Takeaway: Alabama, California, and Colorado are the latest states to pass 'mandatory FAFSA' policies.

By Raymond AlQaisi, Policy and Advocacy Manager, National College Attainment Network

In an apparent resurgence to the growing “mandatory FAFSA” movement, three new states – Alabama, California, and Colorado – have adopted policies that will make completion of the Free Application for Federal Student Aid (FAFSA) a high school graduation requirement.

In 2020, more than a dozen states were considering mandatory FAFSA policies but ultimately did not pass them, with no new adoptions last year – following the onset of the severe COVID-19 pandemic.

The basis for mandatory FAFSA policies is that completion of the aid form is the strongest predictor of college enrollment. Students are more likely to pursue higher education when they are aware of the financial resources available to them. Given this, NCAN supports mandatory FAFSA policies when adequate supports are provided to students in the process – among other important considerations for such policies to be effective.

Illinois is the last state to have adopted the policy, and at the time, when ranked nationally, was among the top 10 states for FAFSA completion. This cycle, Illinois is in the top five 5; 66% of the high school senior class has so far completed the federal financial aid form. Illinois is also currently among a handful of states that have seen increased FAFSA completion as compared to last year.

NCAN’s latest reporting that shows FAFSA completion for high school seniors is down significantly, which presents great concerns for college access. The national completion rate has declined by roughly 5% from the year prior, as of July 16, amounting to over a quarter-million fewer FAFSAs filed since 2019.

Reasonably, states are seeking ways to counteract these trends and mandatory FAFSA is a promising answer.


In April, Alabama’s state board of education approved the adoption of mandatory FAFSA to take effect for the high school graduating class of 2022. Notably, this is a short timeline for the state to ask districts to implement, as other states have provided at least one year before their policies would take effect.

According to reports, the state board assures that the ability for a student to opt out and graduate is simple, though it will require completion of a waiver form. With support from state leaders, including Governor Kay Ivey, the policy is intended to help the state reach its goals for postsecondary attainment and workforce development.

Some individuals have raised concerns about the state ensuring students have the support they need to complete the FAFSA. Alabama Possible, an NCAN member, celebrated the policy’s enactment but has publicly called for the state to provide what is necessary for it to be successful.

Chandra Scott, executive director of Alabama Possible, wrote that “funding must follow this critical new policy to make sure that schools can provide the needed supports to students and families to make sure that those who will benefit most will be able to fulfill the graduation requirement and complete the FAFSA.”


At the end of June, California enacted its 2021-22 state budget, which included such a FAFSA requirement to begin the 2022-23 academic year.

California, in a first to take this approach, is placing the “requirement” on local educational agencies (LEAs) to confirm that their seniors (those who have not opted out) complete either the FAFSA or California Dream Act Application. The state ensures that students’ ability to graduate will not be negatively impacted by opting out. Additionally, to facilitate the process, California will issue further guidance and standardized forms for LEAs.


Last month, the Colorado state legislature passed the Higher Education Student Success bill which included such a requirement.

The law establishes a grant program for LEAs that choose to adopt the requirement, supplementing efforts to assist students in FAFSA completion. Notably, the funding attached that drives this requirement is a unique approach and will help ensure students are well-supported for future FAFSA cycles.

The bill text cites support for partnerships between LEAs, higher education institutions, and community-based organizations that all play a role in students’ FAFSA process; and says that the program will support postsecondary attainment, considering the pandemic’s severe economic impacts.

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