NASFAA Rolls Out Recommendations for Pell Grant Expansion

• Students who are incarcerated are set to regain access to Pell Grants nationwide in 2023.
• Lawmakers and education officials should step up communication and set up clear guidelines for colleges ahead of the rollout, according to a new NASFAA report.
• Incarcerated students face a slew of external factors that affect their enrollment, like struggling to access identification required for the FAFSA.

Education officials should step up communication about the Free Application for Federal Student Aid (FAFSA) process for incarcerated students to make sure the upcoming Pell Grant expansion is successful, according to a new report.

The National Association of Student Financial Aid Administrators (NASFAA) convened a working group to look at challenges that students who are incarcerated might face when filling out the FAFSA, according to a NASFAA release.

That working group rolled out a slew of recommendations Monday for lawmakers and Department of Education officials centered around simplifying the application process and helping students fill out the complex application.

The report comes as incarcerated students will have their Pell Grant access restored in July 2023 — nearly 30 years after the federal policy was ended in 1994.

The Department of Education finalized rules around the Pell Grant restoration in November and incorporated input from community colleges and advocates around the role of corrections agencies in reviewing prison education programs.

"This unique population will need additional help and resources to support them through the federal student aid process," NASFAA President Justin Draeger said in the release. "Thanks to the work of this task force, we have a blueprint on how we can help them take what could be one of the biggest positive changes in their life: a postsecondary education."

What Lawmakers and the Department of Education Can Do

Many of the application challenges that incarcerated students faced during the Second Chance Pell Experiment were addressed by the 2020 FAFSA Simplification Act, according to the report.

That gradual Pell Grant expansion for incarcerated students, for example, saw many students struggle with questions about selective service registration and drug conviction eligibility requirements, according to the report. Those questions were nixed by the FAFSA Simplification Act.

But lawmakers and Department of Education officials can take more steps to ensure that incarcerated students successfully fill out the FAFSA and get access to Pell Grants, according to the report. Some of the working group's recommendations for federal officials and lawmakers include:

• Giving colleges solid guidance on developing an accurate cost of attendance for students and outlining financial administrators' authority to help students who are struggling to access their personal, parental, or spouse information when filling out the FAFSA.
• Providing colleges with flexibility around verifying student identity, given that incarcerated students sometimes struggle to access their external identification documents.
• Setting up standard guides and fact sheets that colleges can give students.
• Collecting data on how different corrections agencies are choosing students for prison education programs.
• Making sure that incarcerated students who have loans in default can still take part in the Fresh Start program, which helps borrowers with federal student loans that are in default to regain student aid.

Department of Education officials should pay attention to ensuring that students aren't affected by outside factors, like being moved to a new facility, according to the report. Illness, quarantine, facility maintenance, and a host of other external factors can "have an extreme impact" on students who are incarcerated, according to the report.

Some students were forced to withdraw from the Second Chance Pell program after being transferred to a different prison over the availability of beds, the working group wrote.

"When a student is moved to a different facility in the middle of a term, or even before they complete their program, their grades, progress toward completion, and future aid eligibility may be negatively affected," the report reads.

The Department of Education should work to allow prison education programs to have the authority to ask state corrections agencies to hold students in place so they can finish out their education or at least finish their courses, the working group recommended, and ensure that a student can continue their enrollment at a new facility if a move is needed.

What Institutions Should Consider

Communication and a strong game plan for prison education programs will be key for success, the working group wrote. The report notes that financial aid offices should play an important role early on and have a voice in program development.

"By including the institution's financial aid experts in the process, implementation problems can be avoided," the report reads. "This will also ensure that Title IV compliance requirements are clear to all institutional stakeholders. Developing lines of communication among all stakeholders within the institution, prior to bringing in third parties such as prisons or state agencies, is critical."

Higher education institutions should also clearly assign responsibilities among their departments for the new programs to avoid unnecessary overlaps and set up policies for students who aren't eligible for the restored Pell Grants, the report reads.

Creating a clear cost of attendance model for students is also important, the working group wrote, and colleges should create "simple, standardized" charges to cover course materials and eliminate fees that don't apply to students who are incarcerated.

Colleges will also need to set up a strategy to make sure students have access to information on course offerings and financial aid, whether through workshops or other means, the working group wrote.

Similar to how education officials and lawmakers need to consider how students are affected by circumstances beyond their control, colleges will need to support students withdrawing from courses.

The report recommends that colleges educate students about the impact that withdrawing from a course could have on their current and future eligibility for prison education programs, and look at ways to support students who are withdrawing due to external factors like being transferred to another facility.

"If a student is switched to another facility, it is important to communicate with the transferring institution so that academic transcript is shared — along with providing an opportunity for a Leave of Absence (LOA) type of option for the student," the report reads.

What the NASFAA Can Do

The working group also released recommendations for the NASFAA, largely centering around providing assistance and training to college staff involved in prison education programs.

The working group said the NASFAA should work to "establish the financial aid community as a knowledgeable, engaged part of the prison education community that is regarded as the premier source of expertise for those with questions on financial aid for incarcerated students."

Partnering with national associations that focus on prison education, as well as supporting state-level groups that are looking to include incarcerated students in more localized financial aid programs, will also be important as prison education programs roll out, according to the report.