Page 1 of 28 11/9/2012

2013-2014 Federal Student Aid Application Comments Tracking Summary 

Comment Status Resolution 

1) It would be great if high school graduation date could be added 

to the FAFSA. 

We currently monitor and report to high schools the percentage 

of their seniors who have completed the FAFSA. Currently we 

know that our data is not 100% accurate because we don’t know 

for sure which of the student from their high school are truly 

seniors (versus students who graduated and took a year off, for 

example). We use date of birth to help narrow down the group, 

but that is not accurate as seniors can be anywhere from 17 years 

of age to 19 or even 20 years of age. With this additional field, 

high schools could have much more accurate information and 

focus their FAFSA completion efforts on those who have not yet 

completed the FAFSA. 

Resolved

No Change 

The High School graduation date field is not 

required for federal student aid eligibility 

determination.

2) 13-14 FAFSA on the Web Application: a) "Recently Filed Taxes" 

section - can this be a more specific period of time such as 

"Recently filed taxes within the last week" or something?

And for the “None of the Above” option, potentially change to: 

"None of the Above or Filed Electronically at least 2 weeks ago 

and filed by mail at least 8 weeks ago"? Many students 

misunderstand the questions / the vagueness of the time period, 

so they are reluctant to choose None of the Above and the IRS 

DRT option is then skipped for them!

b) Electronic Signatures: Electronically signing the FAFSA - not 

obvious to students to enter the PIN and then click on the Sign 

button; find a way to clarify this please.

c) Number the questions on the FAFSA on the Web

d) Lock out the Assets field after an amount has been entered 

and ask them to call FA office to make the change. 

a) Resolved

b) Resolved

c) Resolved

No Change

d) Resolved

No Change

a) An enhancement to the 2013-2014 FAFSA on 

the Web will address the “Recently Filed Taxes” 

and “None of the Above” comments by 

simplifying and clarifying the IRS Data Retrieval 

Tool logic.

b) An enhancement to the 2013-2014 FAFSA on 

the Web will clarify the logic for the electronic 

signature process.

c) The question numbers on the paper FAFSA are 

referenced in the help topics, the Help and Hints, 

and the application summary report (viewable 

from any page within the application) on FAFSA 

on the Web. The actual question numbers are 
 Page 2 of 28 11/9/2012

not presented by each question within FAFSA on 

the Web for two reasons: 1) questions in FAFSA 

on the Web do not display in the same order as 

questions on the paper FAFSA due to Web logic 

that allows for a customized experience, and 2) 

this customized experience in FAFSA on the Web 

results in the suppression of certain questions. 

Because of the customized experience in FAFSA 

on the Web, the Department believes that the 

inclusion of question numbers on screen would 

cause confusion.

d) The asset questions in FAFSA on the Web 

correction entry specifically ask for asset 

amounts on the day the application was 

submitted. Because the answer should be 

corrected if a true mistake was made, The 

Department needs to allow applicants to make 

necessary corrections.

3) I work in a Federal TRiO program Educational Talent Search and 

yearly assist my students in both the submission of the FAFSA as 

well as in understanding the output the SAR 

The submission of the FAFSA is not at all difficult and in fact quit 

simple even for students who are not comfortable with or 

knowledgeable about numbers associated with wages salaries 

and other forms of income 

The issue comes after submission when at least in years past 

almost 50 % or more of my low income first generation 

population are selected for a process called VERIFICATION 

This is critical because without completing the verification 

process Financial Aid cannot be awarded and in many cases 

colleges will not make an offer of Financial Aid until it is 

Resolved

No Change

The text that is currently displayed states the 

following:

“Your FAFSA has been selected for a review 

process called verification. Your school has the 

authority to request copies of certain financial 

documents from you and your parent(s).”

Since the verification process varies from school 

to school, FAFSA on the Web does not offer 

individual guidance about next steps. 
 Page 3 of 28 11/9/2012

completed yet they still expect students to pay deposits by May 

1st 

When we go and look @ their SARs the while not always aware of 

what the EFC means and almost never aware that they have been 

selected for verification 

Why well let’s see , The instructions are not bolded , the asterisk 

is not well explained and the process says to contact your FAA 

So why should I contact the Federal Aviation Administration, FAA 

which is what you get if you Google FAA. Why not clearly and in 

BOLD say that you need to contact the office of Financial Aid at 

the institution that you plan to attend 

Verification should be in Bold and should be explained as in both 

the reason why you were selected and exactly what to do next 

step by step 

I realize that there are many components to the whole FA process 

but from the perspective of a practitioner who works with a low 

income population and also assists other High School counselors 

in the 6 High Schools I work in I rural NH VERIFICATION , remains 

the least understood and most obscure part of the entire process 

4) a) Recommendation for greater emphasis on the Department’s 

need for use of the IRS Retrieval Tool.

b) Also we need the FAFSA workshop materials during January of 

the FAFSA filing year. Early submission is required by many 

colleges by February 15. Training cannot be conducted because 

training materials become available much later.

a) Resolved

b) Resolved

No Change 

a) Messaging will be added to FAFSA on the Web 

for 2013-2014 to strongly encourage those 

applicants who estimate their financial 

information to return later and utilize the IRS 

Data Retrieval Tool.

b) Ongoing training opportunities are announced 

on the Information for Financial Aid Professionals 

(IFAP) web site. The FAFSA on the Web demo 

site for the next cycle is available in late 

December.

A PDF of the application is available to the public 
 Page 4 of 28 11/9/2012

in early January via FAFSA on the Web when the 

application is deployed. 

