2025 Year in Review: NASFAA’s Policy, Grant, and Advocacy Efforts
By Maria Carrasco, NASFAA Staff Reporter
2025 was another busy year for NASFAA’s policy team, which focused on providing timely and accurate resources for members regarding a new presidential administration, the incoming 119th Congress, an effort from the White House to “dismantle” the Department of Education (ED), several negotiated rulemaking committees, the enactment of the One Big Beautiful Bill Act (OBBBA) through the reconciliation process, and much more.
NASFAA’s policy team worked to create a list of policy recommendations and priorities for the incoming Trump administration, with President Donald Trump being inaugurated in January.
2025 was also marked by major changes to ED. Earlier in March, Education Secretary Linda McMahon announced a reduction in force (RIF). In response to the fallout, NASFAA conducted two surveys to better understand how the RIF is impacting financial aid offices.
NASFAA in 2025 also worked with the 119th Congress by endorsing multiple pieces of legislation focused on federal student aid. NASFAA also continued its work advocating for Congress to strengthen federal student aid.
NASFAA’s policy, grant, and advocacy efforts expanded to other initiatives from ED, including negotiated rulemaking. ED first held a negotiated rulemaking committee focused on reforming the Public Service Loan Forgiveness (PSLF) program.
With the enactment of OBBBA, the sweeping legislation made several changes to the federal student aid programs. ED held two additional negotiated rulemaking committees focused on the implementation of OBBBA: the Reimagining and Improving Student Education (RISE) Committee and the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee.
NASFAA hosted six Advocacy Pipeline events, which included a pipeline with the 2025 Diversity Leadership Program (DLP) cohort and an annual pipeline with the Graduate/Professional community, enabling financial aid administrators from across the country to make their voices heard in meetings with Capitol Hill staffers.
NASFAA also hosted several timely, policy-focused webinars highlighting the latest administrative policies and financial aid topics like Completing the PEP Application and the E-App Process, Loan Limits, Repayment, and Definitions: Takeaways from the OB3 RISE Committee, Critical Partnerships in Administering a Prison Education Program, Policy Update Webinar, and more.
As the busy 2025 year comes to a close, NASFAA’s policy, grant, and advocacy efforts for 2026 will continue to focus on increasing students' access to federal student aid.
Read on for a comprehensive list of other actions NASFAA and its members took in 2025.
Advocacy Activities and Materials
NASFAA’s Advocacy Pipeline
NASFAA continued its Advocacy Pipeline efforts by hosting six separate events for financial aid administrators, including a pipeline with the 2025 Diversity Leadership Program (DLP) cohort and an annual pipeline with the Graduate/Professional community, to connect with lawmakers and their staff to discuss financial aid reform, doubling the Pell Grant, FAFSA simplification, and more.
Reconciliation Call to Action Campaign
NASFAA created a reconciliation Call to Action advocacy campaign regarding Congress’ reconciliation bill, the OBBBA. NASFAA advocated for members to contact their representatives to protect student aid funding, including maintaining the Graduate PLUS loan program, graduate student loan borrowing limits, and subsidized student loans.
Negotiated Rulemaking
NASFAA continues to keep members up to date with everything happening with the negotiated rulemaking process. Just this year, ED has held three negotiated rulemaking committees focused on higher education and student financial aid issues – the Public Service Loan Forgiveness (PSLF) Committee, the Reimagining and Improving Student Education (RISE) Committee, and the Accountability in Higher Education and Access through Demand-driven Workforce Pell (AHEAD) Committee.
Developed the One Big Beautiful Bill Act (OBBBA) Web Center
NASFAA created a web center dedicated to tracking the implementation of the One Big Beautiful Bill Act (OB3 or OBBBA), which was signed into law on July 4, 2025, through the budget reconciliation process. As this legislation contains significant provisions that reshape student financial aid, NASFAA has created this resource to keep members informed about the latest analysis, guidance, and regulatory developments as they occur. Beyond news coverage, NASFAA developed many resources for members. That ranges from on-demand webinars, multiple charts for members to track the new graduate/professional student loan borrowing limits and overall changes with the OBBBA, and a new planning and implementation checklist to support financial aid offices in preparing for the changes.
Developed Member Resources
Throughout the year, NASFAA created member resources on multiple issues happening in financial aid. Recently, NASFAA published its revised data sharing white paper, which was developed with the assistance of EmpowerED Higher Education Consulting (EHEC). The white paper has been updated significantly and reflects all of the changes to institutional data sharing authority stemming from the FAFSA Simplification Act, including all guidance issued by ED to date. Also, NASFAA updated its data sharing decision tree, another member resource.
