Washington Update

U.S. Department of Education Requests Information on FAFSA Guidance; Releases Framework for 2025–26 FAFSA Testing Period   
The U.S. Department of Education (ED) released a Request for Information on the 2025-26 FAFSA, asking what outreach, supporting materials, and guidance text displayed on the FAFSA form would be most helpful to improving FAFSA completion this year. Written comments are due September 13.  

In addition, ED released its framework for conducting end-to-end testing on the 2025-26 FAFSA, in three phases beginning with several hundred students on October 1, 2024, expanding FAFSA testing to tens of thousands of students, and then releasing the full FAFSA for all students by December 1, 2024. Per ED, during each beta test phase, they will work with a range of stakeholders to support students in submitting the FAFSA, sending FAFSA records to institutions, completing corrections, and packaging aid offers. The tests will help ED to “identify and resolve the kind of system errors that can derail students, contributors, and institutions.” The first beta test period (Beta 1) will be open to nonprofit organizations supporting student applications, in partnership with institutions. Institutions will be able to apply alone beginning in Beta 2. 

APLU continues to underscore the importance of ED ensuring a smooth process, including abiding by timelines. In a recent The New York Times article, APLU President Mark Becker stated, “Now that it has announced its schedule for the 2025-26 school year, it’s imperative the department meet the delivery date with a flawless rollout and fully functional FAFSA. On or before Dec. 1 must be on or before Dec. 1.” 

U.S. Supreme Court Keeps Temporary Block on Biden Administration’s Student Loan Forgiveness 
The U.S. Supreme Court let stand a lower court’s move temporarily blocking the Biden administration’s Saving on a Valuable Education (SAVE) student loan repayment plan. Previously, the SAVE plan allowed borrowers to reduce monthly payments from 10 percent to 5 percent of discretionary income and redefined discretionary income so that borrowers earning less than 225 percent of the poverty line did not need to make payments. The Court continued the pause in the SAVE program while the issue is litigated in lower courts. The approximately eight million borrowers already enrolled in SAVE remain in limbo, without being required to make payments and with their accounts placed in interest-free forbearance. New applicants may continue to apply to SAVE on paper forms, but ED has paused the online application and processing of new applications. 

APLU, Higher Education Community Submit Comments to the Department of Education on Distance Education, Return to Title IV (R2T4) 
APLU joined the higher education community in submitting comments on the U.S. Department of Education’s (ED’s) Notice of Proposed Rulemaking on distance education and return of Title IV funds from the “Program Integrity and Institutional Quality” negotiated rulemaking.  

Broadly, the comments express concern that the administrative burden the regulations place on institutions, and subsequently, on students is not commensurate with the outcomes of the regulation. More specifically, the comments share concerns with the creation of an additional virtual location for data reporting distance education information on campus, challenges on the reporting of enrollment in distance education programs, and the removal of asynchronous learning from clock-hour programs. The letter also details additional resources institutions need from ED to comply with the return of Title IV rules.