5) On the front page of the draft students are advised if their family 

has unusual circumstances that may affect their financial 

situation – such a loss of employment - they are to complete the 

form as instructed, then contact the Financial Aid office of the

school they are planning to attend. When they come in here with 

a similar scenario we tell them that there isn’t anything we can 

do. We do not offer PJ we wait for them to ask about PJ. This 

may appear to them as conflicting information. 

On page 9 it is noted that under VERY limited circumstances a 

student may be able to submit the FAFSA without parental 

information. It does not indicate if that FAFSA will eventually be 

accepted. 

Resolved

No Change

The intent of the text is to encourage all 

applicants to submit the application even if they 

think their personal situation would hinder the 

process. Additionally, students need to know 

who to contact about unusual circumstances. It 

is then up to the school to determine whether or 

not to use professional judgment.

Regarding the note on page 9, more details are 

provided on FAFSA on the Web.

6) I would like to suggest a change to the wording of FAFSA 

question 28:

Current: “Will you have your first bachelor’s degree before July 1, 

2013?” 

Suggested: “Will you have completed your first bachelor’s degree 

before July 1, 2013?” 

For some reason, many students mistakenly answer “Yes” to this 

question as it is currently worded, which results in delays in their 

financial aid processing. 

Resolved

No Change

7) It would be extremely helpful for our institution (and am sure 

many others) to have these 2 questions ADDED back to the 

FAFSA:

a) Expected enrollment – this is VERY helpful for packaging aid at 

correct status (keeping from having to have extensive changes to 

those packaged at incorrect status eg. If all packaged FT).

Resolved

No Change

a) For the 2011-2012 cycle the enrollment status 

question was deleted. The rationale for the 

change is that at the point in which a student is 

applying for aid, students have indicated that 

they do not know what their enrollment status 

will be and often do not understand the 

enrollment status terms that may vary from 
 Page 5 of 28 11/9/2012

b) If a student wants a student loan – this is VERY helpful in not 

having to package all students with loans/or not packaging and 

then having to make students complete additional paperwork to 

request a student loan. I believe this can assist with possibly 

lowering the default rate for schools who may have been 

packaging loans and students accepting without thinking about 

wanting/needing one.

college to college, and therefore end up 

reporting an incorrect enrollment status. 

Additionally, the administration believes 

students may be able to make better decisions 

about college affordability if they are able to see 

the full amount of aid they would be able to 

receive. The Department encourages schools to 

review their administrative processes to account 

for the elimination of this question and to 

understand how they can gather a more accurate 

enrollment status for the student.

b) For 2011-2012, question 31 was revised to 

capture an applicant's interest in work-study 

instead of work-study and loans. The rationale 

for the change is that at the point in which 

students are applying for aid, they often do not 

know whether they will need student loans to 

help pay for college. The Department believes 

that the more appropriate point for students to 

determine whether they will need student loans 

would be when they are reviewing the award 

packages developed by the financial aid office. 

Students and their families can then discuss their 

student loan options based on having 

information about all of the aid they have been 

offered. The Department will continue to ask 

about work-study interest because of its limited 

availability at colleges, and encourages schools 

to review their administrative processes to 

account for the changes to the question.

8) Would you consider adding two additional options to FAFSA item 

numbers 33 and 80?

Resolved

No Change The current income tax return choices are used 
 Page 6 of 28 11/9/2012

Currently, the FAFSA give choices of:

 1040

 1040A/EZ

 A foreign tax return

 A tax return from Puerto Rico, another U.S. territory, or 

Freely Associated State.

I propose adding options thus:

 Form 4868 - Extension

 1040X – Amended return

My reasoning is that many folks know that they are doing this 

upfront or relatively early in the tax season, and it would help FA 

offices determine better what documents we should be looking 

to receive, especially in light of the requirements to get IRS Tax 

Return Transcripts and Tax Account Statements/Summaries.

If not perhaps it could be a separate item?

for the simplified needs test and automatic zero 

Expected Family Contribution (EFC) 

determination. Adding extension or amended 

tax return choices does not assist students who 

file the FAFSA early since it is difficult to predict 

an extension or an amended tax return. 

9) In addition to the AGI, tax paid, etc. posted to the FAFSA, how 

about if the IRS posts which type of tax return they have on file 

for the student/parent and whether the student/parent were 

eligible to file a 1040 A/EZ rather than asking the student parent 

to self-report these two items?

It is my experience that it is often wrong and can result in a large 

EFC change when corrected. Students not getting Pell grants may 

get it, and students who may initially be awarded Pell may lose it.

Resolved 

No Change 

The IRS Data Retrieval Tool transfer does provide 

tax return type; however, the question that asks 

if an applicant is eligible to file a 1040A/EZ is not 

a tax return field. Therefore, it cannot be 

retrieved from the IRS. 
 Page 7 of 28 11/9/2012

10) Question #29 on the FAFSA asks, “When you begin the 2013-2014 

school year, what will be your grade level?” We have found over 

the years that numerous students answer this incorrectly by 

choosing the response of “Continuing graduate/professional 

student.” They take it to mean that they are continuing their 

education after having graduated from high school or are 

returning to school after having worked in a professional setting. 

The result is that they are assumed to have a Bachelor’s Degree 

and therefore flagged as ineligible for Pell Grant funds. This 

requires follow-up so that we can determine if they have in fact 

completed their Bachelor’s Degree or if they need to make a 

correction to their answer. It adds processing time and results in 

frustration for students. 

We would like to see this response reworded or modified to 

prevent such confusion. An explanation in the Helpful Hints 

section of FAFSA on the Web often times does not suffice, as 

students do not take the time to read those tips. Perhaps the 

following could be considered as options: 

· Continuing graduate/professional or beyond (i.e. 

