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Keeping it Simple: Impact of FAFSA Simplification on Federal and State Student Aid Eligibility SHEEO August 2011

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Keeping it Simple: Impact of FAFSA

Simplification on Federal and State Student Aid Eligibility

SHEEOAugust 2011

Current Federal and State Issues

Pell Grant program expenditures have doubled since 2008-09Increases not sustainable

Federal budget deficit threatens cuts in Pell Grant and other federal aid programsStudent loan subsidiesCampus-based aid

Economic downturn has resulted in cuts in state funding to higher education and to need-based grants

President Obama has set a goal for increasing college completion by 2020

Early Awareness and Simplicity

An effective federal and state student aid system is key to meeting college completion goals

The current student aid system is complex (process and programs)

Low- and moderate-income students are more likely to prepare academically if they understand financial aid

A simple, predictable, well-targeted student aid system will lead to more efficient use of taxpayer dollars

College Board’s Rethinking Student Aid (RSA) recommendations are based on this premise

Simplification: Progress to Date

HR 3221 passed but never considered by SenateOnly data available from IRS used to determine

federal aid eligibility; families with assets above legislated cap ineligible for federal aid

Similar proposal in President Obama’s FY 2012 budget

Administration committed to further FAFSA simplification

State Need-Based Aid Study

Goals of studyHelp states understand impact of a simplified

federal aid process on state grant programs• Support institutions’ ability to plan for a simpler FAFSA

Build state support for a simplified process to ensure that students will benefit• Evidence about benefits of simplifying the application

and increasing predictability of grant aid is compellingHelp states advocate for a streamlined system

that will enable them to distribute need-based aid equitably and efficiently• May require changes to underlying Federal Methodology

Our Approach

Selected a representative group of pilot states based on criteria for eligibility & aid determinationKentuckyMinnesotaOhioTexasVermont

Using state’s 2007-08 or 2008-09 FAFSA and award data, simulated impact of potential federal data and formula changes on state grant awards

Our Methodology: Multiple Simulations

1. Remove Worksheet A items (new baseline for comparison) — previously eliminated in 2009-10 FM

2. Eliminate all assets3. Eliminate untaxed income and income

adjustments (Worksheets B and C items)

4. Use only IRS data (similar to HR 3221 language)• No employment allowance• FICA based on AGI/total earnings• IRS data included AGI, taxes paid, number of exemptions

Reviewing the Results

Focus today on 2 statesMinnesota (Shared Responsibility Model)Kentucky (EFC cut-off, first come/first-served)

Ohio completed but results more complexLimited data make results difficult to compare to other

statesVermont process very different from other 4

statesRequires additional application formConsiders asset data, noncustodial parent financial

informationAnalysis of Texas data incomplete

Impact of Removing Assets on EFC

Average EFCs decline for all applicantsLargest declines among dependent applicants from

highest income households (more likely to have significant assets)In MN dependent students from families with incomes > $75K

would see average EFC decreases of $2,540 (10%); similar results in KY

In MN dependent students from families with incomes between $45K and $60K would see average EFC decreases of $530; in KY average EFCs for this group decline by $636

Lowest income students (incomes below $30K) would see average declines in EFC < $200 in both states

Small decreases in EFC for independent studentsUnlikely to have significant assets; little impact when assets

removed

klittle
Review this slide against state reports

Impact of Removing Assets on State Grants and Pell GrantsMinimal impact on average state grant in MN,

OH, KYTargeted at students from low- and moderate-income

backgrounds who are less likely to have significant assets

MN: average grant would increase by $10 per applicant; total expenditures by $1M or .6% (Shared Responsibility model)

KY: eligibility would increase on average by $27; total expenditures by $2.9 million or 3% (if program were fully funded)

More significant increases to average Pell Grant in both states ($87 per filer in MN and KY)

Using Only IRS Data: Impact on Dependent Filers

Average EFCs would decline for most applicants Largest impact among those from higher income families; more likely to have

complex financial situations In MN, average decrease in EFC of $3,323 for FAFSA filers with family income

> $75,000; $2,569 drop in KY In MN, average EFC declines by about $600 for filers with family income

between $45K and $60K; by about $750 in KY In MN average decrease in EFC of about $300 for lowest-income (< $30K);

similar pattern in KY Small impact on Pell Grants and state grants which are targeted at

students from lower income backgrounds MN: Average Pell Grant per filer would increase by $23; average state grant

would decrease by $6 KY: Average Pell Grant would increase by $47; average state grant eligibility

would increase by $22 Institutional need would increase significantly, particularly at

institutions that award need-based aid to higher income applicants

Using Only IRS Data: Impact on Independent FilersIndependent students without dependents

Average EFCs would decrease modestly: in MN by $323 on average, in KY by $46 on average

Small increases in Pell and state grants for lowest income filers, but small decreases for those with higher incomes

