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2014-2015 Federal Student Aid Application Comments Tracking Summary 

(30 Day draft)

Comment Status Resolution

1 Q.45j “Money received, or paid on your behalf (e.g., bills), not 

reported elsewhere on this form. This includes money that you 

received from a non-custodial parent whose information is not 

reported on this form that is not part of a legal child support 

agreement. See Notes page 2.”

By expanding the scope to include any parent whose 

information is not reported on the FAFSA, this question would 

encompass financial support from parents given to independent 

students, which should also be included.

Resolved Question 45j will be revised to read: “Money 

received, or paid on your behalf (e.g., bills), not 

reported elsewhere on this form. This includes 

money that you received from a parent whose 

financial information is not reported on this form 

and that is not part of a legal child support 

agreement. See Notes page 2.”

2 The question about having a bachelors degree before July 1, 

2014, is too vague and then also too specific.

The question says "Will you have your first bachelors degree". I 

think it should read "Will you have completed your first 

bachelors degree". Then it gives a date of July 1st, 2014. But 

many schools have summer semesters that a student could be 

completing their Bachelors requirements in, and have a 

bachelors degree completed before the new school year begins. 

Shouldn't it say prior to the start of the 2014-15 school year? So, 

all in all, my thought is that the question should read:

"Will you have completed your first Bachelors degree prior to 

the start of the 2014-2015 school year?" Then in the 

instructions, tell the student that they should contact the school 

for that student's start date for the school year.

Resolved. FAFSA on the Web Help text will be updated to 

clarify this information for applicants. The FAFSA 

on the Web Help topic “Am I eligible to receive 

financial aid?” will read:

“Many types of federal student aid, such as the 

Federal Pell Grant or subsidized loans where the 

government pays the interest while you are in 

college, also require you to have financial need. 

Additionally, once you have a bachelor’s degree 

or a first professional degree, you are generally 

not eligible for Pell or Federal Supplemental 

Educational Opportunity Grants (FSEOG). 

Other requirements may apply. Contact the 

financial aid office at your college for more 

information.”
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Comment Status Resolution

3 Regarding Revised the "Notes for questions 42 and 43 (page 4), 

45j (page 5), and 91 and 92 (page 7)," it states, "Investments 

include real estate (do not include the home you live in), rental 

property . . ."

To avoid a hanging participle, I would suggest you change the 

wording, "do not include the home you live in" to "do not 

include the home in which you live."

Resolved. The Notes for questions 42 and 43 (page 4), 45j 

(page 5), and 91 and 92 (page 7) will be revised 

to read: “Investments include real estate (do 

not include the home in which you live), rental 

property (includes a unit within a family home 

that has its own entrance, kitchen, and bath 

rented to someone other than a family member), 

trust funds, UGMA and UTMA accounts, money 

market funds, mutual funds, certificates of 

deposit, stocks, stock options, bonds, other 

securities, installment and land sale contracts 

(including mortgages held), commodities, etc.”

4 In FAFSA instruction "Notes for Step Four, Questions 59-64....", 

the first bullet note should be changed as needed to ensure 

proper context around the topics involved.

Current wording: "If your parent was never married or is 

widowed and does not live with your other legal parent, answer 

the questions about that parent."

Suggested wording: "If your parent was never married and does 

not live with your other legal parent, or if your parent is 

widowed and not remarried, answer the question about that 

parent."

Resolved. The first bullet under the Notes for Step Four, 

Questions 59-94 (pages 6 and 7) will be revised 

to read: "If your parent was never married and 

does not live with your other legal parent, or if 

your parent is widowed and not remarried, 

answer the question about that parent."

5 I believe that there needs to be a clarification in the FAFSA with 

respect to question 59 (parent's marital status). According to 

Dear Colleague letter GEN-13-12, dependent students whose 

biological parents live together are required to include both 

parent’s information regardless of marital status. Every year, we 

get a number of students whose parents are either divorced or 

legally separated that still live together. It’s clear that if the 

parents are divorced, yet still live in the same household, they 

Resolved. The third bullet under the Notes for Step Four, 

Questions 59-94 (pages 6 and 7), will be revised 

to read: “If your parents are married, select 

“Married or remarried.” Consistent with the 

Supreme Court decision holding Section 3 of the 

Defense of Marriage Act (DOMA) 

unconstitutional, same-sex couples must report 

their marital status as married if they were 
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Comment Status Resolution

should file with the new “Unmarried and both parents living 

together” status, as the instructions explicitly point out. 

