Today’s Students Deserve Their Fair (Data) Share

By HLA's Amy Ellen Duke-Benfield, managing director, policy and research.


Postsecondary credentials are a good investment for individuals, families, and communities. Yet college tuition and fees have increased at a much faster rate than financial aid. As college costs continue to rise, along with food and housing prices caused by inflation, students still need to meet the most basic necessities of living. But meeting basic needs – such as food, housing, and child care – is a stressor for one out of five of today’s students; recent national data found 23% of undergraduate students experienced food insecurity and 8% of undergraduates faced homelessness. Moreover, students who are already financially stressed and students of color are facing this insecurity at disproportionately higher rates; 31% percent of Pell recipients, 35% of Black students, 30% of Native American students, and 25% of Hispanic and Latino students are food insecure. Basic needs insecurity, and in particular food and housing insecurity, adversely affects students’ well-being, as well as their college persistence and completion. For more students to complete postsecondary credentials, more investments are needed to address students’ basic needs.

But, federal and state student financial aid alone are insufficient to meet student basic needs. The combination of need-based educational financial aid and enrollment in means-tested public benefits programs such as the Supplemental Nutrition Assistance Program (SNAP), subsidized child care, and Medicaid can help increase student completion rates by addressing students’ financial stressors. Benefits Data Trust research shows that combining a Pell Grant with other assistance can double a student’s financial support for college. But accessing these benefits as a student is much easier said than done.

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Why Don’t More Students with Low Incomes Access Means-Tested Public Benefits?

Roughly 2 million of the approximately 3.3 million students who are eligible for SNAP do not participate. The reason so many students are missing out is unlikely due to hesitation to access assistance. Policies, systems, and processes make it nearly impossible for them to enroll. The process is frustrating. The rules are complex. We ask them to navigate multiple bureaucracies because different agencies administer different benefits programs. The application process is burdensome and bureaucratic, with too much paperwork requiring students to repeatedly prove their poverty, providing the same information on the Free Application for Federal Student Aid (FAFSA) as on a SNAP or child care subsidy application. Although an increasing number of benefits programs provide online applications, some still require time-consuming, in-person interviews at inconvenient locations. Students or their family members may have had a negative application experience in the past. Students may be uncomfortable seeking means-tested public benefits due to the stigma associated with receiving benefits, or may also experience social or cultural barriers to receiving assistance.

Some colleges are trying to help students overcome these barriers by offering means-tested public benefits access services on campus. Colleges can use their FAFSA data to target students who might be eligible for benefits. But this comes with its own set of challenges. Higher Learning Advocates and the National Association of Student Financial Aid Administrators conducted a survey in April 2023 on how institutions of higher education (IHEs) are using FAFSA data to alert students of their potential eligibility for benefits. Although the federal government has recommended that schools use their FAFSA data to conduct such outreach, only roughly 25% of respondents are currently conducting direct outreach to students about any federal means-tested public benefit programs. Sixty percent of institutions do not conduct direct outreach at all; citing resource constraints. We cannot afford to let the option of conducting outreach to students about means-tested public benefits to rest with institutions alone. There must be a better way to connect students to the financial assistance they need to afford the college credentials necessary for success in the labor market.


What If We Could Have One Application For Financial Aid and Public Benefits?

Unfortunately, there are numerous barriers to one application for aid and public benefits. Many of the programs have different eligibility requirements, including different income levels. One program may require income to be no higher than 138% of the federal poverty level, while another allows income levels up to 250%. Income levels are collected over different time frames, with federal financial aid requesting income information from two years prior to the application, while SNAP requests income from the month prior. As noted earlier, different programs are administered by different agencies and at different levels of government. SNAP is administered by the U.S. Department of Agriculture and Medicaid by the U.S. Department of Health and Human Services, while the U.S. Department of Education administers federal financial aid. In some states, the state administers public benefits programs, while in others they are administered by counties. To top it off, the data systems aren’t integrated, which makes it nearly impossible to match data to align programs.

Yet, innovation happens. While a means-tested public benefits applicant previously had to visit several offices to apply for different benefits, all states now provide online applications for the significant means-tested public benefits programs, with many integrating several benefits into one portal. Technology companies, like Code for America, have helped states develop online applications that are streamlined and mobile, shrinking application time from an hour to 15 minutes. Program administrators use human-centered design principles to develop new processes and systems. No one has yet developed one system that would allow individuals to apply for financial aid and means-tested public benefits, but we see glimpses of what the potential well-aligned systems hold.