Supported or Endorsed Legislation in the 119th Congress
NASFAA endorsed several pieces of legislation in the 119th Congress, including the Degrees Not Debt Act, the College Transparency Act, the Student Loan Tax Elimination Act, and more.
Updated the Financial Aid 101: Resources for the 119th Congress
In January, NASFAA offered and created resources to assist members of the 119th Congress as they worked to pass reforms to strengthen access to, and success in, higher education for our nation's students. Resources included timely Higher Education Act (HEA) reauthorization topics, key financial aid issues to watch, financial aid basics, and NASFAA research and reports.
Developed Policy Recommendations for the Trump Administration and the 119th Congress
NASFAA developed a series of policy recommendations for both the Trump administration and the 119th Congress in 2025, which includes newly updated recommendations and priorities regarding Higher Education Act (HEA) reauthorization.
Origination Fee Issue Brief
NASFAA updated its issue brief regarding student loan origination fees in February, which includes information on how origination fees work and looks at how much in interest students pay for these fees. The brief recommends Congress work to eliminate origination fees altogether since these fees stand in clear opposition to the overwhelming congressional support for simplification, transparency, and affordability in the federal student aid system.
Advocacy Work Through the Student Aid Alliance
In 2025, NASFAA did advocacy work through the Student Aid Alliance, a coalition of over 40 higher education organizations co-led by NASFAA that advocates for increased support for federal student aid. That includes sending a letter to congressional appropriators calling on them to protect student aid funding in fiscal year (FY) 2026. NASFAA also co-hosted a Taco Tuesday Lunch and Learn Briefing on Capitol Hill with the Student Aid Alliance that focused on the importance of student aid programs and how they could be impacted by the proposed funding cuts in the House FY 26 Labor-HHS appropriations bill. The panel discussion included NASFAA’s National Chair, Heidi Carl.
Participated in the Committee for Education Funding’s (CEF) Hill Day
In 2025, NASFAA continued its involvement with the Committee for Education Funding (CEF), a coalition of more than 100 organizations that advocates for increased federal investment across the education continuum, including the federal student aid programs. NASFAA member Alex DeLonis spoke about the impacts of delaying federal education funding on a panel as part of CEF’s Legislative Conference in September. NASFAA also participated in CEF’s annual Hill day, where the association advocated for robust increases to federal student aid funding.
Continuation of the Double Pell Campaign
Throughout 2025, NASFAA continued its commitment to the Double Pell campaign, calling on Congress to make key investments in the program. Throughout the year, NASFAA participated in numerous events with members and federal officials to continue highlighting how federal aid has served as a lifeline for generations of students seeking to pursue higher education.
Grant & Research Initiatives
2025 National Student Aid Profile
NASFAA’s National Student Aid Profile is an annual publication that provides a high-level overview of the federal student financial aid programs, which fund millions of students each year. The profile provides an overview of the following programs: the Federal Pell Grant Program, the Federal Supplemental Educational Opportunity Grant (FSEOG) Program, the Federal Work-Study Program, the Federal Direct Subsidized and Unsubsidized Loan Programs, and the Federal Direct PLUS Loan Program. Additionally, the profile outlines the most up-to-date data and information on the number of recipients, total volume of awards, federal funding levels, and distribution by family income for each program, as well as an appropriations update on Title IV program funding for the 2025-26 award year.
Exploring How Institutions Build Their Cost of Attendance|
NASFAA conducted a mixed-methods study to investigate how institutions determine their cost of attendance (COA). This work included a targeted survey of financial aid administrators, focus groups, and one-on-one interviews with institutional and state-level experts. The project aimed to document current COA development practices, identify common challenges, and elevate the perspectives of financial aid professionals responsible for constructing COA. This research revealed consistent patterns across institutions and sectors while also highlighting variations based on institutional mission, capacity, and regulatory context. The findings detailed in the report offer timely insights for policymakers considering federal regulation of COA and provide practical considerations for institutions and professional associations to improve COA development practices.
