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K‑12 advisers raise concerns about FAFSA/TASFA changes and documentation for undocumented students
Summary
High‑school counselors and THECB staff discussed this year’s FAFSA/TASFA timing, immediate FSA ID verification and confusion among undocumented families about what documentation institutions will require for lawful presence and residency determinations.
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School counselors and ISD representatives told the THECB committee they are preparing for an earlier FAFSA/TASFA cycle and reported increased family anxiety — especially among undocumented students — about what documentation colleges will require to demonstrate lawful presence and residency.
Erica (ISD representative) said the earlier FAFSA opening means counselors are “doing a lot more… get started on apps now so that we can keep you in a timely basis with FSA IDs” rather than waiting for late fall. Sandra Moore, a district counselor, praised the new immediate FSA ID verification for catching issues at creation: she gave an example where a student whose legal name had changed but not yet been updated with Social Security was flagged earlier in the process.
Counselors repeatedly asked for clearer, institution‑level guidance about what documents will satisfy “lawful presence” and residency determinations, noting those determinations are typically made by admissions or registrars at public institutions rather than by financial aid offices. THECB staff pointed counselors to the updated TASFA web page and the Texas Department of Public Safety (DPS) residency documentation guidance linked on THECB’s site.
THECB staff clarified these points about TASFA and FAFSA: - The TASFA is a pass‑through application that does not itself determine residency or program eligibility; institutions make residency determinations and determine program eligibility. - The 2026–27 TASFA (online and paper) is scheduled to go live Oct. 1; the TASFA does not require Texas residency questions on the form and is not an eligibility determination tool. - Counselors and institutions should consult the THECB TASFA web page and the DPS guidance for acceptable residency documentation.
Counselors asked how institutions will treat valedictorian/salutatorian automatic‑admit and related merit awards when a student cannot demonstrate lawful presence; responses varied by institution and counselors were advised to contact planned colleges directly for institution‑specific residency or scholarship policy.
THECB staff encouraged continued communication; the agency’s TASFA page and institutional guidance were offered as the primary reference points for K‑12 advisers helping families this fall.