However, it’s not at all clear what they should do if they are 

legally separated, but still live in the same household. Using the 

new status wouldn’t be correct, as they are still married, but if 

they choose the “separated/divorced” category, then only 1 

parent’s information will be accepted by the FAFSA on the Web 

logic. Married would seem to be the most correct choice, but 

the way the choices are labeled, and the way the instructions 

are worded, I don't believe most people in this situation would 

use this. I believe that it would be clearer to include a sentence 

in the "Married" section of the instructions to indicate that 

persons in this situation should use this category, such as: "If 

your legal parents are legally separated but living together, 

select “Married”, not "Divorced or Separated".

legally married in a state or other jurisdiction 

(foreign country) that permits same-sex 

marriage, without regard to where the couple 

resides. If your legal parents are divorced but 

living together, select “Unmarried and both 

parents living together.” If your legal parents are 

separated but living together, select “Married or 

remarried,” not “Divorced or separated.”

6 There should be notes/additional clarification for questions #74 

and #96 (reporting the number of family members in college), to 

state that certain military academies as well as certain foreign 

colleges and universities should not be included. Ideally, families 

should be be provided a link to the list of eligible Title IV 

institutions that may be counted.

Resolved. FAFSA on the Web help text will be revised for 

both the parent and the student to include this 

information.

The parent help topic will read: “Enter the 

number of people in your parents’ household 

who will attend college between July 1, 2014 and 

June 30, 2015. 

Include:

•Yourself, even if you will attend college less 

than half-time in 2014-2015.

•Other people in your parents’ household only if 

they will attend college at least half-time in 

2014-2015, in a program that leads to a college 

degree or certificate.
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Comment Status Resolution

Do not include:

•Your parents, even if they are enrolled at least 

half-time in 2014-2015 in a program leading to a 

degree or a certificate.

•Students at a U.S. service academy, because 

most of their primary educational expenses are 

paid for by the federal government.”

The student help topic will read: “You must 

enter the number of people in your household 

who will attend college between July 1, 2014 and 

June 30, 2015.

Include:

•Yourself even if you will attend college less than 

half-time in 2014-2015.

•Other people in your household only if they will 

attend college at least half time in 2014-2015, in 

a program that leads to a college degree or 

certificate.

Do not include:

•Students at a U.S. service academy, because 

most of their primary educational expenses are 

paid for by the federal government.”

7 Question 28 poses a problem with students earning their 

bachelor's degree in the Fall. The question asks the student if 

they will earn a bachelor's before July 1, 2014, but makes no 

consideration that the student could get their bachelor's just 

afterwards like in December. Unless the transcripts are 

submitted a student who answers the question correctly but 

earns their degree in the Fall and transfers to another school to 

Resolved. Refer to comment #2 for resolution.
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Comment Status Resolution

earn some additional credit would be incorrectly paid pell. Could 

the question be worded differently or could there be a way for 

schools to know when a student has earned a bachelor's degree 

through the clearing house and on the ISIR?

8 We recommend changing this sentence in the Notes for Step 

Four section at the top of page 9:

Current wording: Additional instructions about who is 

considered a parent on this form:

Proposed wording: Review all instructions below to determine 

who is considered a parent on this form.

Resolved. The paper FAFSA will be updated to reflect this 

change.

9 a. Item # 31. on the FAFSA, I would like to suggest that you add 

the work "employment" after work-study. We believe this may 

assist in students understanding that they are to work for this 

funding.

b. For items #80 thru # 83, would it be helpful or necessary to 

indicate parent 1 and parent 2 given the new inclusion of 

unmarried parents. Also, will it make a difference as to the order 

that they complete the answer, if there are two parents for any 

verification documentation requested/submitted. 

c. Items #24 and 25, is this impacted by the new parent 

category?

a. Resolved.

No Change.

b. Resolved.