Implications of Negative SAI Report
The 2024-25 FAFSA Simplification Act brought about significant changes, notably replacing the Expected Family Contribution (EFC) with the Student Aid Index (SAI). A key aspect of this reform is the introduction of a negative SAI, which allows the lowest possible index to reach -1,500. While the new calculation provides greater differentiation among the nation’s lowest-income students, its practical impact on financial aid awarding, institutional decision-making, and federal policy remains underexamined. To better understand how institutions are responding to this change, NASFAA conducted a mixed-methods study in 2025, which included a practitioner survey of NASFAA’s Rapid Response Network and a series of eight virtual focus groups and interviews with financial aid administrators from across institutional sectors. This research explores how institutions interpret and operationalize negative SAI, the factors that constrain or support implementation, and the policy reforms practitioners believe are needed to ensure the measure translates into meaningful support for students with the highest need.
Impact of Workforce Reductions and Potential Closure of the Department of Education on Financial Aid Offices
In May 2025, NASFAA conducted a national survey of financial aid professionals to understand how the March 2025 reduction in force (RIF) at the U.S. Department of Education (ED) and Office of Federal Student Aid (FSA) — along with related federal directives to dismantle ED — are affecting financial aid office operations, staffing, and student service. The survey collected responses from approximately 900 unique institutions representing all sectors of U.S. higher education. Institutions report operational delays, breakdowns in federal support systems, and an erosion of communication channels with ED and FSA. Most critically, these institutional-level challenges are already affecting students’ abilities to access, understand, and rely on federal student aid.
Follow-Up Survey: Impact of Workforce Reductions and Potential Closure of the Department of Education on Financial Aid Offices
In July 2025, NASFAA conducted a second national survey of financial aid administrators to assess how the March 2025 reduction in force (RIF) at the U.S. Department of Education (ED) and Office of Federal Student Aid (FSA) — along with broader efforts to dismantle ED — are continuing to affect institutional operations, staffing, and students’ access to federal financial aid. The survey collected responses from financial aid practitioners at over 500 institutions across all sectors of U.S. higher education, building on the findings of NASFAA’s first post-RIF survey conducted in May. Institutions report that conditions have not improved. A higher percentage now cite delays, federal systems breakdowns, and a lack of clear federal communication. Most critically, these challenges are no longer limited to administrative burdens — they are increasingly visible to students. Institutions report a rise in student confusion, inquiry volumes, and frustration with aid delivery processes that rely heavily on functioning federal systems and clear guidance.
FAFSA Data Sharing in the Context of Federal Tax Information
In light of the changes resulting from the FUTURE Act and the FAFSA Simplification Act, NASFAA was interested in examining how entities that previously relied on FAFSA data are adapting to the new data-sharing rules and what new processes they have found to meet their needs. For this project, NASFAA partnered with the Council for Opportunity in Education (COE), the Data Quality Campaign (DQC), the Institute for Higher Education Policy (IHEP), the National College Attainment Network (NCAN), the Student Success Through Applied Research (SSTAR) Lab at the University of Wisconsin-Madison, and the State Higher Education Executive Officers Association (SHEEO) to produce two reports.
- Research Responses to FAFSA Reform and FTI DataNASFAA commissioned a report, authored by the SSTAR Lab, for financial aid researchers interested in using student or parent income data within the context of new prohibitions on using FTI data for research. The report provides background information, examples of alternative measures, and descriptions of lessons learned for researchers.
- Perspectives on Implications of Statutory Changes to Data-Sharing RulesAs described in this report, considerable confusion remains in several areas where legislative changes to FTI and non-FTI FAFSA data sharing have occurred. In many places where previous confusion has been resolved by ED guidance, overly strict interpretations of the statute have hindered—or in some cases eliminated—the ability of institutional staff outside of the financial aid office to administer the programs or conduct research that has historically relied on FAFSA data.
Administrative Burden Report
As a follow-up to studies it conducted in 2010, 2015, and 2020, NASFAA again surveyed financial aid professionals at its member institutions to better understand how ongoing regulatory changes are affecting college financial aid offices. The survey found that a strong majority (91%) of respondents reported feeling the time and resources their office devotes to processing each aid application has “greatly increased” or “somewhat increased” in the past five years. Additionally, in this report, NASFAA outlines considerations to address the causes associated with resource constraints and presents Congress and ED with options for reasonable steps to reduce administrative burden.
