Immigration reform has been hotly debated in recent years. Although many component issues are controversial, the question of legalizing large numbers of unauthorized immigrants in the United States has been a focal point of debate, galvanizing both support for and opposition to reform proposals. Historically less controversial has been legislation known as the "DREAM Act" that proposes a more targeted legalization program to enable certain unauthorized students to obtain legal immigration status. The name DREAM Act derives from the bill title, Development, Relief, and Education for Alien Minors Act, but it refers more broadly to a class of measures to provide immigration relief to unauthorized alien students, whether or not particular bills carry that name. While living in the United States, unauthorized alien children are able to receive free public education through high school. Many unauthorized immigrants who graduate from high school and want to attend college, however, face various obstacles. Among them, a provision enacted in 1996 as part of the Illegal Immigration Reform and Immigrant Responsibility Act (IIRIRA) discourages states and localities from granting unauthorized aliens certain "postsecondary education benefits." More broadly, as unauthorized aliens, they typically are unable to work legally and are subject to removal from the United States. Multiple bills have been introduced in recent Congresses to provide relief to unauthorized aliens who were brought into the United States as children. Prior to the 111 th Congress, DREAM Act bills generally proposed to repeal the 1996 provision and to enable certain unauthorized alien students to adjust to legal permanent resident (LPR) status. In the 111 th Congress, the House approved a different type of DREAM Act measure as an amendment to an unrelated bill ( H.R. 5281 ). Unlike earlier DREAM Act bills, the DREAM Act language added to H.R. 5281 did not include a repeal of the 1996 provision and proposed to grant eligible individuals an interim legal status prior to enabling them to adjust to LPR status. H.R. 5281 died at the end of the 111 th Congress. Bills to legalize the status of unauthorized alien students were again introduced in the 112 th Congress. Some of these bills were similar to the measure approved by the House in the 111 th Congress, while others included more traditional DREAM Act elements. In the 113 th Congress, DREAM Act provisions were incorporated into larger comprehensive immigration reform bills, including the Border Security, Economic Opportunity, and Immigration Modernization Act ( S. 744 ), and were integrated with other legalization provisions in these bills. The Senate passed S. 744 , but it was not considered in the House and died at the end of the 113 th Congress. As of this writing, no DREAM Act bills have been introduced in the 114 th Congress. Under federal law, unauthorized aliens are neither entitled to nor prohibited from admission to postsecondary educational institutions in the United States. State laws vary and may prohibit enrollment in public postsecondary institutions. To gain entrance to available institutions, unauthorized aliens must meet the same requirements as any other student, which vary depending on the institution and may include possessing a high school diploma, passing entrance exams, and surpassing a high school grade point average (GPA) threshold. Although admissions applications for most colleges and universities request that students provide their Social Security numbers, this information typically is not required for admission. Even if they are able to gain admission, however, unauthorized alien students often find it difficult, if not impossible, to pay for higher education. Under the Higher Education Act (HEA) of 1965, as amended, they are ineligible for federal financial aid. In most instances, unauthorized alien students are likewise ineligible for state financial aid. Furthermore, as explained in the next section, they also may be ineligible for in-state tuition rates. Section 505 of IIRIRA places restrictions on state provision of educational benefits to aliens who are not lawfully present in the United States. It directs that such aliens shall not be eligible on the basis of residence within a State (or a political subdivision) for any postsecondary education benefit unless a citizen or national of the United States is eligible for such a benefit (in no less an amount, duration, and scope) without regard to whether the citizen or national is such a resident. There is disagreement about the meaning of this provision, and no authoritative guidance is available in either congressional report language or federal regulations. The conference report on the bill containing IIRIRA did not explain Section 505. (A conference report on a predecessor IIRIRA bill, which contained a section identical to Section 505, described the section as "provid[ing] that illegal aliens are not eligible for in-state tuition rates at public institutions of higher education.") Although Section 505 does not refer explicitly to the granting of "in-state" residency status for tuition purposes and some have questioned whether