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Board discusses proposed administrative rule to require FAFSA completion for graduation; staff and members raise privacy and implementation concerns
Summary
State staff outlined a proposed amendment to the Alabama Administrative Code making FAFSA completion an opt‑out requirement for graduation beginning with the 2021–22 school year. Board members and staff debated privacy, parental consent, implementation timelines and whether the change should be pursued by statute or administrative rule.
State education staff discussed Dec. 10 a proposed amendment to the Alabama Administrative Code that would make completion of the Free Application for Federal Student Aid (FAFSA) a condition of high‑school graduation unless a parent or guardian opts out.
Dr. Mackey described the proposal as part of a broader effort to increase FAFSA completion rates after department analysis showed 2,018 2019 graduates did not complete the FAFSA, an omission the department says represents roughly $47.4 million in unclaimed federal aid. Staff noted the governor has raised FAFSA participation as a priority and that other states have pursued policies to increase completion, including Louisiana, where lawmakers required FAFSA completion unless families opt out.
Sean Stevens (staff), who joined the meeting, gave the board a numerical summary: he said last year’s statewide non‑completion figure (2,018 graduates) corresponded to an estimated $47,400,000 in federal aid not pursued by graduates. Staff explained the department would not collect FAFSA financial data; the department’s role would be to require completion (or an opt‑out acknowledgement) and confirm that a student either completed the form or submitted the opt‑out.
Board members raised a range of questions. Several expressed support for improving FAFSA completion to expand college and training opportunity and reduce financial barriers. Other members and some board counsel warned about parental privacy concerns, implementation logistics, and potential liability. Members asked whether the rule could be implemented immediately for the graduating class of 2022; staff said the earliest practical effective school year would be 2021–22 for implementation actions and that the department would work through timing and reporting details before seeking a formal vote.
Several board members and staff suggested pursuing other, lower‑impact steps first — such as better counseling support, targeted outreach by community colleges, and clearer guidance for counselors and families — before embedding FAFSA completion into graduation requirements. Staff agreed to collect additional information on other states’ policies and timelines and to share a proposed implementation timeline with the board before any formal vote.
