A new report from the education advocacy nonprofit EdTrust is urging states across the nation to implement universal Free Application for Federal Student Aid (FAFSA) completion policies, arguing that such mandates are crucial to ensuring students access the full spectrum of financial aid available for higher education. The report, which examines the successes and challenges of universal FAFSA policies in Colorado, Illinois, Indiana, and Louisiana, highlights that billions of dollars in federal grants and loans remain unclaimed annually due to low completion rates, often stemming from the form’s perceived complexity and lack of widespread understanding.
The FAFSA is the gateway to federal financial aid, including Pell Grants, federal student loans, and work-study programs, and often serves as a prerequisite for state and institutional aid as well. Despite ongoing efforts to simplify the application process, its intricate nature and the sensitive financial information required can present a significant barrier for many students and their families, particularly those from low-income backgrounds or who are the first in their families to pursue higher education. EdTrust’s analysis underscores that students who successfully complete the FAFSA are demonstrably more likely to graduate high school, enroll in college, and ultimately earn a degree, directly linking FAFSA completion to improved educational attainment and future economic mobility.
The Rise of Universal FAFSA Policies
As of the latest data, 14 states have adopted policies requiring or strongly encouraging universal FAFSA completion, with nine of these policies currently in effect. These initiatives represent a growing recognition among state policymakers of the critical role FAFSA plays in college access and affordability. The goal is to proactively address the financial hurdles that often prevent students from pursuing post-secondary education.
Key Examples of State Approaches:
- Illinois: Has integrated FAFSA completion as a mandatory graduation requirement for high school students. This policy aims to ensure every student engages with the financial aid application process before leaving secondary education.
- Indiana: Similar to Illinois, Indiana has established a requirement for high school seniors to complete the FAFSA. This measure is designed to maximize the number of students applying for aid as they transition to college.
- Colorado: Implemented a competitive grant program, known as "Fund My Future," that incentivizes school districts to require students to complete the FAFSA or a state aid form for graduation. This approach uses financial incentives to drive adoption of FAFSA completion policies at the local level.
All three of these states have incorporated opt-out provisions within their policies, allowing students or their families to decline completion under certain circumstances, typically requiring a written waiver. This approach balances the imperative of universal access with individual autonomy.
Setbacks and Challenges in Implementation
While the trend towards universal FAFSA policies is positive, the path has not been without its obstacles. Louisiana, which was a pioneer in adopting a FAFSA completion policy in 2018, has since repealed its mandate. This decision was largely driven by privacy concerns, with some parents expressing unease about being required to submit sensitive tax information as part of the application process. New Hampshire has also rescinded its FAFSA completion policy, indicating that the implementation of such mandates requires careful consideration of constituent feedback and potential unintended consequences.
These instances highlight the delicate balance states must strike between ensuring students receive the aid they are entitled to and respecting family privacy and administrative burdens. The complexity of financial aid applications, coupled with varying levels of digital literacy and access to resources, can create friction points that necessitate robust support systems and clear communication strategies.
The Unclaimed Billions: A Persistent Problem
Despite the increasing number of states implementing universal FAFSA policies and a generally strong FAFSA completion rate for the 2026-27 academic year—with 5.78 million students having submitted the form by December 31st, according to federal data—financial aid experts contend that a substantial amount of aid remains on the table. The EdTrust report vividly describes this as "billions of dollars" in financial aid that students and families are missing out on.
Mark Kantrowitz, a prominent financial aid expert, emphasized the profound impact of FAFSA completion on educational outcomes. "This is a very important issue because students who complete the FAFSA are more likely to graduate high school, more likely to enroll in college and more likely to graduate from college," Kantrowitz stated. He further elaborated on the direct correlation between financial aid and college persistence, noting, "The No. 1 reason people drop out of college is because of money. If you get the financial aid, you’re more likely to at the very least be able to afford college if you decide to go." This underscores that financial aid is not merely an optional supplement but often a critical determinant of whether a student can even begin or continue their higher education journey.