State and county government agencies administering means-tested public benefits work with one another to streamline access. Several states have focused on coordinating SNAP and WIC (Special Supplemental Nutrition Program for Women, Infants, and Children) to address child hunger. In some instances, the application process is simplified by using an eligibility determination made by another program or information gathered through another program’s application process. For instance, WIC considers applicants income eligible if they receive Medicaid benefits. The applicant still has to undergo a WIC nutritional assessment, but they do not have to provide their income and other related information again. This process is referred to as “adjunctive eligibility.” Other programs offer categorical eligibility, which means an individual who receives one benefit is automatically eligible for another benefit on the basis of already meeting financial eligibility rules for that other benefit. For instance, receipt of Supplemental Security Income (SSI) makes one categorically eligible for SNAP.

Strides have also been made to simplify access to federal financial aid for those applicants who received SNAP, WIC, Medicaid, SSI, Free and Reduced Price Lunch, or Temporary Assistance for Needy Families in the two years prior to applying for aid on the FAFSA. If an applicant answers affirmatively to receiving one of these benefits, the applicant undergoes a simplified application process and is deemed to have a zero on the Student Aid Index. This may lead the applicant to qualify for a maximum Pell Grant. They are not automatically eligible for a maximum Pell Grant given their means-tested public benefit receipt, though. Someday the different systems may be so well aligned that categorical eligibility could be the case.


What Can We Do Now?

So, a single application may currently be out of reach. But progress can be made. In the meantime, data sharing can streamline eligibility processes and identify participants who may be eligible for other programs. Information-sharing is efficient, reduces hassles, and can help increase enrollment. State and county means-tested public benefits systems can enter data sharing agreements (DSAs) with state higher education and financial aid agencies and institutions to match cross-program data and automate cross-program referrals. It’s not an integrated eligibility system, but DSAs can allow state and county public benefits agencies to identify who is or is not receiving financial aid or public benefits. The social service agency or institution can use that information to reach out to students directly for enrollment or can be used to pre-populate forms so students aren’t repeatedly providing the same information. Then the institution or agency can contact students to collect any additional necessary information. Agreements can also be used for adjunctive eligibility so students already receiving means-tested public benefits are automatically eligible for aid.

There are legal, technical, and ethical considerations to data sharing that are important, complicated, and must be dealt with, (and outside the purview of this brief), but not so insurmountable to stop DSAs. Other systems have overcome these concerns and established privacy standards. Privacy is paramount when sharing income data and other eligibility information, and there are laws that protect an individual’s data, such as FERPA. Unfortunately, fears about privacy can play a bigger role than actual law in inhibiting an agency or institution from sharing data across systems.

And, it’s already happening. A handful of government agencies and institutions have established DSAs for the purposes of connecting more students to means-tested public benefits or connecting benefits recipients to financial aid.


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Washington Student Achievement Council and the Washington Department of Social and Health Services
The Washington Student Achievement Council (WSAC) has three data sharing agreements under consideration or operating with the Washington Department of Social and Health Services, the state’s SNAP agency. These DSAs achieve two goals: 1) to increase access for recipients of the state financial aid program – the Washington College Grant (WA Grant) – to means-tested public benefits and 2) to increase access to the WA Grant for recipients of means-tested public benefits. One DSA will provide WSAC with confirmation that a student receiving the WA Grant does not receive SNAP or other state benefits, which DSHS administers. With this information, colleges can provide targeted outreach and support to students who are not receiving SNAP or other benefits. Another DSA currently offers categorical eligibility for the WA Grant for participants in three small state means-tested public benefits programs (the Aged, Blind and Disabled program; the Essential Needs and Housing Support program; and the Pregnant Women Assistance program). The state legislature recently passed legislation that would authorize WSAC to offer categorical eligibility, starting in 2025-26 school year, for the WA Grant to high school students in the 10th, 11th, or 12th grade whose family receives SNAP. This will dramatically streamline access to financial aid for low-income students.