No Change.

c. Resolved.

a. This is a stylistic preference that would make 

the question redundant. The word “work” 

already indicates a form of employment.

b. Only questions 24, 25, 61-68, 88 and 89 are 

specific to one parent, and question labels were 

updated to reflect Parent 1 or Parent 2. All other 

parent questions apply to one parent or two 

parents as determined by question 59. The 

Department of Education believes that to include 

references to Parent 1 and Parent 2 in questions 

that didn’t previously reference mother or father 

would add undue burden and decrease 

readability. 

c. FAFSA question numbers 24 and 25 are 

impacted by the category and have been 

updated to read “Highest school completed by 

Parent 1” and “Highest school completed by 

Parent 2”.
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Comment Status Resolution

10 We recommend the following revisions to Step Four of the 

paper FAFSA: 

a. At the top of page 6, after the sentence that reads “Complete 

this step if you (the student) answered “No” to all questions in 

Step Three”, we recommend adding this sentence: IMPORTANT 

- Before you continue, review all Notes on page 9 to determine 

who is considered a parent on this form.

b. Errors in answering questions 80-94 when a student’s parents 

are “Unmarried and both parents living together” may be highly 

likely. Therefore, we recommend bolding (in addition to 

highlighting) the following sentence which immediately 

precedes question 80 on page 6 to emphasize the need to seek 

assistance: If your answer to question 59 was “Unmarried and 

both parents living together,” contact 1-800-4-FED-AID for 

assistance in answering questions 80-94.

a. Resolved.

No Change.

b. Resolved.

a. The Department of Education believes that 

this is repetitive. The current language reads: If 

your parent was never married, widowed, 

divorced, separated or remarried, see the Notes 

on page 9 for additional instructions.

b. The text will be bolded as recommended.

11 Q.26 General Educational Development (GED) certificate or 

state equivalent test. 

Students may not know what constitutes a state equivalent test 

in their state. We recommend further instructions directing 

them to this information.

Forwarded 

to 

Appropriate 

Business 

Unit

The Department has referred this suggestion to 

the appropriate business unit to review 

recommendations. 

12 I was recently informed by a counselor that colleges use the 

FAFSA to deny students admission or limit financial aid. The 

counselor received this information from this article: 

http://www.insidehighered.com/news/2013/10/28/collegesuse-fafsa-information-reject-students-and-potentially-lowerfinancial-aid .

Is it possible to deny colleges and universities access to the 

other colleges students list on their FAFSA? 

Forwarded 

to 

Appropriate 

Business 

Unit

The Department has referred this suggestion to 

the appropriate business unit to review 

recommendations. 
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Comment Status Resolution

13 The new answer option on parent marital status of “unmarried 

and both parents living together” should also be asked of the 

student’s marital status. It seems unfair that only dependent 

parents get put into this group while independent students do 

not. 

Resolved.

No Change.

The family contribution for a dependent student 

is defined in Section 475 of the Higher Education 

Act, as amended. For each student, the 

expected family contribution is equal to the 

parents’ contribution and throughout this 

section, the parents are referenced without 

regard to their marital status. It is the 

relationship of the dependent student to the 

parents and not the marital status that is 

significant.

14 Student 4. (Parent Instructions)

Answer all the questions in Step Four even if you do not live 

with your legal parents (your biological and/or adoptive 

parents). Grandparents, foster parents, legal guardians, aunts 

and uncles, or other people are not considered parents on this 

form unless they have legally adopted you. If your legal parents 

are married to each other or are not married to each other and 

live together, answer the questions about both of them. If you 

parent was never married or is remarried, divorced, separated 

or widowed, see Notes page 9 for additional instructions.

Added text expands the scope of who is not considered a parent 

so the instructions aren’t misinterpreted as allowing people 

other than those specifically listed to be considered a parent in 

the absence of legal adoption.

These instructions also preclude same-sex stepparents who are 

legally married to an applicant’s legal parent, but who have not 

adopted the student, from being included on the FAFSA. 

Without DOMA guidance from ED, we are unable to determine 

if this was the intent.

Resolved.

No Change.

The third bullet under the Notes for Step Four, 

questions 59-94 (pages 6 and 7) state: “If your 

parents are married, select “Married or 

remarried.” Consistent with the Supreme Court 

decision holding Section 3 of the Defense of 

Marriage Act (DOMA) unconstitutional, same-sex 

couples must report their marital status as 

married if they were legally married in a state or 

other jurisdiction (foreign country) that permits 

same-sex marriage, without regard to where the 

couple resides. If your legal parents are divorced 

but living together, select “Unmarried and both 

parents living together.” If your legal parents are 

separated but living together, select “Married or 

remarried,” not “Divorced or separated.” 

