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Students walk under a canopy of trees along a brick pathway on a campus

Southwestern University in Texas was one of the first institutions to draw up its own student aid form mimicking the FAFSA after the latest delay from the Education Department.

Southwestern University

Tom Delahunt was fed up with waiting.

Already stressed over the rocky rollout of the new Free Application for Federal Student Aid, the vice president for strategic recruitment and enrollment at Southwestern University knew he couldn’t sit tight any longer after the Education Department’s latest and most disruptive delay early this month. So he took matters into his own hands.

Delahunt and his team drew up their own formula mimicking the new Student Aid Index calculations and sent out a makeshift financial aid estimate form to admitted students last week. In the first 48 hours, they received 80 completed forms, and they have begun calculating their best approximations of student aid packages.

“We had been talking about doing this for a few months, but that [Institutional Student Information Record delay] was really the last straw,” Delahunt said. “Part of this, of course, is so the university can speed up this already-stalled process. But it’s mainly for the families and the students that are in this situation trying to make an informed financial decision on a really stressful timeline.”

The Education Department has made some progress since the ISIR delay was announced. On Friday the department began sending test ISIRs to colleges, meeting the timeline for additional support laid out in early February. But for many colleges that delay was a sign that they had to step in to help prospective students—or risk losing them.

Families will still have to file the FAFSA and await their final federal aid packages, likely to come sometime in April. But Delahunt said that even a ballpark estimate should help admitted students feel more confident in considering their options.

Emmanual Guillory, senior director of government relations at the American Council on Education, said using institutional replicas of the FAFSA to estimate and send early aid packages—especially without guaranteeing them—is a gamble. But he understands that institutions have been dealt a difficult hand.

“What we see here are institutions trying to make the best of a bad situation,” he said. “We wouldn’t necessarily highly recommend this, but we certainly understand why institutions are doing it and trust that they are making the right decision for themselves.”

Formulating a FAFSA Facsimile

Rob Reddy, vice president for enrollment management at St. Louis University, first predicted the FAFSA rollout would be a debacle nearly a year ago, when the Education Department conceded it would not meet its initial launch deadline of Oct. 1.

“I’ve seen a lot in my 35 years as a financial aid officer, and looking at how the department was handling this rollout, I anticipated there were going to be issues,” he said.

In early January, after the new FAFSA’s soft launch left most students and families unable to access the forms, Reddy decided enough was enough. Within three weeks, SLU had spun up its own form and sent it to admitted students; a week later, the university had received over 430 completed copies and an outpouring of gratitude from high school counselors.

Reddy noted that students from a wide range of socioeconomic backgrounds filled out the form, reflecting an eagerness for information even among those whose aid packages are likely to be relatively small.

“There’s clearly an appetite for this across the spectrum,” he said.

SLU’s student aid application mirrors the new FAFSA, only it uses updated inflation tables that were conspicuously absent from the original when it launched in January. The university will guarantee all institutional aid in early packages unless families misreport their income in excess of $15,000.

For its part, Southwestern will guarantee the estimate procured from its completed student aid forms “as a baseline,” meaning that if a student is entitled to more federal aid once the ISIRs come in, that increase will be honored instead of used to supplant any promised institutional aid. It’s a delicate balance: if the university overestimates students’ federal aid, it risks paying out of pocket to make up the difference.

Delahunt said the Education Department forced Southwestern’s hand. He believes it’s worth the added cost to ensure that students—especially those from low-income families or underserved communities—feel prepared to make the difficult decision of which college to attend, or whether to attend at all.

“There’s some risk involved, but we can’t just sit around on our hands and wait,” Delahunt said. “It’s the right thing to do.”

Other colleges, including Carroll College in Montana, are offering aid package estimates with a conditional guarantee: it will stand by its institutional aid offers but won’t make up for changes in final federal aid if students end up qualifying for less than they predicted. (This paragraph has been update to correct Carroll's name from “University” to “College.”)

Carroll isn’t collecting student information using its own aid forms, but rather taking Student Aid Index numbers from FAFSAs that have already been filed and plugging them into a formula created by its financial aid office. The college has been sending out the resulting package estimates since mid-January, anticipating further delays.

Janet Riis, Carroll’s director of financial aid, said she was confident of the college's federal aid estimates but she understood the risks of offering a package that is subject to change without a full guarantee. Still, she believes it’s in the best interest of both the institution and the students to have more information earlier.

“This is unlike anything we’ve ever gone through, and it will at least give folks a bit more guidance,” she said. “We’re taking it day by day, and our motto is ‘Pivot, pivot, pivot.’”

A Competitive Advantage With a Risky Edge

The institutional forms and estimates are meant to help students and families make more informed decisions in the weeks before they receive their final federal aid packages. But they hold another benefit as well: in a year of uncertainty, institutions that provide an early guarantee can secure commitments from students eager for a solid, timely aid offer, potentially peeling them away from competitors who don’t—or can’t—do the same.

“I’d be lying if I said that didn’t cross our minds,” Delahunt said. “We were losing students already in this process. So we weren’t doing it just for the students; we did it for us, too.”

Some colleges use the College Scholarship Service Profile, a FAFSA calculator alternative, to make aid estimates. Only a few hundred of the thousands of four-year institutions in the country pay the premium to subscribe to the Profile—usually the best-endowed private colleges with chests of aid to dole out—and the form is notoriously exhaustive and frustrating to fill out. But Delahunt said those institutions have an advantage in a year when getting an aid offer early can be the decisive push to commit. For non-Profile colleges, homespun forms are the only alternative.

Institutions able to engage in such a competitive enrollment strategy by offering guaranteed pre-FAFSA aid estimates belong to a fairly uniform group: small private colleges that depend on enrollment and tuition for operating revenue but have enough institutional resources to back up their wagers.

“Not everyone can go this route, I know,” said Carroll president John Cech, who is also chair of the National Association of Independent Colleges and Universities’ Student Aid Committee. “We’re a small, nimble private college. We can make these decisions.”

Guillory said that divide is one of the many ways the new FAFSA rollout has exposed the stratification of higher ed institutions.

“There are institutions that understand the unintended consequences of estimating and not being sure and do not have the capacity to be able to put out information and then go back on it,” he said. “Underresourced institutions don’t have a lot of institutional aid to begin with, let alone set aside to make up for a difference in federal aid.”

The institutions offering only an estimate, and not a guarantee, are more diverse—and are taking an even bigger risk, Guillory said. If they are confident in the ballpark accuracy of their early offers, then being proactive in an uncertain climate could net them an enrollment bump. If they miscalculate, they risk alienating admitted students by changing their aid packages retroactively.

That’s especially concerning considering Congress has yet to pass an appropriations bill, Guillory added; the deadline is March 1. The amount of federal FAFSA aid and other federally funded subsidies available could fluctuate significantly based on the final bill, especially in a year when political power is split contentiously between the two parties.

“In an environment like this, where there are drastic cuts being proposed on the House side to things like Federal Work-Study, it could really put institutions in a bind,” he said. “We hope and trust that institutions have a plan in place and are making these offers and estimates from an informed position. But those who may have less resources could be putting themselves in jeopardy.”

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