Reclassification Case Studies in Financial Aid Offices
These case studies — spanning public, private, community college, graduate/professional, and proprietary institutions — offer real-world insights into how financial aid leaders have successfully navigated the complexities of reclassification. While strategies varied by institution type, common themes emerged, including HR collaboration, salary benchmarking, leadership advocacy, and aligning changes with institutional priorities. To support financial aid directors in navigating reclassification, NASFAA has also developed Tips and Resources for Reclassification, outlining actionable steps and key considerations for initiating these efforts. Additionally, NASFSAA’s Employee Reclassification Guide provides a structured approach to requesting job title, salary, or role adjustment for employees seeking to advocate for their reclassification. Lastly, we have added specific examples of job responsibilities and how job positions were updated (by level of position) through reclassification.
Prison Education Programs (PEP)
NASFAA continued its efforts surrounding Prison Education Programs (PEP), including providing financial aid administrators updated on tools, training, and news related to the implementation of financial aid in carceral settings. Sheila Meiman, NASFAA’s Prison Education Specialist, held on-demand webinars, including one focused on the PEP application and the E-App process, and another on critical partnerships in administering PEP. In June, NASFAA also held its second annual PEP Convening, an event critical to strengthening higher education opportunities for incarcerated individuals. Titled "Aligning Efforts: Navigating the Intersection of Student Services and Prison Education," the convening brought together a diverse array of professionals pivotal to the success of prison education.
College Cost Transparency (CCT) Initiative
NASFAA, along with leaders from nine other higher education associations representing college presidents, financial aid offices, and admissions and school counselors, continued their work with the College Cost Transparency initiative. The goal of the initiative is to improve the clarity, accuracy, and consistency of student financial aid offers by producing a set of guiding principles and minimal standards to be used when developing aid offers. To date, the CCT initiative has partnered with 732 institutions, serving nearly 7 million students.
NASFAA On the Record
Letters
Request For Information Responses: Enhancing Transparency and Reducing Student Costs
October 28, 2025 - In response to a Request For Information (RFI) from the Senate HELP Committee, NASFAA provided comments and feedback on enhancing transparency in higher education and reducing student costs.
NASFAA Joins Organizations in Opposing Trump Administration’s Higher Education Compact
October 17, 2025 - NASFAA, along with other organizations, released a statement opposing the Trump administration’s higher education compact, outlining concerns that the proposal threatens “to undermine the very qualities that make our system exceptional.”
NASFAA Signs Onto Letter Providing Feedback on the Redesign of IES
October 15, 2025 - NASFAA, along with over 50 organizations and partners, signed onto a letter to the Department of Education (ED) in response to its Request for Information about redesigning the Institute of Education Sciences (IES).
NASFAA Expresses Concerns Over ED’s Admissions and Consumer Transparency Supplement (ACTS) Survey
October 7, 2025 - NASFAA, along with other higher education organizations, sent a letter to the Department of Education (ED) outlining multiple concerns regarding the department’s proposed new IPEDS Admissions and Consumer Transparency Supplement (ACTS) survey.
NASFAA Calls on Congress to Restore ‘Critical’ MSI Funding
October 3, 2025 - NASFAA, along with 20 other higher education organizations, called on congressional leaders to restore this funding and to increase federal investments for Minority-Serving Institutions (MSI) in fiscal year (FY) 2026.
NASFAA Raises Concerns Over ED’s Proposed PSLF Regulations
September 17, 2025 - NASFAA outlined its concerns with the Department of Education’s (ED) proposed regulations to the Public Service Loan Forgiveness (PSLF) program, warning that some of the currently drafted provisions could deeply harm borrowers.
NASFAA Calls on Appropriators to Fund Key Labor-HHS-Education Programs for FY 2026
July 25, 2025 - NASFAA, along with over 500 organizations, called on congressional budget appropriators to properly fund labor, health, and education programs in the appropriations process, which is currently underway.
NASFAA Signs Onto Letter Opposing Trump’s FY 2026 Proposed Cuts to Pell Grants, Campus-Based Aid, TRIO Programs
June 13, 2025 - NASFAA, as part of the Student Aid Alliance, signed onto a letter urging lawmakers to continue their bipartisan support of federal student aid programs in fiscal year (FY) 2026 and oppose the Trump administration’s proposed cuts to several programs.
NASFAA Signs Onto Community Letter Opposing Reconciliation Bill
May 21, 2025 - NASFAA, along with over a dozen higher education organizations, signed onto a letter strongly opposing the House’s reconciliation bill, writing that if enacted, the bill would put college out of reach for hundreds of thousands of students.
NASFAA Joins Call for Trump Administration to Reforge Its Partnership With the Higher Education Community
May 14, 2025 - NASFAA, along with dozens of higher education organizations representing institutions across the country, called on the Trump administration to work together and reforge the relationship with the higher education community.