Master’s/Doctorate) 

· Pursuing Master’s/Doctorate/Professional Degree 

· Pursuing (advanced) degree beyond Bachelor’s 

Resolved

No Change

The stated categories were defined and 

implemented in conjunction with state entities 

to facilitate the determination of eligibility for 

state grant programs.

11)

Georgia Southern University would greatly appreciate having the 

'are you interested in a loan' question added back to the FAFSA.

Resolved

Duplicate

Refer to Comment #7 

12)

On behalf of Boston University, I am submitting the following 

comments regarding the 13/14 Draft FAFSA. As a QA school, BU 

has reviewed a broad range of FAFSA filers to analyze which fields 

a) Resolved

Forwarded 

to 

appropriat

a) The application describes the rules according 

to the current Higher Education Act (HEA) The 

comment has been forwarded to the appropriate 

business unit that reviews policy 
 Page 8 of 28 11/9/2012

are most commonly misreported. We believe these suggestions 

may improve the accuracy of students’ and parents’ responses to 

these questions.

a) Payments to tax-deferred pension and savings plans (Q. 

44a, 92a): Our QA analysis confirms this field is likely the 

most commonly misreported item on the FAFSA and we 

believe it is because families do not understand the question.

Many families do not consider their contributions to 

retirement plans as payments to “pension and savings plans”; 

therefore, they report “zero” on the FAFSA but we often 

verify a contribution as indicated on W-2 forms in Box 12a –

12d. We suggest changing the language to include the word 

“retirement” which will help families better understand the 

question.

o Suggested Text: “Payments to tax-deferred 

retirement, pension and savings plans (paid 

directly or withheld from earnings), including, but 

not limited to, amounts reported on the W-2 forms 

in Boxes 12a through 12d, codes D, E, F, G, H, and 

S.”

b) Net Worth of Investments, including Real Estate (Q. 41, 

89): When a portion of the primary home is being rented, the 

FAFSA does not instruct the family to report that portion of 

their home as “other real estate.” We suggest adding 

language to the “notes” on the FAFSA, page 2 for parents and 

students to include the rental portion of their home in the net 

worth of investments.

c) Net Worth of Businesses and/or Investment Farms (Q. 42, 

90): We commonly find families incorrectly include the net 

worth of their family-owned business and/or family-owned 

e business 

unit 

b) Resolved

Forwarded 

to 

appropriat

e business 

unit

c) Resolved 

No Change

d) Resolved

Forwarded 

to 

appropriat

e business 

unit

e) Resolved

Forwarded 

to 

appropriat

e business 

unit

f) Resolved

No Change

recommendations.

b) The application describes the rules according 

to the current HEA. The comment has been 

forwarded to the appropriate business unit that 

reviews policy recommendations.

c) The Department believes the current language 

provides adequate guidance. 

d) The application describes the rules according 

to the current HEA. The comment has been 

forwarded to the appropriate business unit that 

reviews policy recommendations.

e) The application describes the rules according 

to the current HEA. The comment has been 

forwarded to the appropriate business unit that 

reviews policy recommendations.
 Page 9 of 28 11/9/2012

farm on the FAFSA. The “notes” on the FAFSA, page 2 clarify 

when to include or exclude the business/farm; however, we 

suspect that families are not referring to the special 

instructions. The current question specifies “don’t include a 

family farm or family business with 100 or fewer full-time or 

full-time equivalent employees.” We suggest adding more 

specific language to this question for parents and students to 

clarify the definition of “family-owned.”

o Suggested Text: “As of today, what is the net 

worth of your parents’ (or students’/spouses’) 

current businesses and/or investment farms?

Don’t include a farm or business that is more than 

50% owned and controlled by the family, and has 

100 or fewer full-time or full-time equivalent 

employees. See Notes page 2.” 

d) Health Savings Accounts (HSAs) (Q. 44i, 92i): per the 12/13 

Application and Verification Guide, HSAs are to be treated as 

untaxed income. However, the FAFSA does not instruct 

students and parents to include tax-free contributions to an 

HSA as untaxed income. We suggest adding language to both 

students and parents “other untaxed income” questions that 

tax-free HSA contributions should be included as untaxed 

income.

e) Homebuyer Tax Credit (Q. 44i, 92i): it is our understanding 

that the first-time homebuyer tax credit expired after the 

2011 tax year. However, the FAFSA question for “other 

untaxed income” instructs both students and parents to 

include the first-time homebuyer credit as untaxed income.

We suggest removing these instructions if the tax credit has 

expired.
 Page 10 of 28 11/9/2012

f) First Bachelor’s Degree before July, 1, 2013 (Q. 28): Many 

of our undergraduate continuing students mistakenly respond 

“yes” to this question. We suggest formatting this question 

similar to how the illegal drug conviction question (Q. 23) is 

formatted, whereby the “no” response displays before the 

“yes” response. Perhaps reversing the order of the responses 

will reduce the number of incorrect responses.

13) Among the most common and frequent FAFSA error/omission we 

observe is that of Untaxed Income, specifically “payments to taxdeferred pension and savings plans”. I think the core of the 

problem is that the instructions for what should be reported only 

appear if the student or parent checks the box. 

I suggest that you list the most common type and where to find 

it, such as “contributions to 401(k) – See box 12 on your W-2”, 

under the question for the filer to see without having to check the 

box first. 

Resolved

No Change 

Instructions are provided on the paper 

application and in FAFSA on the Web. A 

response to this question may also be available 

through use of the IRS Data Retrieval Tool.

