Incoming president Donald Trump has vowed to .

For students who are eyeing college, his presidency represents a potentially brutal Sophie鈥檚 Choice if they have undocumented parents: Risk exposing them to a possible immigration dragnet by completing the federal Free Application for Federal Student Aid, or FAFSA, or leave thousands of dollars in cash for school on the table. 

While researchers and advocates have yet to hear anything concrete from Trump representatives about using financial aid data to target undocumented residents, they know families are afraid.

鈥淔ront line staff that work directly with students are reporting that students and parents are asking them if the FAFSA is safe鈥� given Trump鈥檚 campaign promises of mass deportation, said Marcos Montes, policy director for Southern California College Attainment Network, a coalition of nonprofits that help students apply for college admission and financial aid.

The National College Attainment Network said those fears are justified. It 鈥渃annot assure mixed-status students and families that data submitted to the US Department of Education, as part of the FAFSA process, will continue to be protected,鈥� a read late last month.

That fear is exacerbated by  that the only way to deport undocumented parents whose children are citizens is to have the whole family leave. 鈥淚 don鈥檛 want to be breaking up families,鈥� Trump said. 鈥淪o the only way you don鈥檛 break up the family is you keep them together and you have to send them all back.鈥� How Trump can force out citizens, including those with parents not born in the U.S., is unclear; experts say .

An estimated 3.3 million Californians , including 1 in 5 children under 18, according to data from Equity Research Institute, a USC research group.

A California workaround

Experts say California students eligible for financial aid can minimize the possible harm to their undocumented parents. Unlike the FAFSA, the state aid application is not shared with federal agencies. That policy is  in place under California鈥檚 so-called 鈥渟anctuary鈥� laws  the use of state resources to . Several legal experts told CalMatters the Trump administration would have to clear a high legal bar to gain access to those state records and that court cases have put restrictions on how wide a net immigration enforcement agencies can cast in their search for data. 

Because the deadline for state financial aid is in March 鈥� though there are plans to move it to April 鈥� and the federal deadline , Californians attending college here should complete the state application first, said Montes. Then they should wait to see if the Trump administration will break precedent and begin using the federal financial aid data for immigration enforcement purposes.

That strategy is also endorsed by Madeleine Villanueva, the interim higher education director at Immigrants Rising, a California-based advocacy and research group focused on undocumented residents. She stressed that there鈥檚 a bevy of analysts and immigrant rights advocates who鈥檒l be watching for updates from the Trump administration.

鈥淯nfortunately, we can鈥檛 say what鈥檚 going to happen federally,鈥� she said. But the California state aid application, known as the California Dream Act Application, is an 鈥渆xtra layer of safety when it comes to applying for financial aid.鈥�

The California Student Aid Commission, an agency with the sole goal of getting students more money, suggests students may need to forgo federal aid given the risks to their families. The agency, which runs the state鈥檚 financial aid programs,  that completing just the state aid application is a 鈥渧iable option鈥� for students in mixed-status homes who have 鈥渇ears of adverse action by federal immigration enforcement.鈥�

However, taking a wait-and-see approach with federal aid means California campuses won鈥檛 have a full picture of how much aid a student is likely to get when they send out financial aid estimates to admitted students in the spring. The University of California鈥檚 central office worries that students may not complete the FAFSA and lose out on aid. Both UC and the California State University indicated to CalMatters they鈥檒l process either form students submit and will work with students who file their federal applications later.

About , which waives tuition at the public universities and partially at private colleges. That grant plus the state鈥檚  can add up to more than $17,000 in aid in one year. The state aid application ensures students fearful of the federal application can still receive the state support for which they鈥檙e eligible.

The University of California鈥檚 undergraduate student government is also on edge about FAFSA. The lack of a firm firewall 鈥渃ould put certain students at risk,鈥� said Saanvi Arora, external vice president for UC Berkeley鈥檚 student government and a board member for the systemwide student government.

Understanding the FAFSA risk

Students who are  are eligible for up to $7,400 in Pell grants and access to federal loans that come with repayment protections that are often stronger than what the private sector offers. To receive this aid, students who live with their parents need them to fill out portions of the federal aid application. More recently,  have been asked to indicate they lack one and then must answer a set of questions about their identity.

The U.S. Department of Education and the Department of Homeland Security, which also oversees the country鈥檚 immigration enforcement, have a regularly renewed . Because students need to be citizens or permanent residents to get financial aid, a signed agreement between the two departments states that students鈥� information they submit for FAFSA will be matched against an . It鈥檚 one that hundreds of state, local and federal agencies use to determine whether an individual is eligible for federal benefits. Neither SAVE nor the agency that operates it, U.S. Citizenship and Immigration Services, are used for immigration enforcement purposes. 

