Financial Aid Graduation Requirement - FAQs

Frequently Asked Questions

Section 1: Applicability of Requirement and Exemptions

1.1 - Does the financial aid application graduation requirement apply to private schools?
No. The requirement applies to students graduating from a high school in a public school district or open-enrollment charter school in Texas, starting with seniors in the 2021-22 school year.  

1.2 - Does the financial aid application graduation requirement apply to: 

• highly mobile, homeless/unaccompanied youth, as defined by McKinney-Vento? 
• students receiving special education services?
• recently transferred students?
• students over 18 years old enrolled in accelerated or alternative high school programs?
• seniors graduating prior to October 1 in a school year?
• students who plan to enlist in the military?

Yes, the financial aid graduation requirement applies to any public high school student enrolled in grade 12 during the 2021-2022 school year or later.  Texas Education Code (TEC) §28.0256 allows exemptions under the following conditions:

• A student's parent/guardian signs and submits a form to decline or authorize the student to decline (i.e., opt-out) to complete and submit the financial aid application
• A student who is 18 years or older or an emancipated minor under Texas Family Code Chapter 31 signs and submits an opt-out form
• A school counselor authorizes a student to opt-out for good cause

Good cause should be locally defined by the district or charter school and may include criteria determined to be appropriate for the local education agency (LEA).  Further, under TEC §28.025, a school counselor may not indicate a student has not complied with the requirement if the district or charter school failed to provide the opt-out form to the student or their parent/guardian. 

1.3 - If a grade 12 student is not on track to graduate, does the student have to complete the FAFSA or opt out?

No. However, the student will need to complete a financial aid application or opt-out before the student graduates.

1.4 - Does a 5th-year senior who completed the financial aid application or opted out in the previous school year need to submit the application or opt out form again?

No. The statute does not require repeated financial aid applications or opt-out forms.

1.5 - For students receiving special education services and who may be identified as enrolled in grade 12 for multiple years while completing the provisions of the Individual Education Plan (IEP), are they required to submit a financial aid application or opt-out form in a school year they are not scheduled to graduate?
No. However, the student will need to complete the financial aid application or opt-out form before the student graduates.

1.6 – May a student complete a financial aid application in grade 11 to meet the graduation requirement? 
No. The financial aid application must be completed in grade 12. However, if the student intends to graduate in grade 11, then the requirement must be met prior to graduation. If the student does not graduate in grade 11, they must complete and submit an application or sign and submit an opt-out form in their grade 12 year.   

Section 2: Financial Aid Application Opt-Out Form

2.1 - Is there a standard opt-out form for the financial aid application graduation requirement? 
TEA has published the Financial Aid Application Opt-Out Form on its website in both English and Spanish. The form was revised in October 2021 to reflect changes in state law. The LEA must make the form available in any other language spoken by a majority of students enrolled in a bilingual education or special language program under Subchapter B, Chapter 29.

2.2 - What should I do if a parent refuses to complete a financial aid application or is not willing to provide information necessary for its completion?
The parent may sign and submit to the district or charter school the Financial Aid Application Opt-Out Form. 

2.3 - What if a parent fails to provide financial information for a student's financial aid application? May the student submit the application without this information to graduate? 
If the student is considered a dependent for financial aid purposes, the financial aid application form is not complete without the parent's financial information. Although the form can be submitted, the student will receive an email that the application form was not processed, and the financial information will need to be entered and re-submitted. Submission prior to form completion does not meet the graduation requirement. State law provides parents the option to decline or authorize their student to decline to complete and submit the financial aid application through use of the opt-out form. 

Since the requirement provides an opportunity for students and families to learn about the financial aid application process, it is highly encouraged that school counselors continue to assist students with appropriate instructions on how the form is completed and what steps are necessary to access federal and state financial aid as the student and family may later decide to complete the application.

2.4 - What reasons may a parent provide to use the Financial Aid Application Opt-Out Form? 
A parent or guardian does not need to provide a reason for signing and submitting the opt-out form to authorize their student to decline. However, LEAs are encouraged to provide families information on the benefits of applying for financial aid. 