14) I have a suggestion for the 13-14 FAFSA. The 12-13 process of the 

IRS data retrieval makes verification to be very quick with less 

corrections. Thank you, it has really simplified the verification 

process. However, after experiencing the process of performing 

the other components of verification I have a bit of an uneasy 

feeling when the parent or student report their marital status as 

unmarried but discover after verifying household size that they 

are married. How would I know that the IRS data retrieval that 

was transferred to the FAFSA was for one or two people. Is it 

possible to add the question on the FAFSA what was the “filing 

status on the 1040”. ie: single, married, head of household. This 

way we would be able to know for sure that the data transferred 

is for all family members. Also this could be a red flag for 

verification when the filing status does not match the reported 

marital status.

Resolved

No Change

The question recommended is not required to 

calculate the Expected Family Contribution (EFC). 

Marital status questions 16 and 58 are used to 

determine the EFC. 
 Page 11 of 28 11/9/2012

15) It would be nice if tax filing status could be drawn done from the 

IRS. Such as Head of Household, Married filing jointly, single etc...

It is hard to tell sometimes when screening for this issue in the 

verification process when the student has utilized the IRS match.

Resolved

Duplicate

Refer to Comment #14.

16) We are a community college with a large immigrant population. 

People completing the FAFSA often misinterpret the questions 

asking for high school completion status and “Will you have your 

first bachelor’s degree before July 1, 20xx” to mean a only US 

high school or US college and do not answer the question 

correctly. We often find students who graduated from schools in 

other countries answering “NO” to these questions because of 

that misinterpretation. Since both of these elements affect 

student eligibility, this misinterpretation has serious 

consequences for many students. We are requesting that these 

two items be amended to add “in the US or any other country” to 

clarify the question for students who attended school outside of 

the US.

Resolved

Duplicate

The comment has been forwarded to the 

appropriate business unit that reviews policy 

recommendations.

17) My suggestion is that the IRS data retrieval has been a great 

benefit to both the student/parent and financial aid 

administrator. I have seen ISIR’s where the IRS data retrieval was 

done but there were “0” wages reported. There is no way for me 

to verify that they had earnings. Not reporting wages is a 

disadvantage to the students financial aid eligibility. If it possible 

to have the IRS data retrieval process to include wages? This is a 

line item on the IRS transcript, I am sure it would be a retrievable 

item for the FAFSA.

Resolved

No Change 

The information retrieved from the IRS does not 

include W-2 information. Since joint tax return 

filers add wages together and report the sum on 

their tax return, FAFSA on the Web is unable to 

separate student/spouse or mother/father 

income earned from work for eligibility 

determination. However, The Department is 

exploring options to address this issue.
 Page 12 of 28 11/9/2012

18) On behalf of the more than 3,000 member institutions of the 

National Association of Student Financial Aid Administrators 

(NASFAA), I am writing to offer our comments on the draft 2013-

14 Free Application for Federal Student Aid (FAFSA).

a) We appreciate the Department’s continued efforts to clarify 

and improve the FAFSA structure and language, however we 

believe that the Department would receive much more useful 

feedback from the community if it instituted a similar comment 

process with a similar timeframe for the FAFSA on the Web 

(FOTW), since the vast majority of applicants use FOTW rather 

than the paper FAFSA.

Generally, the FOTW demonstration site 

(www.fafsademo.ed.gov) for the upcoming cycle is not available 

until mid-December. This late time frame makes it difficult for the 

financial aid community to provide useful feedback in time for ED 

to make any necessary or desired changes prior to the January 1

start-up date. In future years, we ask that you make the 

demonstration site available to the community for comment at or 

near the same time you are soliciting comments on the paper 

FAFSA.

b) Of particular concern this year are the complexities facing 

members of the lesbian, gay, bisexual and transgender (LGBT) 

community. Because of their family structures, completing the 

FAFSA can be particularly difficult for this community. For 

example, under the Defense of Marriage Act (DOMA), same-sex 

marriages are not considered marriages for federal purposes, 

including the FAFSA. Because there are no corresponding 

instructions to the “Are you married?” question on the FAFSA, a 

student in a same-sex marriage could reasonably answer “Yes” to 

that question. Lacking further instruction, that

a)Resolved

No Change

b) Resolved

No Change

c) Resolved

Forwarded 

to 

appropriat

e business 

unit

a) Availability of the FOTW demonstration site is 

the same as availability of the “official” FAFSA on 

the Web site. 

b) The application describes the rules according 

to the current HEA. For the purposes of federal 

student aid eligibility determination, the 

definition of “married” is based on the DOMA 

definition.

c) The comment has been forwarded to the 

appropriate business unit that reviews policy 

recommendations
 Page 13 of 28 11/9/2012

student could also reasonably include his or her same-sex 

spouse’s information throughout the rest of the FAFSA. We 

recommend that you add instructions to assist these students 

and their families in completing their FAFSAs in accordance with 

federal law.

c) If you are an eligible noncitizen, write in your eight- or ninedigit Alien Registration Number. Generally, you are an eligible

noncitizen if you are (1) a permanent U.S. resident with a 

Permanent Resident Card (I-551); (2) a conditional permanent

resident with a Conditional Resident Alien Green Card (I-551C); 

(3) the holder of an Arrival-Departure Record (I-94) from the

Department of Homeland Security showing any one of the 

following designations: “Refugee,” “Asylum Granted,” “Parolee” 

(I-94 confirms that you were paroled for a minimum of one year 

and status has not expired), T-Visa holder (T-1, T-2, T-3, etc.)

or “Cuban-Haitian Entrant;” or (4) the holder of a valid 

certification or eligibility letter from the Department of Health 

and Human Services showing a designation of “Victim

of human trafficking.”

If you are in the U.S. on an F1 or F2 student visa, a J1 or J2 

exchange visitor visa, or a G series visa (pertaining to 

international organizations), select “No, I am not a citizen or 

eligible noncitizen.” You will not be eligible for federal student 

aid; however, you should still complete the application because 

you may be eligible for state or college aid.