Conceptually, it鈥檚 not hard to use that federal financial aid data for enforcement purposes, according to experts who spoke with CalMatters. However, doing so would be a major break from current protocol. 

Under the Biden administration, the U.S. Department of Education 鈥渉as not provided and will not provide information gathered through FAFSA to any federal immigration-related agency for law enforcement activities,鈥� wrote in an email James Kvaal, who holds the number two spot at the U.S. Department of Education and is the top higher education officer in the federal government. However, he wrote, 鈥渟tudents and their families should make the decisions that are right for them.鈥�

That does not 鈥渟ound like a robust encouragement to go ahead and fill out the FAFSA,鈥� said Bob Shireman, who was a senior higher education official in the education department during the Obama administration.

The agreement between the departments 鈥渋s not much of a firewall, it is more like a picket fence,鈥� Shireman said in an interview. The agreement can be changed in a matter of months, he said, 鈥渟o if the next administration wants to use education department records to identify people who may have an immigration status that could subject them to deportation, I don鈥檛 see anything preventing that from happening.鈥�

Federal laws limit the data sharing that can occur between the U.S. Department of Education and law enforcement agencies, said Shelveen Ratnam, a spokesperson for the California Student Aid Commission. Ratnam said that current law 鈥渟trictly prohibits鈥� agencies in possession of personally identifiable information, like parental data, from releasing that information, with few exceptions. Some other laws and policies also apply and the gist is that an agency can only use the personal information of others in ways that support the mission of that federal agency.

But if the U.S. Department of Education gets subpoenaed for information, the department鈥檚 鈥渞esponses and likelihood of challenging the demand for information are unknown,鈥� according to Ratnam.

Even analysts who say using parental FAFSA information is an inefficient way to find possible undocumented parents urge caution. They say it鈥檚 not out of the question that a Trump administration could try to make use of that data for immigration enforcement purposes.

While 鈥渋t鈥檚 sort of methodologically flawed as a way to identify individuals,鈥� said Corinne Kentor, an , 鈥渢hat doesn鈥檛 mean that it won鈥檛 be attempted. But I think it is probably harder and more work than other avenues.鈥�

California Dream Act Application is safer

The California Dream Act Application has more protections than the federal application. Though originally designed to allow undocumented students who are California residents to apply for state college benefits, the application in 2024 was modified to permit any student who ran into problems with the federal application to at least apply for state grants. The change stemmed from colossal data issues with the federal application this year that  from completing the FAFSA.

According to a , 鈥渢he government can鈥檛 enforce a subpoena that is just 鈥榝ishing鈥� for data about undocumented people,鈥� said Ahilan Arulanantham, a scholar on immigration law at UCLA. That鈥檚 in contrast to 鈥渢rying to gather information on a particular individual that the government has reason to suspect is here in violation of the immigration laws.鈥�

Arulanantham also said that a federal agency asking California鈥檚 financial aid agency to search databases for undocumented students could run afoul of the 10th Amendment.

Finally, the state鈥檚 financial aid agency could challenge a judicial order or subpoena that seeks student records on the grounds that it鈥檚 not specific enough and violates the Fourth Amendment鈥檚 protections against unreasonable search and seizure, Ratnam said. 

Now what does all this mean for students with undocumented parents who already submitted FAFSA information last year? Their information is already in government systems. Should they continue to file their FAFSA? Experts had few answers. They said that鈥檚 a decision that only families can decide together given the varying protections available.

Arora, the UC student government member, is sympathetic to those households. It鈥檚 鈥渁bsolutely a tough question,鈥� she said. That鈥檚 one reason she wants UC officials to bolster existing immigration legal aid services, such as bringing in more lawyers. 

It鈥檚 one answer she has to her own question: 鈥淗ow do we mitigate retribution that鈥檚 likely to happen against those students?鈥�

This was originally published on .

• Title 1: Of all the federal Education Department’s funding streams, Title 1 is the best-known, the largest and the most appropriate for tutoring (although the others are also useful places to look). It was designed to target extra resources to high-need schools, specifically for math and reading. The good news is that a tutor is not needed for every student for every subject, so only a portion of Title 1 dollars is necessary. Tutoring is most important for students struggling with their coursework, including those who are not on track for proficiency in reading by the end of third grade or for by the end of ninth. Students who meet these benchmarks are four times more likely to graduate from high school as those who don’t. Districts should look hard at how they are spending Title 1 dollars to help students reach these two goals, redirecting staff positions or funds to tutoring programs with demonstrable return on investment.
  