2.5 - What reasons may a student 18 years or older provide to use the Financial Aid Application Opt-Out Form? 
A student 18 years or older or an emancipated minor as described in Texas Family Code, Chapter 31, does not need to provide a reason for signing and submitting the opt-out form to decline. However, LEAs are encouraged to provide students information on the benefits of applying for financial aid, even if they currently do not anticipate postsecondary enrollment.

2.6 - Is there a date by which a student must turn 18 years old to sign the opt-out form independently? 
For option 1, the student must be eligible on the date of signature on the opt-out form. The opt-out form must be submitted prior to high school graduation. A student may exercise Option 1 from the day they turn 18 up to high school graduation. 

2.7 - May a school counselor sign the Financial Aid Application Opt-Out Form for all students on the campus?
No. School counselors are only able to authorize a student to decline the financial aid graduation requirement based on 'good cause' in agreement with the student and as determined by local policy.

2.8 - What reasons may a school counselor provide to use the Financial Aid Application Opt-Out Form? 
A school counselor may authorize a student to decline submission and completion of a financial aid application for 'good cause' as defined by local policy. The student should be made aware that use of the opt-out form does not affect the student's ability to apply for financial aid at any time, including during the current school year. 

2.9 - Must the student sign the Financial Aid Application Opt-Out Form? 
The student must provide a signature under the applicable option being used to satisfy the requirement for graduation. Option 1 (student declines) and Option 3 (counselor authorization) require a student's signature. A student signature is not required under Option 2 in which a parent declines on the student's behalf. 

2.10 - May an electronic signature be used?
Texas Government Code, §2054.060(b) provides that "[a] digital signature may be used to authenticate a written electronic communication sent to a local government if it complies with rule adopted by the governing body of the local government. Before adopting the rules, the governing body of the local government shall consider the rules adopted by [DIR] and, to the extent possible and practicable, shall make the governing body's rules consistent with the department's rules." In Subsection (e) of that section, "digital signature" is defined as "an electronic identifier intended by the person using it to have the same force and effect as the use of a manual signature."

An electronic signature is satisfactory if it is executed pursuant to rules adopted by the governing body [school board] as provided by Texas Government Code, §2054.060(b). In the event of an agency audit or when transferring records to another district in which the student enrolls, the district would need to be able to provide documentation to the agency or to the receiving district that the [form] for the student was signed by the appropriate party regardless of the method used.

2.11 - Must the school counselor sign the Financial Aid Application Opt-Out Form if a parent and/or student signs the form under Option I or II? 
No, the school counselor only needs to sign the opt-out form under Option III for good cause.

2.12 - Must the student sign the Financial Aid Application Opt-Out Form if a parent signs the form under Option II? 
The student must sign the opt-out form under Option II if the parent checks the box, "authorizes my child to decline to complete and submit a financial aid application (parent and student signature required)." If the parent checks the box, "certifies that I decline to complete and submit a financial aid application on behalf of my child (parent signature only)," the student signature is not required. If the parent checks both boxes, the student signature is not required.

2.13 - Are financial aid advisors or other advising-related staff who are not certified school counselors authorized to submit an opt-out form for good cause under Option III of the opt-out form? Can an administrator sign the opt-out form if the district does not have a certified school counselor on staff?
No. There is not an opt-out option for a district or charter school that does not employ a school counselor. The student or parent, depending on the age of the student, could choose to opt out in such an instance. A district may considered hiring a school counselor on a contract basis to address this and other issues that require school counselor action. 

2.14 - Must the Financial Aid Application Opt-Out Form be filed with the students' cumulative records?
Please follow the state and your district's records retention policy for documents related to this requirement. In the event of agency audit or when transferring records to another district in which the student enrolls, a district must be able to provide documentation to the agency or to the receiving district that the form with appropriate signatures was submitted.

