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 methodology. However, to my knowledge, the statutory definition in the Higher Education Act has not been revised and still references taxable income for the preceding year.

My interpretation has been that FAFSA/ISIR information can be helpful, but only in certain situations.

Since taxable income can never exceed AGI, if the family's AGI reported on the FAFSA is already at or below the applicable TRIO Low-Income Level for the household size reported, then taxable income must also be below that threshold. In those cases, FAFSA information can serve as sufficient evidence that the participant meets the low-income criterion for TRIO.

However, if the AGI exceeds the applicable TRIO Low-Income Level, FAFSA information alone cannot establish eligibility because taxable income may or may not still fall below the threshold. In those situations, additional documentation, such as a signed tax return, signed IRS transcript, or signed statement identifying taxable income, should be obtained.

This approach recognizes the statutory definition in the Higher Education Act while also acknowledging the practical reality that many Financial Aid offices do not have taxable income readily available. It may be particularly useful for programs such as EOC, SSS, and McNair, where FAFSA information is often available through Financial Aid. For many UB and TS projects, however, most of their applicants have not yet completed a FAFSA, making this approach less applicable.