The U.S. Department of Education (ED) released an electronic announcement on January 30 that provided updates to the student aid index (SAI) and the expected receipt date of Institutional Student Information Records (ISIRs). Because the release of the 2024–25 Free Application for Federal Student Aid (FAFSA) shifted last year from October 1 to December 31, 2023, financial aid administrators and state financial aid directors will experience a corresponding delay in the receipt of ISIRs for processing and awarding state and institutional financial aid.
Whereas ISIRs were initially anticipated to begin arriving at institutions and state agencies in late January, the timeline for receipt has shifted to March 2024. The reason for this additional delay is a correction ED made to income protection allowance (IPA) tables, which were inadvertently not adjusted for inflation for the 2024–25 calculations. While the changes to the tables are critical for ensuring that students receive all the financial aid for which they are eligible, these corrections create additional challenges for financial aid administrators.
The January 30 electronic announcement indicated that ISIRs will begin arriving in batches in the first half of March 2024, with the majority of ISIR transmissions occurring in the subsequent weeks. Institutions and state agencies should anticipate receiving most of their ISIRs by late March or early April.
The timeline for FAFSA submission statistics — which are important for ensuring that states are on-track for meeting targeted FAFSA completion rates — will be equally delayed. Completion data will likely become available in mid-March as institutions and state agencies begin receiving ISIRs.
The delay in receiving ISIRs and FAFSA completion data presents a significant challenge for state agencies, which are responsible for administering state financial aid programs and monitoring state-wide FAFSA completion rates. State agencies will not be able to process and award state grants until they begin receiving ISIRs. For first-come, first-served grant programs, state agencies may begin to award grants immediately upon receiving the first batch of ISIRs. For grant programs that consider the pool of applicants before administering awards, the delay in receiving ISIRs pushes their award timeline further into the spring or summer. This delay in award processing can impact students’ enrollment decisions, as many students consider financial aid packages in the college choice process.
The number and rate of FAFSA completions is also an important metric for state agencies that will be delayed. Many states have targeted completion rates, aiming to meet and exceed completion rates from prior years. State agencies regularly monitor these completion rates to determine whether additional advertising and informational campaigns to promote FAFSA completion are warranted. The delay in receiving completion information compresses the timeline for efforts to promote completion.
Strategies for minimizing the impact of the delay in receiving ISIRs and FAFSA completion rates include:
· Ensuring software is up to date and prepared to handle the incoming ISIRs (using the 2024–25 ISIR Guide).
· Communicating the possibility of delays in award processing to students and their families through school counselors and social media.
· Reassuring students and their families that the delay in processing will not impact their final award amounts.
· Continuing to hold and promote regular FAFSA completion events (even without FAFSA completion data).
· Delaying May 1 institutional deadlines for students to make enrollment decisions (as recommended by a coalition of higher education organizations).
· Shifting state financial aid application deadlines to allow students additional time to complete the FAFSA.
The January 30 electronic announcement also indicated that ED has made corrections to the IPA tables that were incorrectly not adjusted for inflation for the 2024–25 academic year. The final SAI and Pell Grant eligibility guide provides these new IPA tables, along with adjusted asset protection allowance tables.
Students currently completing the FAFSA receive an email confirmation of their submission, along with an estimated SAI. This SAI has to date been based on the incorrect IPA tables. Reprocessing of the incorrect SAI will occur automatically for all students with no action on their part or the part of the institution. It is unclear from the electronic announcement when the estimated SAI arriving via email will reflect the updated IPA tables.
The adjustment to the IPA tables increases the amount of income that is protected from the SAI calculation, effectively lowering a student’s income and decreasing the value of their SAI. However, the final SAI guidance also eliminates all asset protection allowances, which may have the impact of increasing a student’s SAI. Most students with negative or zero SAI values will not be impacted by either of these changes. Some students who were previously ineligible for Pell Grants may become eligible, and some students may see increases in their Pell Grant awards.
