Some changes can be implemented without making the major FAFSA changes that ED says cannot be made right away. I don’t see anything that says, for example, the move to ignore student gifts from the formula won’t occur earlier. Similarly, nothing says that the move to ignoring multiple children in college in the formula won’t be implemented earlier. The concern ED has is in the FAFSA simplification … formula changes happen often, so they may well end up implementing some of the changes in 2023-24, after all. This is wait-and-see right now. As it stands, everything has to be implemented by 2023-24. Congress will specify exactly what can wait, and anything not included in that legislation will be statutorily required to be implemented in the original timeframe.
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