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Can Afghan Newcomers Access Title IV, Federal Student Aid? Answering FAQ’s About New Guidance from the U.S. Department of Education

As Afghan newcomers begin to find their footing here in the United States, many will explore options for postsecondary and career and technical education. Accessing Title IV, Federal student aid through the U.S. Department of Education can offer critical assistance in financing these goals and aspirations. The Dear Colleague letter released by the U.S. Department of Education to financial aid professionals on June 17, 2022 provides new guidance on the current eligibility requirements for Afghan newcomers.

What is Federal Student Aid (FSA) and the Free Application for Federal Student Aid (FAFSA)?

The U.S. Department of Education’s office of Federal Student Aid (FSA) is the largest provider of student aid in the country, distributing over $110 billion in financial aid to students in college or career school each year. FSA is the federal office responsible for managing the student financial assistance programs authorized under Title IV of the Higher Education Act of 1965.  

The Free Application for Federal Student Aid (FAFSA) is the application to apply for Title IV, Federal student aid. Information collected through the FAFSA is used to determine applicants’ eligibility to receive aid and calculate the amount they qualify to receive. Applicants can identify and vet eligible college and career programs through the U.S. Department of Education’s College Navigator and College Scorecard.  

What does the Dear Colleague letter address?

The Dear Colleague letter offers assurance that those with the status of Special Immigrant (SI) Lawful Permanent Resident (SI LPR), SI Conditional Permanent Resident (SI CPR), SI Parolee, and Non-SI Afghan Parolee (Non-SI Parolee) are considered eligible non-citizens and therefore meet Title IV, Federal student aid eligibility requirements related to legal status. 

The guidance and exemptions in the Dear Colleague letter are specific to Afghan newcomers who meet one of the following criteria: a.) arrived between July 31, 2021 and Sept. 30, 2022, b.) are the spouse or child of an Afghan paroled between July 31, 2021, and Sept. 30, 2022, or c.) the parent or guardian of an unaccompanied Afghan child who was paroled between July 31, 2021, and Sept. 30, 2022. 

How does the guidance in the letter differ from existing Federal Student Aid policy?

The letter includes notable exemptions for Afghan Parolees that differ from existing Federal Student Aid policy. Typically, in order for parolees to qualify, they must have been paroled into the U.S. for at least one year and be able to demonstrate they are “in the U.S. for other than a temporary purpose with intent to become a U.S. Citizen or Permanent Resident” by presenting proof of submission of the Form I-485 or Form I-130. However, the Dear Colleague Letter indicates that SI Parolees and a Non-SI Afghan Parolees are exempt from these two requirements through March 31, 2023, in response to the 2021 Afghan Supplemental Appropriations Act. This will dramatically expand those Afghan newcomers who are eligible. This is welcome news and evidence of the U.S. Department of Education’s efforts to support Afghan newcomers. 

Why is legal status a consideration to receive Title IV, Federal student aid?

Section 484(a)(5) of the Higher Education Act of 1965, as amended (HEA) states that, for the purposes of Title IV aid eligibility, a student must be a citizen or national of the United States, a permanent resident of the United States, or able to provide evidence from the Department of Homeland Security (DHS) that they are in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident. 

When eligible non-citizens complete the Free Application for Federal Student Aid (FAFSA), information regarding their immigration status is sent to Department of Homeland Security (DHS) for verification. If conflicting information is entered or the automated verification is not possible, financial aid professionals at the applicant’s institution are required to manually verify immigration documentation. The Dear Colleague letter outlines the documents accepted as demonstration of the previously mentioned legal statuses. Please refer to the letter for a complete list by legal status type.  

What other documentation is required to submit the FAFSA?

 The FAFSA collects personal contact and identifying information about the applicant and their parent(s) or legal guardians. This includes their address, date of birth, Social Security Number (SSN), Alien Number, etc. Applicants are also required to submit information on the previous year’s earnings and summary of receipt of public benefits in the United States. See Switchboard’s toolkit Accessing Federal Student Aid for Refugee Youth and Adults for more information.  

To qualify for Title IV, federal student aid for college education, individuals must have completed secondary school or the General Education Development (GED) certificate. However, for many who are displaced, particularly Afghan newcomers, obtaining proof of their completion can be challenging. For the 2022-2023 school year, the U.S. Department of Education removed its requirement to present proof of high school completion (i.e., high school transcripts) if an applicant is selected for verification. This update will offer some relief to those who were unable to travel with their transcripts.  

Note: Individual institutions may have their own admissions policies that require applicants to demonstrate proof of high school completion for admission. Contact the institution’s admissions office for more information.  

Applicants may also qualify for Title IV, federal student aid for eligible career pathway programs 

through “ability-to-benefit” alternatives even if they have not completed secondary school.  See Ability to Benefit Frequently Asked Questions (EA ID: OPE Announcements-21-02).  

What if clients have an immigration status other than those listed in the recent Dear Colleague letter? Do they qualify?

In addition to the specific guidance offered in the recent Dear Colleague Letter, those with refugee, asylum granted (asylee), and Lawful Permanent Resident status remain eligible for federal student aid through existing protocols. See Switchboard’s toolkit Accessing Federal Student Aid for Refugee Youth and Adults for more information. 

Will this change if the Afghan Adjustment Act or similar legislation is passed?

This guidance is based on current legislation and may evolve in the coming months. Passage of the Afghan Adjustment Act or similar legislation could alter or extend these exemptions.  

How can I learn more about the application process?

For comprehensive, step-by-step guidance on accessing federal student aid for ORR-eligible populations, see Switchboard’s toolkit Accessing Federal Student Aid for Refugee Youth and Adults. For general information on the FAFSA, please refer to the U.S. Department of Education’s office of Federal Student Aid website.  

Do you have more questions about education for Afghan newcomers? Email Switchboard@Rescue.org! 

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