleges and with the Office of Federal Student Aid (FSA) that the college lists are routinely provided to colleges, along with the other information submitted by students via the FAFSA. While colleges regularly use information supplied by students, either directly to the college or voluntarily through lead generation sources (such as the agencies that administer the SAT/ACT admission tests and various online college information Web portals) for the purpose of identifying a student’s demonstrated interest in attending, students are made aware upon submission of their personal information that the information will be shared with colleges for use during the recruitment and admission process. However, students are not made aware that information supplied via the FAFSA may be used by colleges in the recruitment and admission process, only that the information will be used in the process of administering financial aid.

Concerns
The association believes that students should not be compelled by colleges to disclose their college preferences during the application process. NACAC’s Statement of Principles of Good Practice (SPGP) – the standards by which the association’s more than 13,000 members operate — dictates that member colleges shall — not require or ask candidates or the secondary schools to indicate the order of the candidates’ college or university preferences (SPGP Mandatory Practice, Section II.B.2).

While students may volunteer this information, the association believes that a student’s right to keeping such information private is an integral part of maintaining a fair admission process. In the past, NACAC has found that institutions exercised leverage over students by asking them to disclose their college preferences, forcing students into the uncomfortable situation of disclosing information that could count against them in the application review process, or being less-than-truthful on their application about their preferences.

As evidenced by media reports and our initial inquiries into the matter, colleges are utilizing the information disclosed by students without their knowledge or consent to make informed guesses about the students’ college preferences. We believe this interferes with students’ ability to navigate the admission process in as fair a manner as possible. NACAC believes that the FSA could remedy this situation by simply not disclosing the students’ college lists to colleges.

NACAC has communicated with the National Association of Financial Aid Administrators (NASFAA) and the National Association of State Student Grant and Aid Programs (NASSGAP) about this issue to ensure that we are not recommending a course of action that would affect their ability to effectively and efficiently administer federal and state aid to students.

We understand from these conversations that the student lists are an important component in administering state aid programs in some states. However, we maintain that in the interest of students, FSA modify the FAFSA in one of the following ways:

1.    Refrain from sending students’ college lists to the colleges; or
2.    Inform students that their lists can be sent to colleges (preferably in alphabetical or random
order), and allow students to either opt-in or opt-out of such a
transmission.

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