LEAs are required to report the completion of the opt-out form for financial aid application graduation requirement through the Texas Records Exchange (TREx) element TE139, Financial-Aid-Application-Code using code (2), "Exemption Submitted" in the table TC46.

2.15 - Does the Financial Aid Application Opt-Out Form need to be submitted to TEA?
No. Completion of the opt-out form may be reported to TEA via TSDS PEIMS using code (2) "Exemption Submitted" for element E1724 Financial Aid Application Code.

2.16 – May a student submit a photo of the signed opt-out form? 
A photo is acceptable as an electronic submission dependent on local policies and rules for such submissions. Regardless of the submission method used, districts must update the student record to reflect whether the student met the financial aid application requirement by submitting an application or formally opting out. 

Section 3: Methods of Proof and Tracking Requirement

3.1 - How should I collect proof that a student has submitted a FAFSA?
FAFSA completion and submission may be confirmed using one of the following:

• Date included in the "FAFSA Process date" field in ApplyTexas Counselor Suite FAFSA data; or 
• Notification from USDE that demonstrates a student has completed and submitted a FAFSA, such as an email confirmation of submission; or
• Alternate proof of FAFSA completion that may be provided by a student based on the local policy developed by a district or charter school. Some examples may include:
  • Screenshot of FAFSA submission acknowledgement page
  • Financial aid award letter from an IHE
  • Other, as established by local policy

Although a student does not use ApplyTX to apply to an institution, the ApplyTX Counselor Suite receives FAFSA completion information directly from THECB on all FAFSA submissions. An LEA may access these data through an account created by this process.

3.2 - How should I collect proof that a student has submitted a TASFA?
To meet the definition of "complete and submit a TASFA," the student must populate all applicable sections of the form and submit the application to at least one Texas institution of their choice. The TASFA is suggested for students who are Texas residents who are not eligible to apply for federal financial aid through the FAFSA. The process for TASFA submission may differ for students based on the institution of their choice. Although there is an available PDF version of the TASFA, an institution may have its own electronic form or paper form.

School districts and charter schools must develop a local policy for the method of proof that the student has completed a TASFA. Some examples include the following:

• Acknowledgement of receipt from an IHE
• Copy of signature page
• Screenshot of TASFA submission acknowledgement page (from those institutions that offer an electronic form)
• Other, as established by local policy

3.3 - What should I do if a community college does not process the TASFA until late spring or after the anticipated high school graduation date? 
Unlike FAFSA, the processing of the TASFA is not standardized in the state and is performed independently by each institution. LEAs may want to consider the timing of surrounding community colleges' TASFA processing when determining what method of proof is appropriate. An example of a method of proof that a LEA might want to request that a college provide is an email or letter that confirms the TASFA is received. The statute only requires 'completion and submission' of the financial aid application form. Full processing of financial aid packages is not required for high school graduation.

3.4 - What should I do if a student has submitted the FAFSA or TASFA but has been selected for income verification? Does this impact the graduation requirement? 
After completion and submission of a financial aid application, there are no additional steps needed to fulfill the high school graduation requirement if a student is selected for income verification. However, school counselors and advisors are encouraged to work with students to help them understand the income verification process, which may be necessary to receive financial aid.

3.5 - May I use ApplyTX Counselor Suite (i.e., ApplyTX CS) to track FAFSA applications for students who applied to college using the Common App or the Coalition site? 
Yes. Any student who applies using the FAFSA will be in the Counselor Suite. The FAFSA data is provided by the Texas Higher Education Coordinating Board, through an agreement with the US Department of Education (ED), to the ApplyTX System every Monday through Friday and updated at that time. Please note, the ED data is information students provided in their FAFSA forms. It is a separate data source than the ApplyTX application data provided in the ApplyTX Counselor Suite. The FAFSA data in the ApplyTX Counselor Suite matches a student by the high school name the student provides, not by individual student. This means students must select the correct high school in the FAFSA application for the information to be made available through the Counselor Suite.