NASFAA Signs on to Letter Urging Congress to Preserve PSLF
April 9, 2025 - NASFAA, along with dozens of higher education organizations, led by the PSLF Coalition, sent a letter to House and Senate education committee leadership urging them to preserve the Public Service Loan Forgiveness (PSLF) Program.
NASFAA Urges ED to Confirm Funding Levels for Higher Education Programs
April 7, 2025 - NASFAA, along with over a dozen higher education organizations, led by the American Council on Education, sent a letter urging the Department of Education (ED) to confirm the funding levels for all higher education programs.
NASFAA Joins Call on ED to Rescind DCL on Ending Racial Preferences, Requests Collaborative Process With Higher Education Community
February 25, 2025 - NASFAA sent a letter to ED asking it to rescind its recent Dear Colleague Letter, which told institutions to cease using "racial preferences" in admissions, financial aid, and other areas, or be at risk at losing federal funding.
NASFAA Presses New Administration to Extend GE/FVT Reporting Deadline to July 2025
January 29, 2025 - With a new presidential administration in office, NASFAA, along with over 50 higher education organizations, called on the Department of Education to extend the institutional reporting deadline for GE and FVT.
Comments to ED
NASFAA Comments to ED on Proposed Revisions to the FSA Feedback System
November 10, 2025 - NASFAA is pleased to share its comments submitted to the Department of Education (ED) in response to its comment request on proposed revisions to the Federal Student Aid (FSA) Feedback System.
NASFAA Comments on Proposed Revisions to the E-App
October 24, 2025 - NASFAA submitted comments to the Department of Education (ED) on Friday, in response to its comment request on proposed revisions to the Application for Approval to Participate in the Federal Student Financial Aid Programs (E-App).
NASFAA Comments to ED on Direct Loan Common Manual RFI
October 15, 2025 - NASFAA submitted comments to the Department of Education (ED) in response to its request for information on a proposed Direct Loan common manual.
NASFAA Comments to ED on IES Redesign Plans
October 15, 2025 - On Wednesday NASFAA submitted comments to the Department of Education (ED) in response to its Request for Information on a proposed redesign of the Institute for Education Sciences.
NASFAA Submits Comments Regarding PSLF
September 17, 2025 - NASFAA submitted comments to the Department of Education (ED) on Wednesday, strongly opposing the department’s proposal to narrow the definition of qualifying employers for PSLF.
NASFAA Submits Comments Regarding PSLF
September 17, 2025 - NASFAA submitted comments to the Department of Education (ED) on Wednesday, strongly opposing the department’s proposal to narrow the definition of qualifying employers for PSLF.
NASFAA Submits Comments Regarding ED's NegReg Committees Focused on New Provisions Under the 'One Big Beautiful Bill Act'
August 28, 2025 - NASFAA submitted comments on ED's notice regarding its intent to establish two negotiated rulemaking committees to address the significant changes to federal student aid programs initiated by the 'One Big Beautiful Bill Act.'
NASFAA Comments on Second Draft of 2026-27 FAFSA
June 13, 2025 - NASFAA on Friday submitted comments to the Department of Education on its second and final round of revisions to the 2026-27 FAFSA.
NASFAA Submits Comments For Revising the Income-Driven Repayment (IDR) Plan Request Form
June 6, 2025 - NASFAA submitted formal comments to the U.S. Department of Education regarding revising the Income-Driven Repayment (IDR) Plan Request form, necessitated by a recent court injunction impacting the SAVE plan.
NASFAA Signs Onto Letter Responding to OMB’s Information Request on Deregulation
May 12, 2025 - NASFAA signed onto a letter in response to the Office of Management and Budget’s request for information on rules to be targeted for rescission, or deregulation, providing a list of guiding principles and feedback to the administration.
NASFAA Shares Comments for Upcoming NegReg on PSLF, IDR and Other Financial Assistance Programs
May 6, 2025 - NASFAA has submitted comments on the Department of Education's (ED) notice regarding potential negotiated rulemaking topics. In this feedback, NASFAA addressed several key areas proposed for negotiation.
NASFAA Comments on 2026-27 FAFSA
April 7, 2025 - NASFAA is pleased to share its comments on the 2026-27 FAFSA. In this first round of comments, NASFAA praised ED for resuming its standard FAFSA schedule including two rounds of public comments and a planned October 1 release.
Publication Date: 1/5/2026
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