The instructions should be consistent in using the official

terminology for these documents, rather than colloquial

terms.

Although these instructions have been improved over the past 

several years, we have a continued concern that they are still not 
 Page 14 of 28 11/9/2012

complete. Battered immigrants are not included

in this list at all, yet ED has issued a Dear Colleague Letter,

GEN-10-07, and the FSA Handbook includes several pages

explaining how to document the eligible noncitizen status of

these students. Page 1-27 of the 2012-13 FSA Handbook states 

that battered immigrants “indicate on the FAFSA that they are 

eligible non-citizens...”. It is not clear to us how they would know 

to do that, based on the current FAFSA instructions.

19) a) Prohibit submission of the FAFSA if the student signature is 

missing or the parent signature is missing (for dependent 

students).

b) For FOTW, perform a check of the Name/DOB/SSN 

combination entered against the Social Security Administration’s 

database and prohibit submission if SSA confirmation fails.

c) Crosscheck the state listed in the mailing address and the state 

identified in the residency question. If they do not match give the 

student a pop-up warning message to have the student double 

check their information and confirm its accuracy to override the 

warning message.

Rationale:

There are large numbers of students who are denied state aid 

due to a missing signature or social security number issues. There 

are many inconsistencies between the student’s mailing address 

and the listed state of residence which requires the states to 

either deny aid or spend additional time tracking down the 

student to confirm residency.

d) Build in a calculator for FOTW to estimate taxes paid.

Rationale:

a) Resolved

b) Resolved

No Change

c) Resolved

No Change

d) Resolved

No Change

e) Resolved

No Change

a) Beginning in 2013-2014, FAFSA on the Web 

will more strongly encourage electronic 

signatures. However, not every person has the 

ability to sign the application electronically, so 

the Department has to provide an option for 

those applicants to sign as well. 

b) Federal Student Aid and the Social Security 

Administration do not currently have real-time 

match capabilities. 
 Page 15 of 28 11/9/2012

It would be helpful to provide a calculator/tool that calculates an 

estimate for “taxes paid” for the applicants who have not yet 

completed their tax returns when filing their FAFSA. There is a 

worksheet that “pops up” to add up the items for a total AGI 

estimate, but there is not help available to estimate taxes paid. 

Applicants too often then just add up taxes withheld from the W2 form and use that as an estimate of taxes paid.

e) Provide information advising students of the “processing time” 

between e-filing income tax returns and when that information is 

accessible to interface with the FAFSA application.

Rationale:

The instructions on interfacing with the IRS are unclear. Although 

students now have an option to skip that feature, perhaps a 

required date field could be added, noting the date the tax return 

was processed. If that date is within the required IRS processing 

time period, the system would then provide an option to 

interface with the FAFSA. At a minimum, information advising 

customers of the “processing time” between e-filing income tax 

returns and when that information is accessible to interface with 

the FAFSA application would be helpful.

20) During the FOTW-renewal process, a student is prompted to 

review the existing information from previous years. When the 

student gets to question “What will be your high school 

completion status?” It does not allow students to populate the 

high school name, city, state and code. With one of the new 

verification items for the 2013-2014 award year being the High 

School Completion Status, this may cause many students to be 

pulled for verification.

Resolved The 2013-2014 FAFSA on the Web will require all 

applicants who indicate they have or will have a 

high school diploma to provide the name, city 

and state of the high school. If the applicant is 

renewal-eligible and has not answered the 

question before, he or she will be prompted to 

answer the question on his or her renewal 

application. 

21) I often help students fill out their FAFSA on the website and I 

have noticed that when students are asked the question about 

whether they have filed taxes there is some confusion. They 

Resolved 

Duplicate

Refer to Comment #2.
 Page 16 of 28 11/9/2012

often will check off that they “Recently Filed” rather than 

“Already Filed” but they have no idea that checking such an 

option will take them out of the running for doing the IRS 

Retrieval. Could we change this option to, “Recently Filed (in the 

past 2 weeks)” instead? Also, the very next question on the 

FAFSA needs to be answered as “None of the Above” or else the 

IRS Retrieval will not be available either. These two roadblocks 

make it so much more confusing than it needs to be. Certainly, 

we want as many students opting for the IRS Retrieval as 

possible!!!

Comments 22-56 have been submitted by one organization

22) Page 2, Notes, Q22

Need to add language that advises the male applicant he can 

register by answering this question if he has not done so already.

Insert new sentence #3 as follows: 

If you are a male between the ages of 18 and 25 and have not 

already registered, we will register you if you request.

Resolved 

No Change

Spacing limitations prevent this inclusion on the 

paper FAFSA. However, this specific information 

is currently provided in the Help text in FAFSA on 

the Web.

23) Page 3, Q23

Seems to be some discrepant guidance in the drug offense 

question. Sentence 1 asks if the applicant was convicted of an 

offense that occurred while he was receiving Title IV aid. 

Alternatively, sentence 2 tells the applicant to answer “no” if they 

never had a conviction while you were receiving aid. Student 

eligibility is based on when the offense occurred, not on when 

the conviction took place.

Update Sentence 2 as follows:

Answer “No” if you have never received federal student aid or if 

Resolved

Forwarded 

to 

appropriat

e business 

unit

The application describes the rules according to 

the current HEA. The comment has been 

forwarded to the appropriate business unit that 

reviews policy recommendations.
 Page 17 of 28 11/9/2012

you have never had a drug conviction for an offense that 

occurred while receiving federal student aid.

24) Page 4, Instructions, Q38 & 39 (and Q86 & 87)

This section now says for wages: “...may be on the W-2 forms 

(Box 5)...” 