• Multi-Tiered Systems of Support: Districts across the nation use Multi-Tiered Systems of Support to target appropriate interventions for students with learning, social, emotional, or behavioral difficulties. Many districts could improve these offerings by using a high-impact tutoring approach, making sure their interventions build relationships between students and educators that motivate, engage and target students鈥� growth areas using data and high-quality instructional materials. Schools can integrate high-impact tutoring with the funds already being used for MTSS by reallocating resources to more effective approaches.
  
• AmeriCorps: One of the priorities of this 30-year-old program is to support effective tutoring for high-need students. awards tens of millions of dollars in grant funding for tutoring and mentorship in early learning and K-12 schools. Districts can apply directly for federal funds through their State AmeriCorps commissions. These three-year grants can largely cover the costs of tutors and supervisory staff. Districts can also seek vendors that are AmeriCorps partners to provide tutoring, which brings a subsidy from the vendor directly into the district.

•  Work-study: This 60-year-old program enables lower-income students to work their way through college. Of the 20 million undergraduates in the U.S., about 600,000 receive work-study as part of their financial aid packages. This allows colleges to use federal funds to subsidize work by their students. Recent guidance has called on colleges and universities to spend at least 15% of those funds on community-based jobs, and tutoring is among the roles prioritized. With a district as a community partner, a college can .
  
• U.S. Department of Education teacher preparation funds: The 60-year-old is designed to increase the number of well-prepared teachers from diverse backgrounds. The focus is on the various aspects of the teacher preparation pipeline, including the recruitment, support and placement in underresourced schools with underserved students. This fund goes directly to higher ed; districts should partner with local colleges to design a tutor-to-teacher pathway.
  
• U.S. Department of Labor apprenticeship funds: These can support for future teachers. State departments of education can help districts address teacher shortages by strengthening the pathway to the classroom through the real-world experience of tutoring in schools. , for example, has just become a federal apprenticeship provider.

Since school districts often lack the capacity to seek grants or manage compliance requirements, leaders could ask local philanthropies for help. They could also rethink some of their current procedures to save money in the short and long term.

For example, some contracts pay providers based on student hours, not tutor hours. In other words, instead of paying a vendor $25 an hour for a tutor鈥檚 time (and overhead), some districts paid $75 for an hour in which that tutor worked with three students. Districts should renegotiate those contracts to pay for tutor time, regardless of how many students were assigned. They should also monitor tutoring implementation and effectiveness in order to make adjustments, maximizing impact; outcomes-based contracts with vendors can help.

And, they can reevaluate the timing of their tutoring programs. 

Offering high-quality tutoring during the school day makes it easier to connect to the kids and teachers, as they’re already in the building, than providing services outside of regular class time; helps cultivate a pipeline of talent entering the education system; and may help stem and reduce dropout rates.

Investing in third-grade literacy and Algebra 1 tutoring specifically makes sound long-term financial sense. Holding onto more kids is not only the right thing to do morally and educationally, but it provides a financial benefit. Allocating $500 to $1,000 per student for high-impact tutoring in grade 9 can yield an average of $15,000 in annual state per-pupil funding for each student who remains in high school for the next three years, until graduation. It is essentially an insurance policy that potentially preserves up to $45,000 in future funding per student, which can sustain tutoring initiatives and support other school needs. 

It is clear that districts have options for sustaining high-impact tutoring programs. Some may require challenging choices and changes, while others will require schools to form partnerships, which takes time and coordination. But if schools are to help students recover from the effects of COVID-related learning interruptions, they will need to focus on the strategies that can provide the strongest outcomes. Schools that make high-impact tutoring a funding priority now will enable their students to succeed for years to come.

Colleges and universities need to relieve students and their families of this added stress and push enrollment deadlines from May 1 until later in the spring or early summer.

Colleges are unable to create financial aid packages for their students without crucial information contained in the Free Application for Federal Student Aid 鈥� 鈥� which is administered by the U.S. Department of Education. At the end of January, the department notified higher education institutions that it could not forward students鈥� FAFSA forms until the . 

鈥嬧�婽hat means colleges will receive crucial financial information at least six weeks later than previously announced, and already months later than in previous years. In turn, already short-staffed financial aid offices will have to scramble to put together offers so that thousands of students can make their college enrollment decisions by May 1. 

One of them is Nicholas Onaiwu, a senior at my high school for whom college seemed like a far-fetched dream because his family could not afford tuition. Then Nicholas started visiting some local colleges. We worked with him on his personal statement, helped him prepare for college interviews and made sure he filled out his FAFSA and looked into state grants. College became a reality that he was excited about, and all of a sudden felt within reach. But when he found out about the FAFSA delay, he felt that his dream was in jeopardy. He was anxious about having a smaller window of time to analyze financial aid packages, pursue internships near the college that gives him the most aid and make a thoughtful, well-informed decision. 

