One issue I frequently see is that Financial Aid offices often provide only FAFSA/ISIR information, which includes Adjusted Gross Income (AGI) rather than taxable income. However, the Higher Education Act defines a low-income individual as someone whose family's taxable income for the preceding year does not exceed 150 percent of the federal poverty level for the applicable family size. In addition, FAFSA relies on prior-prior year (PPY) income, rather than income from the preceding year referenced in the statute.
As a result, FAFSA information does not align perfectly with the statutory definition of low-income for TRIO purposes in two important respects:
FAFSA reports AGI rather than taxable income.
FAFSA uses prior-prior year income, while the Higher Education Act references taxable income for the preceding year.
I am aware that the U.S. Department of Education has previously acknowledged the practical use of FAFSA information in determining TRIO eligibility, particularly given the FAFSA's prior-prior-year…
Thanks for your questions! Please see the answers below:
1. How will the revised categories affect TRIO reporting, and should participant applications be changed now? OMB has revised the federal standards so that race and ethnicity will eventually be collected through one combined question, with respondents permitted to select multiple categories, and Middle Eastern or North African added as a separate category. Hispanic or Latino has not been eliminated; it remains one of the seven minimum categories. However, these changes do not require TRIO projects to revise their participant applications immediately. Projects should continue collecting and reporting information according to the current APR fields until the Department of Education issues revised TRIO forms and instructions. When that occurs, projects can revise their applications prospectively to match the new APR. ED will also need to explain how historical participant records should be handled. Projects should not independently guess or reclassify participants who previously identified under the old categories. Depending on ED’s instructions, some historical information may remain as previously reported or may need to be reported as unknown or not disclosed. Because the new standards allow participants to select more than one category, the category totals may not equal the unduplicated number of participants, and that would not necessarily be a reporting error.
2. What do the revised categories mean for McNair’s underrepresented eligibility criterion? The OMB revisions do not change McNair eligibility because OMB specifically states that the revised race and ethnicity standards are not to be used as determinants of eligibility for participation in a federal program. The current McNair regulations still provide that a student may qualify by being both low-income and first-generation, by being a member of a group underrepresented in graduate education, or through an underrepresented academic-discipline determination approved by the Secretary. Therefore, we cannot yet say that McNair projects may no longer select participants based on underrepresented-group status. However, until ED reconciles the revised reporting categories with the existing McNair eligibility definitions, my conservative recommendation would be to place the strongest recruitment and selection emphasis on students who meet both the low-income and first-generation criteria whenever possible. That is a prudent project practice, not a change in the current law or regulations.