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Compton Community College District and the Los Angeles County Department of Public Social Services (DPSS)
California’s SNAP benefits program, called CalFresh, is administered by counties. This means that colleges enter into DSAs with their county DSS, instead of the state. The Compton Community College District and the Los Angeles County Department of Public Social Services (DPSS) have a memorandum of understanding to share data in order to increase the utilization of CalFresh benefits among Compton’s students from low-income backgrounds. Compton shares data about its students with DPSS to enable the agency to verify CalFresh receipt and conduct screening of students who may be potentially eligible to receive CalFresh benefits. DPSS then returns information about Compton students’ eligibility for and use of CalFresh benefits so that Compton may conduct outreach to its students. Compton asks each student to provide authorization to allow Compton to share the student’s data with DPSS.1 Other California county DPSS agencies, including San Bernardino and Riverside, are also interested in developing similar DSAs with colleges and universities to increase CalFresh receipt among students.


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Additional State Efforts
The Kentucky Community and Technical College System has a DSA to match cross-program data with the Department of Community-Based Services that will provide institution-based benefits navigators the information to conduct targeted outreach to students who may be eligible but are not receiving public benefits. The Colorado Department of Higher Education and the Colorado Department of Human Services are exploring ways to leverage avenues of shared data governance (such as statewide longitudinal data collaborations) to facilitate college student access to benefits, as well.


What Is the Role of the Federal Government?

Although much of the movement to share data to streamline access to financial aid and means-tested public benefits is happening at the state and county level, the federal government has a role to play, too. In 2021, the Biden Administration issued an Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government. It notes that in recent years the annual paperwork burden imposed by federal departments and agencies on the public has been in excess of 9 billion hours and instructs agencies to work with a range of entities, including state and local governments to “design experiences with the Federal Government that effectively reduce administrative burdens…[and] simplify both public-facing and internal processes to improve efficiency.”


We must use technology to modernize Government and implement services that are simple to use, accessible, equitable, protective, transparent, and responsive for all people of the United States.

– Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government


The federal government has the tools to simplify student access to public benefits, beginning with the FAFSA. Existing law requires students to provide written consent prior to sharing FAFSA data. Collecting consent is burdensome at the institutional level. Adding a checkbox to the FAFSA would allow students to express whether they are interested in being contacted about potential benefits eligibility and provide the authorization for their data to be shared. The US Department of Education’s Federal Student Aid office could then share this data with federal, state, and county agencies to facilitate student applications for benefits. These entities could use human-centered design and behavioral science to develop text or email messages that would elicit a response from students.

Federal agencies can offer support and encouragement to states and counties embarking on DSAs with institutions. The recently updated Higher Education Act states, “The Secretary may enter into data sharing agreements with the appropriate Federal or State agencies to conduct outreach regarding, and connect applicants directly with, the means-tested Federal benefit programs…for which the applicants may be eligible.” Over the course of the COVID-19 pandemic, ED designated many of those agencies as entities that can use FAFSA data to aid in the administration of programs, a significant step toward creating DSAs.



Students need access to financial support beyond Pell Grants and state educational financial aid to adequately address the basic needs insecurity that interferes with their postsecondary goals. Means-tested public benefit programs offer a potential solution to help ease financial stressors. Unfortunately, government and technology innovators haven’t yet developed a single application to provide students an easy pathway to getting the support they need, but strides forward are being made. Some states and county government health and human service agencies and higher education agencies and institutions are sharing data as a means of streamlining access – matching data to identify students who could benefit from SNAP or to make individuals in some public benefits programs automatically eligible for state financial aid. These innovations are promising. The federal government also has a responsibility to facilitate data sharing by adding a checkbox to the FAFSA that allows students to directly notify the government they are interested in applying for means-tested public benefits. It can also use its bully pulpit to encourage more states, county government agencies and higher education institutions to do the difficult work of developing DSAs.



  1. At least twice a year Compton provides data to DPSS for students who sign authorizations. These data include any information that is relevant to the identification of each student and the determination of each student’s eligibility to receive CalFresh benefits. Such data include the student’s contact info, date of birth, income, family size, and the number of dependents. DPSS uses this data to determine if the student is receiving or would be eligible for CalFresh benefits and shares the information with Compton to conduct CalFresh outreach and analyze the data to determine the impact of CalFresh benefits on students’ educational outcomes.

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