Using Box 5 may yield inaccurate results for the following 

reasons:

•Tax filers completing the FAFSA have the option of using either 

line items from the tax return OR W-2 amounts. Line 7 from the 

1040 uses box 1 from the W-2. If we change the instructions to 

box 5, some applicants may use line 7 (essentially box 1) and 

others will use box 5.

•Box 5 typically is a higher amount because it includes total 

compensation, including contributions to 401(k) plans. Balances 

of retirement plans are not counted in the EFC, and thus the 

contributions to make such balances should be excluded as well.

•Box 5 is designated as “Medicare wages” – box 3 is “Social 

Security wages.”

Update as follows:

This information may be on the W-2 forms (Box 1), or on IRS Form 

1040 – line 7 + 12 + 18...

Resolved The Department has decided to remove the 

reference to Box 5 and return to the 2012- 2013

language that just states W-2’s. The reference to 

Box 1 may include elective deferrals and for 

reasons listed in the comment, Box 5 may not be 

appropriate. 

25) Page 4, Q38 & 39

Page 7, Q86 & 87

“If any individual earning item is negative, do not include that 

item in your calculation.” What individual earning amount is this 

referencing – the line item or the total? 

Does that mean if a 1040 has the following amounts:

Resolved

No Change

The Department believes the current language 

provides adequate guidance. The text proposed 

is regarding income, not taxes. The suggested 

“tax line” language can mislead the applicants.
 Page 18 of 28 11/9/2012

Line 7 = $400

Line 12 = ($1000)

Line 18 = $0

Would that equal $0 (because the total earning amount is 

negative) or $400 (because line 12 is negative, and thus, 

excluded)?

Replace with the following suggested text, adapted from the 

sidebar on page AVG-12 in the 12-13 FSA Handbook:

“If any individual tax line is negative, do not include that item in 

your calculation.”

26) Page 5, Instructions, Q44i & 92i

ED chose not to include line 25 of a 1040 for the HSA deduction 

(although they do reference the first-time home buyer tax credit.)

Insert the following, adapted from the sidebar on page AVG-19 in 

the 12-13 FSA Handbook:

“Also include the tax-free contributions to health savings 

accounts from IRS Form 1040 – line 25 and first-time homebuyer 

tax credit from IRS Form 1040—line 67.”

Resolved 

Duplicate 

See Comment #12e.

27) Page 5, Q43f

Page 7, Q91f

We should specify that a “cooperative education program” is not 

the same as “federal work-study.”

Insert the following:

Earnings from work under a cooperative education program 

Resolved

No Change

The Department believes the current language 

provides adequate guidance. 
 Page 19 of 28 11/9/2012

offered by a college. (Cooperative education programs are not 

the same as federal work-study positions.)

28) Student Aid Report, Page 1, First Checkbox 1

Recommend text be added to address using the IRSDRT to make 

any necessary corrections.

Add a new third sentence: 

If you filed a federal tax return, you should access your FAFSA 

data online at fafsa.gov, and use the IRS Data Retrieval Tool to 

make the necessary corrections.

Resolved The Department cannot use the text 

recommended because it may not apply to all 

applicants. Some applicants who receive this 

comment have already used the IRS DRT, while 

others aren’t eligible to use it for various 

reasons. However, messaging will be added to 

FAFSA on the Web for 2013-2014 to strongly 

encourage those applicants who estimate their 

financial information to return later and utilize 

the IRS Data Retrieval Tool. 

29) Student Aid Report, Page 1, Second Checkbox 1

A 0 EFC should equate to a Pell Grant of $5550, not the $5350 as 

stated on the SAR. Also, not all colleges offer other grants, loans 

or work-study.

Suggest the following:

Based on your EFC it appears that you may be eligible for a 

Federal Pell Grant of up to $5550, in addition to other grants, 

low-interest student loans, and work-study opportunities that 

may be available.

Resolved

No Change 

The Pell Grant amount currently displayed is a 

place holder. The correct amount will display on 

Pell-eligible SARs.

30) Student Aid Report, Page 3, Checkbox 2

Also need to note the IRSDRT process for making corrections.

Add a new third sentence:

If you filed a federal tax return, you should use the IRS Data 

Retrieval Tool to make the necessary corrections.

Resolved

No Change 

Refer to Comment #28. 

31) Student Aid Report, Page 7, Instructions, Q38 & 39 Resolved Refer to Comment #25. 
 Page 20 of 28 11/9/2012

The instructions don’t match the FAFSA. Need to determine 

which instructions are more accurate and make them match.

Insert the following at the end of the instructions: 

“If any individual tax line is negative, do not include that item in 

your calculation.”

No Change 

32) Student Aid Report, Page 10V and 10Q

It is unclear which page 10 students will receive in the SAR and 

whether the text on the bottom half of these different versions 

need to match. Therefore, we propose the following options (32a 

and 32b) to ensure the signature block is complete, accurate and 

clear.

a) Should this match the statement of educational purpose on the 

FASFA? Need to determine which one is more accurate and make 

them match. Substitute existing text with the following:

By signing this application, you certify that you (1) will use federal 

and/or state student financial aid only to pay the cost of 

attending an institution of higher education, (2) are not in default 

on a federal student loan or have made satisfactory 

arrangements to repay it, (3) do not owe money back on a federal 

student grant or have made satisfactory arrangements to repay it, 

(4) will notify your college if you default on a federal student loan 

and (5) will not receive a Federal Pell Grant from more than one 

college for the same period of time.

