Implementing California’s Universal Financial Aid Application Policy

To gauge how the first year of the universal FAFSA/CADAA policy implementation progressed across the state, we conducted site visits at three school districts and conducted interviews at 18 school districts. The sample included three rural, seven urban, and eight suburban districts. The group included a mix of districts that had higher and lower FAFSA/CADAA completion rates. Most commonly we talked to more than one member of staff at the schools, often including school counselors, principals, college readiness specialists, teachers, and superintendents. Through this rich interview data, we identified many similar experiences in terms of obstacles faced and strategies used.

Obstacles

Many of the obstacles to universal FAFSA/CADAA policy implementation have been longstanding, and some were created by the new policy. Counselors, teachers, and other school staff shared during interviews and site visits their challenges in getting all students to complete the FAFSA or CADAA.

Parent participation can be difficult to obtain

Lack of parent cooperation is by far the most recurring obstacle to full implementation. Both parents and students must participate in completing the FAFSA/CADAA. Parents must also enter their tax information from two years prior or allow their student to do so. Interviewees remarked that many parents did not feel comfortable sharing their financial information with students, and some did not feel comfortable sharing the information with the federal government.

As of 2021, 20 percent of California residents under 18 were living in "mixed-status" families-where one parent is a citizen and one is not (California Immigrant Data Portal 2021). Given the share of undocumented and mixed-status families in the state, fear of exposure or interference with existing legal processes is a concern. For example, a school district in Southern California close to the US-Mexico border noted that the biggest obstacle they faced was parents lacking the necessary tax documentation to complete the form. Missing tax filings, incomplete tax forms, and complications with immigration status made it difficult to complete the process.

School counselor caseloads are too large

At every school and district, school counselors were central to meeting the universal FAFSA/CADAA goal. They were often responsible for family and student outreach. Families often depended on them for tracking completed financial applications. The American School Counselor Association recommends a load of about 250 students per counselor, but our interviews revealed many school counselors have caseloads of upwards of 400 to 500 students (American School Counselor Association 2024). Research has already shown that high caseloads lead to burnout and further decrease the already limited time school counselors have to counsel students directly (Bardhoshi et al. 2014). The policy does not provide any new funding up front for more counselors, professional development, or other help for school counselors. Interviewees expressed how their high caseloads limit their ability to know students individually and make sure full implementation is achieved.

Tracking completed applications was complicated

For the first time, schools were tasked with keeping information on completed and uncompleted financial aid applications for each of their high school seniors. School personnel made innovations to determine which seniors had yet to complete a financial aid form and provide the necessary resources and support. For example, staff at a Bay Area urban high school used an online portal on the CSAC website (Web Grants) to track student completion. They discovered that a significant percentage of the students in this district transferred to another high school or went to a continuing education school but were still being counted as enrolled in their high school.

The portal allows staff to run reports that indicate which students have successfully completed a FAFSA or CADAA. It also provides information on whether a GPA verification form has been uploaded and if this information has been matched to a financial aid application. Although about half the districts interviewed used that portal, inconsistent tracking methods are still a key barrier to a streamlined implementation. Every school we interviewed used some version of a shared Microsoft Excel file or Google document. It would be inherently safer and easier if districts had access to a cloud-based system.

The new opt-out process was confusing to students and staff

As mentioned above, the policy allows students to opt out. The CSAC provided a template for opt-outs, but our interviewees did not always feel there was enough guidance on how to use it. The template requires the following information: pupil name, date of birth, and statewide student identifier (SSID). It also requires a counselor signature and a parent or guardian signature if the student is under 18 years old. A student signature is valid in lieu of parent/guardian if the student is emancipated or over 18 years old. It also includes language stating that submitting an opt-out form does not prohibit a pupil from completing and submitting a financial aid application at any time in the future. A sample opt-out form is provided in Technical Appendix C.

However, the law stipulates that each school district determines the date to submit the form, leaving districts to decipher how and when to provide information to students regarding the op-out choice. We encountered uncertainty about what happens if students refuse to either apply for aid or opt out, which schools admit some students did. There was also confusion about what to do with the opt-out forms, as there is no mechanism to collect or monitor them. One district we spoke to was concerned with who was collecting the data, how it was being stored, and who had access to it.

Strategies

While the schools and districts saw similar challenges, they found solutions for their student populations that often relied on cooperation and coordination between many individuals at schools and in districts. We highlight some of the common and more innovative solutions that emerged from our interviews and site visits.

Building external partnerships

Parent involvement is critical to building trust with families who must provide the sensitive information needed to complete the FAFSA/CADAA. Trust must be established between the families and district by instilling culturally relevant support and information (College Board Advocacy and Policy Center 2010). Some schools and districts relied on larger partnerships with community resources to do so.