The FAFSA data are only provided to districts that have an agreement with the Texas Higher Education Coordinating Board to access the ApplyTX Counselor Suite and an active user for their campus or district. 

For more information on the Counselor Suite, review frequently asked questions on the ApplyTX website.

3.6 - When is FAFSA completion information made available in the ApplyTX Counselor Suite? 
Data is first made available within a few weeks after the FAFSA application for the next academic year opens (October 1), i.e., usually mid- to late-October. Data are then updated daily, Monday through Friday, through September 30 of the following year. For example, FAFSA submission information for the school year 2022-23 application will be made available in mid-October 2021 through September 30, 2022 from 2021-22 graduates. 

3.7 - May we get a comprehensive report of FAFSA completions by campus instead of having to look up students individually? 
FAFSA completion data may be downloaded through the ApplyTX Counselor Suite. For more information on the Counselor Suite, review frequently asked questions on the ApplyTX website.

3.8 - Can TEA provide FAFSA and TASFA completion data to districts? 
No.TEA does not receive information regarding financial aid applications directly from the Department of Education or the Texas Higher Education Coordinating Board (THECB). The FAFSA data are available through the ApplyTX Counselor Suite, an application sponsored by THECB. TEA has partnered with THECB to include eTASFA completion information when the eTASFA is launched in the 2022-2023 school year for the 2023-2024 award year.

3.9 - What should I do if I have students who show up in the ApplyTX Counselor Suite as not submitting their FAFSA but they have confirmation emails for their submission? What if the student shows up as not submitting a FAFSA in the ApplyTX Counselor Suite but they have a processed date represented? 
Application corrections have resulted in some data reporting issues. When a student initially submits the FAFSA, the transaction is processed if there is a ‘processed date.” If a student subsequently reviews the application and makes a correction, another record is created that will show the FAFSA was not complete but a ‘processed date’ will still appear. Currently, for reporting purposes, if there is a ‘processed’ date, the student has successfully completed and submitted the FAFSA application.

Section 4: Reporting

4.1 - Will the financial aid application graduation requirement appear on a student's transcript? 
To track students' completion of the graduation requirement for the student record, the FINANCIAL-AID-APPLICATION-CODE (TE139) and the FINANCIAL-AID-APPLICATION-MET-DATE (TE140) data elements will need to be entered in the Texas Records Exchange (TREx) System.

The FINANCIAL-AID-APPLICATION-MET-DATE (TE140) data element must appear on the student's transcript. The FINANCIAL-AID-APPLICATION-CODE (TE139) data element allows districts to track/transfer FAFSA completion data for the TSDS PEIMS reporting requirement in Submission 1 (graduate record). TE139 data should be part of the student record for this purpose but should not be documented on the high school transcript. Data standards for the TREx System have been published.

4.2 - When will the financial aid application graduation requirement need to be reported through TSDS PEIMS? 
Beginning with the 2022-23 school year submission 1 for the 2021-22 high school graduates, districts and charter schools will be required to report the Financial Aid Application Indicator (E1724) in TSDS PEIMS.

4.3 - What date should be reported for the FINANCIAL-AID-APPLICATION-MET-DATE (TE140)? 
The date selected for this data element is a local decision. The signature lines on the opt-out form include a date. It may be reasonable to select a date on or after the date of the last signature on the submitted opt-out form. For districts using the ApplyTX Counselor Suite for FAFSA completion information, it may be reasonable to select a date on or after the reported FAFSA processed date.

4.4 - If the student completes a FAFSA after their high school graduation but before the submission date for PEIMS reporting, may we report the financial aid application completion in TSDS PEIMS?  
No. The FINANCIAL-AID-APPLICATION-CODE (E1724) indicates the manner in which the student completed the graduation requirement. If the student did not complete a financial aid application (FAFSA or TASFA) prior to their graduation, then they must have completed an opt-out form for the requirement. The student should still be reported with a code of ‘02’ even if they later complete a FAFSA or TASFA after high school graduation.