By signing this application I certify that all of the information I 

provided is true and complete to the best of my knowledge and I 

agree, if asked, to provide information that will verify the 

Resolved

No Change 

a) The statement signed on the FAFSA and the 

statement signed on the SAR are intended to be 

different. The statement on the FAFSA is prior to 

submission of the application, while the 

statement on the SAR is signed after the 

application has been processed and only if 

corrections are made. Furthermore, the 

certification statement on page 10 of the SAR 

varies depending on whether the application was 

processed successfully (applicants receive page 

10V) or if there are issues with the application 

that need to be resolved (applicants receive 

version 10Q).

b) The certification statement applies to all 

students, regardless of whether or not they are 

selected for verification. Since the text is not 

specific to those selected for verification and 

schools have the right to ask for whatever 

documents they choose when a student isn’t 

selected (and can ask for more than what’s 

required when a student is selected), the 

Department prefers to keep the current 

language.
 Page 21 of 28 11/9/2012

accuracy of my completed form. This information may include 

U.S. income tax forms that I, or my family, are required to file. 

Also, I certify that I understand that the Secretary of Education 

has the authority to verify the information I reported with the 

Internal Revenue Service and other federal agencies. If I sign any 

document related to the federal student aid programs 

electronically using a personal identification number (PIN), I 

certify that I am the person identified by the PIN and have not 

disclosed that PIN to anyone else. If I purposely give false or 

misleading information, I may be fined up to $20,000, sent to 

prison, or both.

b) Replace the term tax form with tax transcript for accuracy. 

Schools are permitted to request tax returns only in limited 

circumstances. If I am asked, I agree to give proof that my 

information is correct. The proof might include a copy of my 2012 

U.S. Income Tax Transcript or my W-2 form(s).

33) Page 1, Applying by the Deadlines, paragraph 3

Reword as noted for clarity.

Revise as follows:

Check with your high school or the financial aid office at your 

institution about sources of state and college aid and their 

application deadlines. Be aware that college student aid 

deadlines may be earlier than state aid deadlines.

Resolved 

No Change 

The Department is evaluating the text suggested. 

The comment has been forwarded to the 

appropriate business unit to review

recommendations.

34) Page 1, Using Your Tax Return, paragraph 1, sentence 2

Completing a return is not the same as filing the return.

Revise as follows:

Resolved

No Change 

The Department believes the current language 

provides adequate guidance. “Completion” is the 

term used because an applicant can use 

information on a completed tax return even 

before he or she files the tax return.
 Page 22 of 28 11/9/2012

If you have not yet filed your tax return, you can complete the 

FAFSA using estimated information, and correct the FAFSA after 

you have filed the return.

35) Page 2, Notes, Q34 & 81

Change “...a person...” to “you” for consistency with other 

sections.

Elimination of duplicative explanation of eligibility to use the 

1040A and 1040 EZ tax forms

Revise as follows:

In general, you are eligible to file a 1040A or 1040 EZ if you make 

less than $100,000, do not itemize deductions, do not receive 

income from your own business or farm, do not receive alimony. 

and are not required to file Schedule D for capital gains.

Resolved

No Change 

The Department believes the current language 

provides adequate guidance. The language used 

at the beginning is different to explain what the 

rule is. Once that information is explained, the 

language shifts to “you” to refer to the applicant.

36) Page 2, Notes, Q37 & 85

Change “...a person...” to “you” for consistency with other 

sections.

Revise as follows:

If you filed a 1040EZ, and did not check either box on line 5, you 

must enter 01 if you are single, or 02 if you are married. If you 

checked either the “you” or “spouse” box on line 5, use 1040EZ 

worksheet line F to determine the number of exemptions ($3,700 

equals one exemption.)

Resolved

No Change 

The Department believes the current language 

provides adequate guidance. 

37) Page 2, Notes, Q41, 42, 89 & 90, paragraph 3, sentences 2 & 3

Investments also include... section. Provide less complicated 

instructions relative to dependent and independent students.

Resolved 

No Change

The Department believes the current language 

provides adequate guidance. 
 Page 23 of 28 11/9/2012

Revise as follows:

For an independent student who does not report parental 

information....

For a dependent student who must report parental information...

38) Page 2, Notes, Q48

Delete the “s” from “Reserves” in all occurrences in both 

paragraphs

Replace the word “Reserves” with the word “Reserve.”

Resolved In this section the Department will keep 

references to “Reserves” and will instead add an 

“s” to the end of the word “Reserve” in the Q49 

section.

39) Page 2, Notes, Q48

Define Armed Forces here since this is the first time the term is 

addressed on the page.

Revise as follows:

Answer “Yes” if you are currently serving in the U.S. Armed 

Forces (Army, Navy, Air Force, Marines or Coast Guard) or are a 

National Guard or Reserve enlistee called to active duty....

Resolved The Department will define “Armed Forces” the 

first time it appears in the Q22 section.

40) Page 2, Notes, Q49, paragraph 1, last sentence

Correct awkward wording.

Revise as follows:

Also answer “Yes” if you will be a veteran by June 30, 2014.

Resolved

No Change 

The Department believes the current language is 

correct and provides adequate guidance.

41) Page 2, Notes, Q49

Combine the last two paragraphs into a single paragraph so as to 

Resolved

No Change 
 Page 24 of 28 11/9/2012

match the formatting of first paragraph.

Revise as follows:

Answer “No” (you are not a veteran) if you (1) have never 

engaged in active duty in the U.S. Armed Forces, (2) are currently 

an ROTC student or a cadet or midshipman at a service academy, 

(3) are a National Guard or Reserve enlistee activated only for 

state or training purposes, or (4) were engaged in active duty in 

the U.S. Armed Forces but released under dishonorable 

conditions. Also answer “No” if you are currently serving in the 

U.S. Armed Forces and will continue to serve through June 30, 

2014.