When the reported marital status is “Married or 

remarried,” information for both the parent and 

the stepparent must be reported. 
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Comment Status Resolution

15 Question 16 on the FAFSA for 14-15. Maritial Status. The 

instructions do cover the DOMA act. However, there is no 

instructions regarding people who may not be married but live 

together. There was an earlier notice that stated people who 

live together as the parent and/or student who are contributing 

to the household income should be included on the FAFSA. So, 

if, for example, two parents live together but not married and 

you want both incomes included on the FAFSA, wouldn't you 

add that in this section so we can catch in the verification 

process that they live together we will need both Tax 

transcripts. Otherwise, we would have no way of knowing this.

Resolved.

No Change

Question 16 is specific to the student applicant 

and not the parents. There is no response option 

of “Unmarried and living together” for the 

student; this response option exists only for the 

parent. There is specific guidance contained in 

bullet 2 under the “Notes for Step Four, 

questions 59-94 (pages 6 and 7)” on the paper 

FAFSA for parents who are unmarried and living 

together.

16 Could suffix be a separate field instead of included in the last 

name? This will help match ISIRs with data in enterprise 

systems.

Resolved.

No Change.

Spacing limitations prevent this from being 

included on the paper FAFSA. Each year, third 

party software providers are given Federal 

Student Aid (FSA) specifications for Institutional 

Student Information Record (ISIR) processing.

17 Instructions for 80-94

If your answer to question 59 was “Unmarried and both parents 

living together,” contact 1-800-4-FED-AID for assistance with 

answering questions 80-94.

Clear instructions should be provided on how to answer 

questions 80-94 and then if students need assistance, they can 

be directed to contact 1-800-4-FED-AID. Referring all affected 

students to 1-800-4-FED-AID upfront automatically adds 

another step for affected applicants and precludes financial aid 

administrators and other advisors from properly counseling 

applicants, since they don’t know what the guidance from 1-

800-4-FED-AID will be or if it’s accurate.

Resolved.

No Change.

The current FAFSA instructions for parents who 

are unmarried and living together state: “If your 

legal parents (biological and/or adoptive) are not 

married to each other and live together, select 

“Unmarried and both parents living together” 

and provide information about both of them

regardless of their gender. Do not include any 

person who is not married to your parent and 

who is not a legal or biological parent.

Contact 1-800-4-FED-AID for assistance in 

completing questions

80-94.” 

The instructions direct applicants to include both 

legal parents who are not married to each other, 

and to select “Unmarried and both parents living 
 Page 9 of 9 12/4/2013

Comment Status Resolution

together”. The statement to contact 800-4-FEDAID was added to assist in case applicants have 

additional questions.

18 We recommend the following revision to question 26 on page 3 

of the paper FAFSA:

Immediately following the question, "When you begin college in 

the 2014-2015 school year, what will be your high school 

completion status?", add in parentheses (“None of the above” 

means you do not have a high school diploma, GED, or 

equivalent and did not complete secondary school in a home 

school setting.)

Resolved.

No Change.

This is a stylistic preference that would make the 

response redundant.

19 Based on DCL ID: GEN-13-16 Subject: 2014-2015 Award Year: 

FAFSA Information to be Verified and Acceptable 

Documentation, and “Nontax filers-If an institution questions a 

claim that the tax filer has not, will not, and is not required to 

file a 2013 Internal Revenue Service (IRS) income tax return, the 

institution must require the applicant to submit a “Verification 

of Nonfiling” from the IRS that the tax filer did not file a 2013 

IRS income tax return. The request for “Verification of Nonfiling” 

can be obtained by the tax filer using IRS Form 4506-T and 

checking box 7. IMPORTANT: According to the IRS, a response to 

the request for a “Verification of Nonfiling” for the 2013 tax 

year will not be issued until after June 15, 2014.” In light of the 

length of time that it will take in cases where the institution 

needs the Verification of Nonfiling, it would be beneficial to the 

student and the institution if the IRS DRT could include an 

additional flag to indicate verified non-filer status. This may only 

be possible after the normal tax filing deadline of 4/15/2014, 

but would be a valuable addition.

Resolved. 

No change.

The IRS Data Retrieval Tool does not currently 

include non-tax filer information, and to explore 

the possibility of obtaining this information 

would be a collaborative effort between the IRS 

and the Department of Education. The 

Department will have conversations to explore 

this issue.