Connecting College Students with Public Benefits: A New Era of Outreach
Written by: Bryce McKibben, Senior Director of Policy and Advocacy at The Hope Center at Temple University
Good news has finally arrived for cash-strapped college students, millions of whom are experiencing basic needs insecurity. The U.S. Department of Education (ED) has released new guidance (GENERAL-24–93) explaining how state grant agencies, and colleges and universities, can use data already at their fingertips to reach out to students about public benefits.
By leveraging data from the Free Application for Federal Student Aid (FAFSA), states can now more effectively identify students and families who might qualify for vital programs that can improve their financial security. These include means-tested benefit programs such as:
· Health insurance subsidies under the Affordable Care Act
· Medicaid
· Child Tax Credit
· Earned Income Tax Credit (EITC)
· Federal housing assistance under “Section 8”
· Special Supplemental Nutrition Program for Women, Infants, and Children (WIC)
· Supplemental Nutrition Assistance Program (SNAP)
· Supplemental Security Income (SSI)
· Temporary Assistance for Needy Families (TANF)
Other means-tested benefits can be included in outreach to students, too, if the eligibility for the program includes an income or asset threshold (in other words, a “means test”). For example, states could send students information on:
· Child Care and Development Fund (also known as the Child Care and Development Block Grant)
· Children’s Health Insurance Program (CHIP)
· Low Income Home Energy Assistance Program (LIHEAP)
· Some free and reduced-price school lunch programs (where a means test is used to determine eligibility)
· Unemployment insurance
· Transit or broadband subsidies
· American Opportunity Tax Credit and Lifetime Learning Credit
State grant agencies can identify the relevant programs, design effective outreach campaigns, and send direct notices to students about benefits. States can also serve as intermediaries to facilitate outreach through colleges and universities.
This is a game-changer. For too long, eligible students have missed out on valuable public benefits simply because they didn’t know how to apply or presumed they wouldn’t qualify. Just this month, the Government Accountability Office found that two-thirds of students potentially eligible for food assistance under SNAP weren’t participating in the program, including 59% of students who had low or very low food security.
Student basic needs insecurity is rampant — with 4.3 million students experiencing food insecurity and 1.5 million experiencing homelessness. These students need all the financial support they can get, and public and tax benefits can help.
Rules for public and tax benefit programs remain alarmingly complex — and should be overhauled by Congress and maximized by states wherever possible. But this new federal guidance gives states and institutions alike a roadmap to connect students with essential resources as they exist today.
The data also show that outreach works. A 2022 study in California showed that outreach worked to increase students’ application for the state’s SNAP program.
FAFSA data can be securely and legally used to identify students needing help finding out about available support. These data points include information such as:
· Email address and phone number
· Pell Grant eligibility
· Student Aid Index (SAI)
· Dependency status, including status as an independent with dependents (e.g. parenting student);
· Demographic information; and
· Public and tax benefits students or parents are already receiving
Students who have an SAI of between 0 and -1500 are especially likely to have fewer financial resources and be more likely to qualify for public and tax benefit programs. States should consider informing these students with low incomes of the supports that may be available to help them meet their cost of attendance and succeed in college.
Targeted outreach could include a wide range of mediums — including sending customized emails, text messages, letters, postcards, and messages in student portals. It could also include supplemental information within students’ financial aid offers, to give them more context about the resources available to help them meet the cost of attendance and any unmet need. Ideally, students will most likely see the outreach if they receive it in multiple formats and more than once.
The FAFSA already asks students and their families whether anyone in their household received public benefits, including programs like SNAP, WIC, Medicaid, and TANF (see below). Outreach could be customized based on the answers to this FAFSA question. For example, if a student checked that they were receiving Medicaid but not SNAP, they could receive a note encouraging them to explore food assistance, too — or reach out to the relevant state or local agency contact if they need help maintaining their Medicaid coverage.
A state might choose to conduct customized outreach on health insurance options like Medicaid and low-cost ACA marketplace plans during “open enrollment” periods, while prioritizing notices on food and housing earlier in the academic year. Or, a state might choose to conduct outreach on tax benefits (EITC, CTC, AOTC, LLC, etc.) during tax filing season.
Why is this new? The new guidance released in July 2024 is the most comprehensive set of instructions on how to conduct means-tested benefits outreach to date. Beginning in January 2022, ED issued guidance to financial aid administrators encouraging colleges and universities to use FAFSA data for outreach on public benefits. But many of the programs listed in that guidance have since expired due to the end of the pandemic’s public health emergency period. State grant agencies were also conspicuously absent from any mention in that 2022 guidance — leaving many unsure of whether states, or only institutions, could conduct the outreach.
Additionally, data-use restrictions have been tightened under the FAFSA Simplification Act and FUTURE Act, especially for Federal Taxpayer Information (FTI), such as Adjusted Gross Income. Both states and institutions have been looking for more assurance that using FAFSA data for public benefits outreach remains permissible. This new guidance provides the certainty states need to begin targeted outreach.
While states cannot use FTI for outreach purposes without the applicant’s consent, the proactive use of FAFSA data for targeted outreach to students about public benefits is not restricted; it fits squarely within federal law. Additional student-level data obtained directly by states and institutions through enrollment or admissions (and outside the FAFSA) and financial aid award amounts could also be used to target outreach; these data might include unmet need, Pell or FWS award levels, or parenting student status where it is collected.
States and institutions can also go beyond outreach by developing processes for applicants to provide consent to redisclose their FAFSA data and FTI to federal, state, and local government entities for the purpose of determining eligibility and enrolling in benefits. (Note: Federal Student Aid Conducted a webinar on July 24, 2024, explaining some of the differences between what is considered FAFSA data and FTI).
Why should states and colleges care about this new guidance? The benefits of public and tax benefits outreach are far-reaching. When students have access to basic needs like food and housing, they are better able to focus on their studies, leading to higher retention and graduation rates and better job outcomes. States and institutions will save on instructional and other operating funds that are otherwise spent on students who aren’t able to complete a degree or credential or who eventually re-enroll but have to retake coursework and tap more state aid.
A more educated and economically mobile workforce benefits every state — and results in higher tax revenues. And states are well-positioned to conduct this outreach rather than relying on individual institutions.
States benefit from economies of scale that individual institutions don’t have, allowing them to reach more students and ensure they hear about essential programs regardless of where they enroll. States can also assign experts familiar with state rules in public benefit programs to help design outreach language, including the best times and strategies to apply, rather than relying on campus-level administrators to learn the nuances of state programs they don’t usually handle on a routine basis.
Additionally, a recent study showed that about three-quarters of financial aid administrators had not conducted any outreach to students about public benefits, and more than 4 in 10 said they had no plans to do so. State grant agencies can help fill that gap where institutional resources and expertise may be stretched thin.
Imagine systems of higher education where students aren’t worried about where their next meal is coming from or if they have a safe place to sleep. It’s a vision for a higher education system that genuinely supports working people in obtaining economic mobility.
The Department’s new guidance opens more possibilities to help students succeed. By embracing this opportunity to connect students with public benefits, states, and colleges can take a significant step toward making that vision a reality. Consider starting a conversation in your state today to take advantage of this new era in public benefits outreach.
Bryce McKibben is the Senior Director of Policy and Advocacy at The Hope Center at Temple University. He previously served as Senior Policy Advisor on the U.S. Senate Health, Education, Labor, and Pensions Committee.