42) Page 3, Q8

Change the “N” in Number to lower case.

Your Social Security number

Resolved

No Change 

43) Page 3, Q26

The term “school year” confuses applicants and is not defined as 

either an academic year or an award year

Update Sentence 1 as follows:

When you attend college in 2013-2014, what will be your high 

school completion status?

Resolved

No Change 

The Department believes the current language is 

correct and provides adequate guidance.

44) Page 4, Q29

Suggest same change as on Q26, noted above.

Revise as follows:

Resolved

No Change 

The Department believes the current language is 

correct and provides adequate guidance.
 Page 25 of 28 11/9/2012

When you attend college in 2013-2014, what will be your grade 

level?

45) Page 4, Q30

Suggest same change as on Q26, noted above.

Review as follows:

When you attend college in 2013-2014, what degree or certificate 

will you be working on?

Resolved

No Change 

The Department believes the current language is 

correct and provides adequate guidance.

46) Page 5, Instructions, Step Three

“Once you answer ‘Yes’ to any...” This makes it sound like if the 

student gets to one yes, they can skip the rest of the questions. 

Revise as follows:

If you answer “Yes” to any of the questions in this step, skip Step 

Four and go to Step Five on page 8.

Resolved

No Change 

The Department believes the current language is 

correct. Once the student answers “Yes” to one 

of the dependency questions, the Central 

Processing System is able to determine the 

dependency status.

47) Page 6, Instructions, Q60

Change the “N” in Number to lower case. Also change “date of 

birth” to birth date for simplicity.

Revise as follows: 

What are the Social Security numbers, names and birth dates of 

the parents reporting information on this form?

If your parent does not have a Social Security number,...

Duplicate Refer to Comment #42.

48) Page 6, Q 72, Third Bullet

For clarity (a) and (b) should be indented under the introductory 

statement as noted.

Resolved

No Change 

The Department believes the current language is 

correct. The suggestion reflects a stylistic 

preference.
 Page 26 of 28 11/9/2012

Revise as follows: 

...your parents’ other children if:

- your parents will provide more than half of their support 

between July 1, 2013 and June 30, 2014, or 

- the children could answer “No” to every question in Step Three 

on page 5 of this...

49) Page 6, Instructions, Q74-78 

Page 8, Instructions, Q95-99

Instructions for the federal means-tested benefits questions no 

longer explain that SNAP is the new name for food stamps; there 

is no reference to food stamps at all.

Revise instructions by adding a new sentence four:

Mark all that apply. Answering these questions will not reduce 

eligibility for student aid or these programs. TANF may have a 

different name in your parents’ state. Also note that SNAP refers 

to food stamps.

Resolved

No Change 

The 2012/2013 FAFSA instructions indicated 

“Supplemental Nutrition Assistance Program 

(SNAP) is the new name for Food Stamps.” For 

2013/2014, this text was removed because the 

name change is no longer new. The program is 

called Supplemental Nutrition Assistance 

Program (SNAP).

50) Page 7, Q88

Delete the extra space between Q87 and Q88.

Resolved

No Change 

The paper FAFSA does not have an extra space 

between Q87 and Q88. The text aligns with the 

boxes on the right. 

51) Page 8, Q93

Place the spouse on a separate line from the student for clarity.

Revise as follows:

Include: 

• yourself,

• your spouse, if you are not separated, divorced or widowed, 

Resolved

No Change 

The Department believes the current language is 

correct. The suggestion reflects a stylistic 

preference.
 Page 27 of 28 11/9/2012

• your children, if you will provide more than half of their support 

between July 1, 2013 and June 30, 2014, and 

• other people if they now live with you, you provide more than 

half of their support and you will continue to provide more than 

half of their support between July 1, 2013 and June 30, 2014.

52) Page 10, Instructions How can I have more colleges...

Update to match the enhancements shared by Department staff 

at the NASFAA conference. Some students may not automatically 

receive a PIN if they didn’t provide a valid email address and will 

instead have to apply for one. Also, applicants may be confused 

as to which button to press now at fafsa.gov, since now there will 

be two.

Revise as follows:

1. Use the Federal Student Aid PIN and go to FAFSA on the Web 

at www.fafsa.gov. Click the “Login” button to log in and then 

select the “Make FAFSA Corrections” link.

Resolved The second sentence will be changed to: Click 

the “Login” button on the home page to log in to 

FAFSA on the Web, then click “Make FAFSA 

Corrections.”

53) SAR, Page 1, paragraph 2, sentence 2, Federal Student

Amend second sentence to reference the financial aid package.

Revise as follows:

Your financial aid package may include grants....

Resolved

No Change 

The Department believes the current language is 

correct and provides adequate guidance. The 

text suggested cannot be used because it would 

change the definition of what is being described.

54) Page 1, paragraph 3, sentence 3 For more information...

The link to the website that is currently listed does not work. 

Replace website link as follows:

http://studentaid.ed.gov/resources/loan-grant-fact-sheets.

Resolved The updated link is:

StudentAid.gov/aidInfo

55) Page 3, Checkbox 1, sentence 2 Resolved The Department is evaluating the text suggested. 
 Page 28 of 28 11/9/2012

Revise as noted to provide more accurate guidance.

Revise as follows:

You must contact the financial aid office at your school to resolve 

this issue.

No Change The comment has been forwarded to the 

appropriate business unit to review

recommendations.

56) Page 4, Summary of Federal Student Loans, paragraph 3, 

sentence 2

Curious as to why ED continues to use the 5% rate when 6.8% 

would provide a more accurate and realistic picture.

Resolved 

No Change 

The interest rates are based on the legislation. 

The percentage used in this section is only an 

example.