in-state tuition is a "postsecondary education benefit" for purposes of Section 505, the discussion surrounding the provision has focused on the granting of in-state tuition rates to unauthorized aliens. A key issue has been whether it is possible to grant in-state tuition to resident unauthorized students (and not to all citizens) without violating Section 505. Various states have attempted to do this. For example, a California law passed in 2001 makes unauthorized aliens eligible for in-state tuition at state community colleges and California State University campuses. The measure, however, bases eligibility on criteria that do not explicitly include state residency. The requirements to qualify for in-state tuition under the California law include attendance at a California high school for at least three years and either graduation from a California high school "or attainment of the equivalent thereof." In addition, the law requires an unauthorized alien student to file an affidavit stating that he or she either has filed an application to legalize his or her status or will file such an application as soon as he or she is eligible. California officials have argued that by using eligibility criteria other than state residency, the law does not violate the Section 505 prohibition on conferring educational benefits on the basis of state residency. In November 2010, the California Supreme Court upheld the California law. At least one federal court also has considered whether state laws that authorize in-state tuition for unauthorized students violate Section 505. On June 15, 2012, in the absence of congressional action on DREAM Act bills, the Department of Homeland Security (DHS) issued a memorandum announcing that certain individuals who were brought to the United States as children and meet other criteria would be considered for deferred action for two years, subject to renewal. The eligibility criteria for deferred action for childhood arrivals, or DACA, as the initiative is known, are similar to those for relief in DREAM Act bills. These criteria include the following: (1) under age 16 at time of entry into the United States; (2) continuous residence in the United States for at least five years before June 15, 2012 (that is, since June 15, 2007); (3) in school, graduated from high school or obtained general education development certificate, or honorably discharged from the Armed Forces; (4) not convicted of a felony, a significant misdemeanor, or three or more misdemeanors, and not otherwise a threat to national security or public safety; and (5) below age 31 on June 15, 2012. Consideration for DACA is limited to individuals who entered the United States without inspection or whose lawful immigration status expired as of June 15, 2012. Aliens granted deferred action can apply for employment authorization. The DACA program, however, provides no pathway to a legal immigration status. The program is administered by DHS's U.S. Citizenship and Immigration Services (USCIS). On November 20, 2014, DHS issued another memorandum that directs USCIS to expand eligibility for the DACA initiative and make other changes to the program, as follows: (1) eliminate the "below age 31 on June 15, 2012" requirement; (2) advance the required starting date of continuous residence from June 15, 2007, to January 1, 2010; and (3) extend the initial grant and renewal periods for DACA and accompanying employment authorization from two to three years. In the memorandum, DHS directs USCIS to begin accepting applications under the expanded DACA parameters in 90 days. Traditional DREAM Act bills would enable certain unauthorized alien students to obtain LPR status in the United States through a two-stage process. Requirements to obtain conditional status (stage 1) typically include residence of at least five years in the United States, and a high school diploma (or the equivalent) or admission to an institution of higher education in the United States. Requirements to become a full-fledged LPR (stage 2) typically include acquisition of a degree from an institution of higher education in the United States, completion of at least two years in a bachelor's or higher degree program, or service in the uniformed services for at least two years. In 2010, using data from the March 2006, March 2007, and March 2008 Current Population Survey (CPS) and other sources, the Migration Policy Institute (MPI) published estimates of the population potentially eligible for legal status under S. 729 , a Senate DREAM Act bill introduced in the 111 th Congress. This bill would have established a two-stage process for unauthorized alien students to obtain LPR status. Aliens who met specified age, physical presence, educational, and other requirements could have first applied for conditional LPR status. After meeting additional requirements, including two years of either college or service in the uniformed services, they could have applied to have the condition on their status removed and become full-fledged LPRs. According to the MPI analysis, if this DREAM Act bill had been enacted, about 2.150 million individuals could have attempted to become LPRs under its provisions.