The message went out to 8,000 people.
Late last week, a national college-access organization sent an urgent email to its members: Students who haven’t previously filed the Free Application for Federal Student Aid, or FAFSA, should “make a considered decision” about whether to do so. Undocumented immigrants who contribute to the form, the email said, could be “targeted for punitive action in the future.” It was a warning, a word of caution, at a time when families of mixed immigration status find themselves in a perilous position.
The email came from the National College Attainment Network, known as NCAN. Its members work at small and large organizations in almost every state, helping low-income and first-generation students apply to college and find a way to pay for it. Since the presidential election, some of those members have been asking NCAN’s leaders about the privacy of FAFSA data. Is it still safe for undocumented parents to submit their personal information on the form?
NCAN delivered its answer in the email, which had an informal but somber tone. “We share your concerns and send this message with a heavy heart,” it said. Though the Higher Education Act (HEA) prohibits the use of FAFSA data for any purpose besides determining and distributing federal aid, the email explained, “we cannot assure you at this time that data submitted to the U.S. Department of Education as part of the FAFSA process will be protected.” For some mixed-status families, the message continued, the potential risks of submitting the application “could now outweigh the considerable benefits of federal student aid.”
Kim Cook, NCAN’s chief executive, was unavailable for an interview early this week; two other officials at the organization declined to comment. In a blog post on Monday, NCAN said it understood the “grave ramifications” of its recommendation to families, which it said it chose to share “in light of the priorities publicly outlined by the incoming administration and based on our understanding of FAFSA data and agency practices.”
NCAN’s email was just one dash of guidance from one of Washington’s many associations. But it was also a revealing moment and a sign of the uncertain times ahead: The imminent return of President-elect Donald J. Trump, who has described his plans for mass deportations of undocumented immigrants, has shattered a sense of normalcy. All of a sudden, NCAN, which has long urged students everywhere to submit the FAFSA, was now telling some of them to think twice about it, all because the political climate has turned colder for many mothers and fathers who aren’t U.S. citizens.
Amid recent reporting on the Trump administration’s plans for workplace raids and detention camps for undocumented immigrants, some college counselors have been grappling with what to tell high-school students whose parents lack a Social Security number. Teresa Steinkamp, director of advising at the Scholarship Foundation of St. Louis, said it has been her top worry since November 6, the day the nation woke up to the inevitability of a second Trump term. She didn’t have a magic speech in her head — just an understanding that she would need to handle each conversation with great care, on a case-by-case basis. “Not every family,” she said, “is going to have the exact same thoughts and feelings about this.”
We’re trying to figure out what the gray areas are and how big a risk this is for families. We wouldn’t want FAFSA data to be used to enforce any immigration law. We just don’t know yet how concerned we should be about that possibility.
Students born in the United States are eligible for federal aid even if their parents aren’t U.S. citizens. About 340,000 students in mixed-status households submit a FAFSA each year, according to the U.S. Department of Education (about 17 million forms are submitted in all). Fwd.us, an advocacy group, estimates that nearly 500,000 students between the ages of 17 and 21 have at least one undocumented parent.
Steinkamp knows all too well that many mixed-status families struggled to complete the FAFSA process during the disastrous 2024-25 cycle because of various technical issues with the form; for months, undocumented parents weren’t able to create a Federal Student Aid ID, now required of all contributors to the form. Though the Education Department eventually provided updates and workarounds for such families, some continued to encounter problems with the form that delayed their financial-aid offers from colleges.
Then, this fall brought another wave of FAFSA-related anxiety. “This population of students — and their families — has been through so much already,” Steinkamp wrote in an email to The Chronicle on Monday. “Although I do not want to discourage students from pursuing their education or applying for the necessary funds to make it possible, I also know we have a responsibility to consider their safety and well-being.” She plans to have frank conversations with families about what the FAFSA requires, to encourage students and parents to discuss their comfort with it.
After NCAN issued its guidance, a spokesperson for the Education Department told The Chronicle in an email that, under the policies of the Biden administration, the agency “has not provided information gathered through FAFSA to any federal immigration-related agency for law-enforcement activities.” But the spokesperson couldn’t speak for the incoming administration or say what that administration might do with information collected on the federal-aid form. “Students and their families,” the spokesperson wrote, “should make the decisions that are right for them.”
But how would they know what’s right? Not every family will have informed experts like Steinkamp to help them think things through. “Although there has been no history of information from the Department of Education being shared with other government entities that might take that information and use it to deport people,” she said, “I don’t feel like it is my place to assure families that it can’t or won’t happen in the future. They need to make those decisions for themselves, and I’m prepared to help them, regardless of the decision that they make.”