Independent students with dependents Average EFCs would increase for all but lowest income

filers as a result of elimination of employment allowanceIn MN EFCs would increase by $70 on average; in KY

average EFCs would increase by $15; slight EFC decreases for lowest-income filers in both states

Small decreases in Pell and state grants as a result of EFC increases

Additional Modeling Activities

White House Council of Economic Advisers (CEA)National ISIR sampleSimulated impact of HR 3221 on Pell GrantsSegmented results by state to support College

Board study• Small samples for most states• Income distribution based on sample

• State tax allowance based on national average (2-3%) • Simulated impact on EFC, PC and Pell for families with

EFCs below $25,000

What We Learned from CEA Model

National analysis using only IRS data

Dependent students

• 61% change in Pell Grant < $250

• 36% increase > $250

Independent students

• 90% change in Pell Grant < $250

Average EFC Changes: MinnesotaAGI % of FAFSA

Apps in MN (Total = 100%)

Mean “Old”

EFC

Mean “New”

EFC

% with EFC Decreases >

$2000

% with EFC Decreases >

$1000

% with EFC Decreases

$500 - $1000

% with EFC Decreases

$200 - $500

% with EFC change within

+/- $200

% with EFC Increases

$200 - $500

% with EFC Increases

$500 - $1000

% with EFC increases >

$1,000

% with EFC increases >

$2,000

Net change in

EFC

Panel A: Dependent StudentsAll 100.0 11,079 10,042 18 10 9 6 34 6 9 7 2 (1036.69)<$0 0.8 1,555 160 12 4 5 6 73 - 0 - 0 (1395.08)$0 to $9,999 6.0 220 80 1 1 1 1 96 0 0 0 0 (139.47)$10,000 to $19,999 5.7 416 201 2 1 2 2 91 1 1 0 0 (214.73)$20,000 to $29,999 7.2 1,969 1,502 6 7 14 11 39 8 13 1 0 (467.03)$30,000 to $39,999 8.2 3,326 2,550 10 13 19 10 20 10 15 3 1 (775.79)$40,000 to $49,999 8.5 5,109 4,081 15 16 15 8 14 10 14 7 1 (1027.43)$50,000 to $59,999 8.1 7,379 6,065 20 14 11 8 12 8 12 11 2 (1314.29)$60,000 to $69,999 8.4 9,858 8,569 23 12 9 6 12 7 12 15 4 (1289.08)$70,000 to $79,999 7.9 12,587 11,209 26 12 9 6 11 7 11 14 4 (1378.44)$80,000 to $89,999 8.2 15,277 13,848 28 12 9 6 12 6 10 13 4 (1428.27)$90,000 to $99,999 7.8 17,671 16,117 32 14 9 5 13 6 9 10 3 (1553.60)$100,000 to $124,999 10.3 20,232 18,904 25 13 9 5 33 4 6 4 1 (1327.59)$125,000 to 149,999 5.5 22,205 20,969 22 8 5 2 59 2 2 0 0 (1236.65)$150,000 to $199,999 4.3 23,870 22,774 22 8 4 2 62 1 1 0 0 (1095.76)$200,000 or more 3.2 24,858 24,655 4 2 1 1 93 0 0 0 0 (203.17)

Minimizing the Impact of Fewer Data ElementsMake modest changes to the underlying

need analysis formula Achieve EFC results closer to current level while

simplifying the application for studentsModeled impact of changing the adjusted

available income assessment ratesParameters in current system are arbitrary and

not based on economic research• Increase marginal tax rates by 3% • Modify Adjusted Available Income (AAI) bands

Achieved EFC levels similar to those in effect in 2007-08

2007-08 FM AAI Assessment Rates

Adjusted Available Income (AAI) Assessment Rate Applied to AAI

Less than -$3,409 -$750 -$3,409 to $13,400 22% of AAI $13,401 to $16,800 $2,948 + 25% of AAI over $13,400

$16,801 to $20,200 $3,798 + 29% of AAI over $16,800

$20,201 to $23,700 $4,784 + 34% of AAI over $20,200

$23,701 to $27,100 $5,974 + 40% of AAI over $23,700

$27,101 or more $7,334 + 47% of AAI over $27,100

Minimizing the Impact of Fewer Data ElementsIf only IRS data were used to determine

federal aid eligibility, why couldn’t more detailed IRS data be provided to institutions and perhaps to states?Identify tax filers with negative AGIImpute assets based on interest and dividend

incomeCreate more effective need analysis system

than exists todayModel still under review, but opens up possibilitiesWould require support from Administration and

perhaps legislation

Policy Considerations

Given the evidence related to the effect of a simpler student aid system on increasing enrollment and graduation rates among low-income students, would states and institutions support a move to a system based only on IRS data?

Would states and institutions be supportive of modifications to the federal need analysis system to reduce impact of less federal data?

Would states and institutions support a proposal to develop a new need analysis formula that relied on more detailed IRS data?

We’re Interested in Hearing From You

Sandy [email protected]

Kathie [email protected]