A Collective Responsibility for FAFSA Completion
Kyla Hurns, a higher education policy analyst at EdTrust and a co-author of the report, stressed the need for a shared commitment from various stakeholders to elevate FAFSA completion rates. "It’s less about it being solely on one person, but making sure it’s an entire ecosystem of people supporting the [FAFSA completion] requirement and supporting the policy to make sure that you’re able to essentially meet students at all possible avenues," Hurns explained. This "ecosystem" approach involves collaboration among policymakers, educational institutions, community organizations, and families.
The EdTrust report’s primary recommendation centers on the allocation of dedicated funding. This funding is envisioned to support a crucial element often overlooked in mandate-driven policies: the personnel necessary to assist students. Specifically, the report advocates for funding to:
- Hire and support financial aid specialists: These professionals would be tasked with the direct work of helping students navigate the FAFSA application process.
- Conduct targeted outreach: Proactive communication and information dissemination are essential to inform students and families about the importance of FAFSA and the resources available to help them complete it.
- Develop data dashboards: These tools would enable officials to monitor FAFSA completion progress in real-time, allowing for timely interventions and adjustments to strategies.
The Challenge of Unfunded Mandates and Resource Allocation
The implementation of universal FAFSA policies, particularly when framed as graduation requirements, has often been characterized by educators and state officials as an "unfunded mandate." This designation highlights a critical disconnect: states may require an action without providing the necessary financial resources to support its successful execution.
In Illinois, for instance, the 2019 law making FAFSA completion a graduation requirement was initially met with concerns about funding. However, the state leverages the Illinois Student Assistance Corps (ISACorps), a program comprising college access advisers embedded in high schools and community settings. ISACorps, overseen by the Illinois Student Assistance Commission, a state-funded agency, plays a vital role in assisting students with FAFSA completion. The EdTrust report notes that Illinois appropriated $7.8 million for ISACorps in fiscal year 2025, demonstrating a state-level investment in supporting the mandate.
"To be clear, in Illinois, the actual policy itself is unfunded," Hurns clarified, adding that the existence of ISACorps provided "a funded way for them to send in bodies to help." This distinction is crucial: while the policy itself might not carry a direct appropriation, the state has established a funded mechanism to facilitate compliance. This model offers a potential blueprint for other states looking to implement similar requirements.
The Strain on School Counselors
A significant challenge identified in the EdTrust report is the disproportionate burden placed on school counselors. These professionals, already managing demanding caseloads that often include crisis intervention, mental health support, and academic advising, are frequently expected to also guide students through the intricacies of FAFSA completion. This can stretch their capacity to the breaking point.
One Illinois school counselor, quoted in the report, expressed frustration that the state had "added way too much to the plate of school counselors" without correspondingly reducing student-to-counselor ratios or increasing staffing. This situation can lead to increased stress and burnout among counselors, particularly when families require intensive support due to complex financial or familial circumstances. The report notes that "In some states, this has led to heightened stress and burnout, particularly as some families require intensive support to navigate complex financial and familial situations."
Expertise and Dedicated Support Remain Crucial
While the FAFSA has undergone successive simplifications over the years, Mark Kantrowitz maintains that completing the form still demands a level of financial aid expertise that not all students and families possess. He echoed EdTrust’s call for dedicated funding, advocating for resources to support personnel who can assist outside of regular school hours or organize special events focused on FAFSA completion.
"I don’t think you could categorize it as absolutely essential," Kantrowitz said, referring to the need for dedicated personnel, "But it’s certainly helpful." This nuanced perspective acknowledges that while universal FAFSA policies are a powerful tool, their effectiveness is significantly amplified by accessible, expert assistance. The availability of trained individuals to demystify the application process, address individual concerns, and ensure accurate completion is paramount to unlocking the full potential of these policies.
The broader implications of increasing FAFSA completion rates extend beyond individual financial aid awards. Higher college enrollment and graduation rates contribute to a more educated workforce, enhanced economic productivity, and reduced societal inequalities. By prioritizing policies that facilitate FAFSA completion and ensuring adequate resources are allocated to support these efforts, states can make a tangible difference in the lives of countless students and contribute to a more equitable future for higher education. The EdTrust report serves as a critical call to action for policymakers to move beyond mandates and invest in the infrastructure and human capital necessary to ensure that every eligible student can access the financial support they need to pursue their educational dreams.




