ED Proposes Changes to Application for Federal Student Aid Program Participation
By NASFAA Policy & Federal Relations Staff
On Monday, the Department of Education (ED) announced a series of proposed revisions to the Application for Approval to Participate in the Federal Student Aid Programs (E-App). ED's proposed changes aim to clarify language and reduce the administrative burden on institutions. A 60-day public comment period is now underway, with comments due October 24, followed by an additional 30-day review period.
The application is a key tool ED uses to determine an institution's eligibility for federal student aid. Institutions utilize this form for initial participation, renewal of eligibility, adding new programs or locations, and fulfilling reporting requirements. The proposed revisions intend to streamline these processes.
One of the key updates includes a provision for automatically accepting applications for simple updates, which ED suspects will significantly reduce their review and approval times. Additionally, the logic for adding or deleting Federal School Codes (FSCs) will be revised. Instead of a single question, the new form will present situation-specific options depending on whether an institution has an active, inactive, or no FSC.
The proposed changes also include several new questions. Two questions related to accreditation and licensure requirements would be added, including a question asking if the program is offered in a state that requires a student to complete a minimum number of clock or credit hours for licensure or certification for the occupation for which the program prepares the student.
The application also adds a question related to an administrative capability regulation that went into effect July 1, 2024. The question allows institutions to affirm they have developed procedures to evaluate the validity of a student’s high school diploma if there is reason to believe it is not valid. While a "yes" or "no" answer is required, an optional field for an explanation will be provided. Also related to administrative capability regulations, a new requirement will be added for schools to self-certify that they have conducted debarment checks on their employees and contractors, shifting the responsibility of ensuring that employees and contractors are not prohibited from participating in the administration of Title IV programs from ED to the institution.
The proposed application will also require fewer college officials to provide their personal details. Contact information, such as home addresses, personal emails, and personal phone numbers, would only be required for the President/Chancellor and emergency contacts at domestic schools.
ED also proposes a new method for selecting Title IV programs to simplify the initial application process. Instead of requiring schools to choose the specific programs they wish to participate in, the new application will only ask if they want to participate. Federal Student Aid (FSA) will then determine the programs for which the school is eligible.
The proposed application will also incorporate new certifications for institutions offering Gainful Employment (GE) or Prison Education Programs (PEP). A new certification text will be displayed if an institution offers these programs.
To reduce administrative burden, the new form will allow schools to self-certify their Title IV policies and procedures, eliminating the need to upload and have ED review them. This change would presumably reduce burden on schools as well as ED.
Publication Date: 8/27/2025
Joseph S | 9/10/2025 10:40:33 AM
To Nedi G's question asking why a PPA includes an expiration date, Section 498(g)(1) of the Higher Education Act of 1965, as amended, provides that the Secretary of Education may certify an institution's Title IV eligibility for a period not to exceed six years.
Melissa H | 9/2/2025 10:22:20 AM
I would love to see a system that can be used to collect required signatures electronically. The practice of requiring "wet signature" by postal mail is antiquated and inefficient.
Jeff A | 9/2/2025 9:51:46 AM
They should also take advantage of this revised process to ask questions to determine if an addtional location (facility) should not be characterized as a 'closed school'. i.e. is this a facility that was used to offer a program that is no longer being offered. Is it a consolidation of locations in the same city/market? Ask the right questions to determine if students have been harmed by a precipitous closure, or even planned disclosure to determine if there truly should be loan forgiveness provisions triggered or not. The vast majority of the time they should NOT. Did all students complete their program? How many did not? etc. etc. This has been a horribly mischaracterized scenario. Understand that ED has a list of nearly 20,000 'schools that have closed'. Clearly the vast majority are truly not 'closed schools', but rather facilities no longer utlized by continuing institutions!!!
Peter G | 8/29/2025 12:22:27 PM
The argument against the change to which TIV programs a school wants to participate in is that schools don't always want to participate in certain programs they would qualify to offer - TEACH and DL as the most common, but also FWS.
Compared to the many other issues with the form, while it may simplify onboarding slightly, I don't see that as a substantial factor in why both submission/review are slow and overcomplicated.
Trish L | 8/28/2025 7:52:20 PM
The new E-App has some improvements over old version, however, the time to enter new programs increased.
Charles M | 8/28/2025 12:38:54 PM
Would would be the process for a school to conduct debarment checks on their employees and contractors? I'm having a hard time visualizing how that would work and how much burden there would be for something like that.
Nedi G | 8/28/2025 10:43:32 AM
Most of these changes are welcome. Home addres requirements sre silly, at best.
Why is there an expiration date? - we should just be required to make updates to the PPA immediately as needed. My PPA renewal is pending since February and there were zero changes.
Jennifer B | 8/28/2025 9:34:11 AM
I have been waiting to get our renewal PPA updated since December. At one point it was assigned to analyst but she was let then let go. I continue to get a response from FSA Case Teams that it has been assigned but they do not have an expected turnaround response time. I already need to make an update.
James C | 8/28/2025 9:27:40 AM
They need a new platform. The application is antiquated and almost every time you have to call the regional office for assistance. Often you then have to call the help desk line.
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