The change doesn鈥檛 just impact the 19,000 students at the Uncommon Schools network where I work; it affects more than 17 million students nationwide who rely on the FAFSA to determine federal financial aid, Pell Grants, student loans and work-study programs.

The delays are caused by an effort to improve the FAFSA and that would have dispersed less aid to students from mostly economically disadvantaged communities. The new process, revised after Congress passed the makes the form shorter, and 600,000 students with financial need will receive Pell Grants for the first time due to a change in eligibility guidelines. These much-needed modifications to FAFSA are a crucial step toward ensuring that college continues to be a path to the middle class for millions of young Americans.

But the new form didn’t come out until Dec. 30, 2023, and on the department said it was making a last-minute fix so take the latest inflation data into account. This domino effect of delays has put colleges and families in a bind. 

, including the American Association of State Colleges and Universities, are urging colleges and universities to move their enrollment deadlines. In a joint statement, they said, 鈥淒uring the pandemic, many institutions extended their enrollment, scholarship and financial aid deadlines beyond the traditional May 1 date, and we urge institutions to make similar accommodations this year. We all want students and families to have the time they need to consider their financial options before making enrollment decisions.鈥� 

, like the University of Illinois, have already decided to push their enrollment deadline, and others are considering it.

The right thing for colleges and universities to do is to move their enrollment deadlines to at least June 1, so students and their families have time to make reasoned and well-informed decisions about this monumental investment in their futures. 

My students and their families have spent years preparing for this moment, from learning how to read in kindergarten to staying up many late nights working on college applications as high school seniors. They have worked hard and dreamed big. The least colleges can do is give them and their families a few extra weeks to decide what is best for their future.

The University of Wisconsin-Madison announced a program on Monday that would cover all of the costs for students who are members of one of Wisconsin鈥檚 11 federally recognized Native American tribes.

Any enrolled member of one of the tribes will be eligible for the program and eligibility will not depend on a student鈥檚 financial need. The program was announced less than a week after the UW System Board of Regents a deal with the Republican-controlled state Legislature to freeze hiring for positions focused on diversity, equity and inclusion in exchange for the release of pay raises for thousands of UW employees and funds for capital projects 鈥� including a new engineering building on UW-Madison鈥檚 campus.

UW-Madison Chancellor Jennifer Mnookin, who supported the deal with the Legislature, said the program for Native American students has been in the works for more than a year so its announcement is not related but added that it shows the university remains committed to diversity.

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鈥淚 have said and will continue to say that diversity is a core value for us as an institution here at UW Madison,鈥� Mnookin said at a press conference announcing the program. 鈥淎nd this program is another example of the ways that that is and will continue to be true.鈥�

The undergraduate program will cover the full costs of getting a degree at UW-Madison, including tuition and fees, housing, meals, books and other educational expenses. A separate five-year pilot program will cover in-state tuition and fees for students in the medical and law schools. The annual in-state cost for an undergraduate student is $28,916, according to the university. The cost of tuition and fees for law students is $35,197 annually and $42,198 annually for medical students.

Students will not need to apply for funding under the program. At the press conference Monday, university officials said students would just need to provide proof of tribal membership when they submit their annual financial aid forms.

Officials said there are about 650 students at UW-Madison who self-identify as Native American, however that self-identification doesn鈥檛 require proof of tribal affiliation and includes Native students from tribes outside of Wisconsin.

Mnookin said the program will be funded with money from private donations and 鈥渙ther institutional resources.鈥� She wouldn鈥檛 say where specifically the other resources are coming from, but noted that none of the money will come from state funding.

The chancellor added that creating the program 鈥渇elt like the right thing to do鈥� to continue improving the partnership between the university 鈥� which sits on traditional Ho-Chunk Nation land 鈥� and the state鈥檚 11 tribes.

鈥淭he tribal nations of Wisconsin, dating from the 1700s and into the 21st century, have always believed education to be the equalizer,鈥� Shannon Holsey, president of the Stockbridge-Munsee band of Mohican Indians, said. 鈥淭he truth is, if it were not for the loss of land by indigenous peoples, American colleges and universities would not exist. Institutions must challenge themselves to move away from encouraging acts that are performative into communities of transformative change. I believe today represents just that, the creation of this program marks a significant step in the partnership between American Indian tribes in Wisconsin and the University of Wisconsin-Madison. While several other states have programs with similar goals, we are not aware of any other effort that goes this far beyond financially helping Native students afford higher education.鈥�

Officials said they don鈥檛 yet know how popular the program will be, noting that the application deadline for incoming students for the fall of 2024, when the programs will begin, is Feb. 1. Mnookin said it would be unrealistic to expect a large increase in Native American applicants within six weeks of announcing the program, but that she hopes the number of tribal members at UW-Madison will continue to increase once the program is more established.

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