Those decisions, in St. Louis and everywhere else in the United States, would surely pit many families’ hopes for the future against their fears of one day being ripped apart.
Two immediate questions arise from NCAN’s guidance. The first: What can the federal government do with the personal data families provide via the FAFSA, according to applicable laws and policies? The second: Will the answers even matter if the Trump administration decides to flex its muscles, double down on deportations, and ignore apparent constraints?
Karen McCarthy has been thinking carefully about the first question. “This has been on our radar, but we’re still figuring out what the relevant law is here and digging into how much interpretation may be in play,” said McCarthy, vice president for public policy and federal relations at the National Association of Student Financial Aid Administrators, or NASFAA.
McCarthy has a lot to dig into, like the Privacy Act of 1974, which established a code of fair information practice that governs the use of personally identifiable information in records maintained by federal agencies. The federal law prohibits the disclosure of information from a system of records without an individual’s written consent, but there are several exceptions.
The Federal Student Aid office’s privacy policy explains that the Education Department may share students’ information without consent for “routine uses.” That allows federal agencies to share information for designated purposes, which must be published in the Federal Register.
The department also publishes a list of answers to frequently asked questions for students whose FAFSA contributors don’t have a Social Security number. One of them states, in part, that the department may share personal information with other federal agencies, such as the Social Security Administration, when verifying information, but that it “will only share information on the applicant (the student), not any of their contributors, with the Department of Homeland Security to confirm citizenship and eligibility for federal student aid.”
Also, that FAQ explains, any federal agency that receives such information from the department may use the data only for explicitly authorized purposes. “This does not include any immigration or enforcement actions,” it states.
McCarthy said NASFAA will continue assessing the concerns NCAN raised. “We’re trying to figure out what the gray areas are and how big a risk this is for families. We wouldn’t want FAFSA data to be used to enforce any immigration law. We just don’t know yet how concerned we should be about that possibility.”
David A. Hawkins, chief education and policy officer at the National Association for College Admission Counseling (NACAC), said that counselors who advise mixed-status families have long worried about the federal government using undocumented parents’ FAFSA information against them. “To date, those fears haven’t been realized, but the election has put those fears into a new context,” he said. “It has sent shock waves throughout our community. People don’t know what to expect from this administration. With all the rhetoric around deportation, there could be a lot of precedent-shattering moves with this administration.”
Some of NACAC’s members have been asking the association to advise them on counseling mixed-status families, and Hawkins said the organization feels a sense of urgency to provide helpful information: “We’re going to be very deliberate about talking with other stakeholders before we put out formal guidance.”
NCAN shared its guidance a few hours after the 2025-26 FAFSA officially became available to all students late last week. That caused some emotional whiplash in high schools. One college counselor told The Chronicle that, upon seeing that the form was ready to roll, he urged several of his students to go ahead and complete it. Later, after reading NCAN’s message, he reached out to a student with undocumented parents and said, “Come see me.” Then came an awkward chat about why the student might want to hold off on submitting the FAFSA right now.
One challenge is that no one can say when, or if, further guidance will arrive, which leaves counselors and families in a difficult spot. Aaron Fulk, director of college counseling at the University School of Nashville, has advised many students from mixed-status families during his career, including at two private schools in California. “It’s a gross generalization, but these families are already wary of filling out any form,” he said. “It’s difficult to convince many of them to fill out the FAFSA. So if you’re like, ‘Hey, you’re probably going to need to do this, but maybe don’t do it now,’ you’re condemning that student. At that point, many of them are not going to fill that FAFSA out. There’s no way to deliver that message with nuance.”
Some college-access experts describe NCAN’s guidance as premature, if well-intentioned; others worry that it will prove harmful. Sara Urquidez is executive director of the Academic Success Program, which provides college advising to 7,000 high-school seniors in Dallas, Houston, and College Station, Tex. She and her colleagues advise many mixed-status families; she understands why some might feel anxious.
Still, Urquidez thinks it’s important to wait and watch, carefully, what happens when the new administration takes over before stoking those anxieties. “Trump, obviously, has done unprecedented things,” Urquidez said, “but there’s no precedent for FAFSA data being used for other purposes. So, this guidance seems purely speculative. It’s really damaging to perpetuate a culture of fear. I worry about students being opted out of this process early. I worry that this is just going to dissuade them from going to college.”
For many students, the FAFSA is a gateway to college. Sooner or later, we’ll find out if there’s a good reason for some families to think of it as a trap door.
