How should your school handle the issue of undocumented parents or students?

by Mark J. Mitchell
Vice President, SSS by NAIS

“Management cares about only one thing. Paperwork. They will forgive almost anything else…as long as the paperwork’s filled out properly. And in on time.” -- Connie Willis, Bellwether

Earlier this week, a student contacted our office for information on financial aid availability given that her parents are undocumented residents here in the U.S. From time to time, schools also ask how SSS treats undocumented parents and students in the financial aid process. So, here are some things to consider as you encounter this situation and craft policy around it.

For filing the Parents’ Financial Statement (PFS), the applicant’s citizenship status is a moot point, in and of itself. That is, SSS would process the family’s PFS the same as any other family’s application. As such, the matter of how they’re treated in the SSS process is very much less significant than what additional documentation your school will require, and whether you can offer the family assistance.

Our observation has been that most schools do not provide aid to students who are not U.S. citizens, so for many schools this is a non-issue. If the family cannot prove U.S. citizenship, then aid is not provided. However, this issue is becoming more and more of a gray area for some schools and there is a growing trend — even among day schools — to enroll more international students. Given these realities, it is increasingly important to be clear about your policy on providing aid to non-citizens, particularly undocumented residents. So, what to do?

If the school receives any federal, state, or local support (subsidies or grants funded by taxpayers), even if it’s not used for financial aid grants, it may be bound by other laws governing what you can or cannot provide to non-citizens. You should check with the school’s legal counsel about that to be sure that is covered in your final policy.

Be mindful that if you enact a policy allowing undocumented citizens to apply for financial aid, you should treat them in the same manner that you’d treat any other applicant, consistent with the NAIS Principles of Good Practice. That is, evaluate their need the same way, and have the same process/standards for granting an award.

The biggest wildcard often lies in documenting income and other financials. This is one main reason why schools stop short of offering aid to undocumented citizens: the inability to document and verify the information submitted on the financial aid forms. Assuming any state-/locally-based legal restrictions aren’t there, the biggest policy issue to grapple with is how to “exempt” an undocumented parent from the regular policy requirements.

If the student’s parents are undocumented, they may not be completing 1040s or perhaps do not receive W2s, which makes it challenging to hold them to the same standards as others in the aid process and challenging to prove that their financial aid documents are true and accurate reflections of their financial status. Even contacting an employer for some income verification can be dicey because the employer may not want to be “exposed” for hiring an undocumented worker.

It is important to be clear on the issue of getting the right documents to verify the PFS. Your policy can either state something like the following:

A completed financial aid application includes the following documents at a minimum: PFS, 1040, and W2. Exceptions to these requirements may be made on a case-by-case basis in situations such as: when family income is too low to be required to file, undocumented workers who do not file tax returns, etc.

Or you could use something shorter like this:

A completed financial aid application includes the following documents at a minimum: PFS, 1040, and W2. Families unwilling or unable to produce the full set of documents will not be considered for aid.

With these considerations, the issue is not really about the documented citizenship status (even ‘documented’ people could be restricted from getting aid), so much as the ability to provide what’s needed to make a good aid decision and clarity around when/why to exempt some from those requirements.

If you agree to review/process an aid application without supporting documentation, the PFS will be all you can go on (unless you find they file some kind of 1040-type return in another country) and you’ll have to steel yourself for the possibility of incorrect, or incomplete, information being used.

Mark J. Mitchell is Vice President, School Information Services, SSS by NAIS.