One example is Val Verde Unified School District's partnership with TODEC -Training Occupational Development Educating Communities-a local organization that provides legal services to the undocumented and mixed-status families of their community. Their attorneys provide free legal consultation to families, which cultivates a sense of trust and knowledge when tackling a legal form such as FAFSA/CADAA. TODEC also provides knowledge on the rights of undocumented individuals, conducts town halls, and facilitates college tours. Although this service is not available to all students, many districts have also partnered with California Student Opportunity and Access Program (Cal-SOAP), which provides financial aid information to families. They offer counseling sessions virtually or in person with families who have yet to complete their form.

Data sharing

Districts we interviewed noted that improved data sharing across high schools was an important tool for locating students and helping them complete the financial aid application process. Having all student data consolidated to a central location readily accessible to school counselors allows for timely interventions to help students and their families. Some districts have achieved data sharing agreements by working with their county's department of education or other partnerships.

For example, Val Verde Unified School District is part of a data-sharing agreement with all 23 districts in their county, administered by the Riverside County Office of Education. Val Verde has steadily increased their FAFSA/CADAA completion rates over a seven-year period-from 69 percent to 92 percent-by improving their student tracking systems and ensuring that pupils whose information reported to CSAC were currently enrolled. They also partner with other schools in the district when students transfer, not just to ensure preciseness, but so that the student also gets the necessary support for filing FAFSA/CADAA at their new school. For Val Verde and other interviewed districts with data-sharing agreements already established, this additional data is pivotal in measuring results and pinpointing errors, which districts can then address in an efficient and impactful manner.

At the state level, two data systems mentioned by districts that we interviewed could also prove valuable in ensuring a greater number of students complete the FAFSA/CADAA, and should provide important information to policymakers and practitioners regarding the impact of increased FAFSA/CADAA completion on college access and affordability. First is the California College Guidance Initiative (CCGI). CCGI provides students from middle school to college age with an online portal that allows them to access information on college, career, and financial aid planning. Importantly, this tool also allows students to complete and submit the FAFSA/CADAA and other critical financial aid information directly to CSAC and the Federal Student Aid authority. CCGI also partners with school districts to provide reporting tools and automate routine tasks, and helps districts manage expanding capacity and analysis of the student data they collect. School districts in California often have rich student data but can lack the capacity to use this data to evaluate the outcomes of different policies and practices.

Second, the Cradle to Career Data System-which will provide California with its first longitudinal, student-level data system-will collect and report data on 11 different variables related to student financial aid. The system will collect information on financial aid eligibility, applications, awards, and debt for the state's high school, public, and private nonprofit colleges. Critically, this data system will also be able to provide information on students who applied for aid and did not receive it, allowing for greater analysis of the barriers students face when navigating the financial aid application process.

Managing policy information flow

One of the most common strategies was prudently managing the information students had access to. Rather than telling students they can either fill out the FAFSA/CADAA or an opt-out form, many districts told them it was a graduation requirement, or simply that they were expected to complete it. Similarly, some chose not to tell students the opt-out form was a choice until later in the school year and after they had attempted other approaches. Opt-outs were generally low (under 10%) at most of the schools we interviewed. The main groups choosing that option were students in Special or Continuing Education groups, students planning to join the military or workforce, and families who had presumed they would not qualify for aid. Even so, despite staff efforts and low numbers of opt-outs, just over 25 percent of students neither applied nor opted out of applying for financial aid (CSAC 2023b).

Incentives and competition

Best practices from several districts show that incentives and friendly competition for schools and students are a key motivation to ensure high FAFSA/CADAA completion rates. Finding a way for students to feel valued for their hard work and effort is important. According to our interviewees, when seniors who complete their financial aid form are celebrated in one form or another, students can look forward to these rewards, which can then become an invaluable tradition.

On a broad level, the California Student Aid Commission created the Race to Submit website, which publicly shares FAFSA/CADAA completion data and strategies. The schools with the highest FAFSA/CADAA completion rates are invited to attend an annual celebration ceremony where they receive banners to display. This friendly competition has been something that many districts have embraced and use as motivation for staff and students alike.

Within individual schools or districts, incentives could be as small as a classroom lunch gathering or as large as a schoolwide festival with activities and prizes. For example, after the FAFSA/CADAA March 2 deadline, Val Verde Unified holds a party called "Cashchella" for high school seniors who have completed the form-with rides, food, and prizes. Seniors who do not complete the application are not allowed to participate. Administrators, staff, and students all noted that this event is considered a highlight for the year and is a key motivator.

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