Student Financial Aid:

Need Determination Could Be Enhanced through Improvements in Education's Estimate of Applicants' State Tax Payments

GAO-05-105: Published: Jan 21, 2005. Publicly Released: Jan 28, 2005.

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Cornelia M. Ashby
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In 2003, the Department of Education (Education) proposed an update to the state and other tax allowance, a part of the federal need analysis for student financial aid. Most federal aid as well as some state and institutional aid is awarded based on the student's cost of attendance less the student's and/or family's ability to pay these costs--known as the expected family contribution (EFC). The allowance, which accounts for the amount of state and other taxes paid by students and families, effectively reduces the EFC. Given the potential impact of the allowance on the awarding of aid, we determined what factors have affected the updating of the tax data on which it is based, the effects the proposed 2003 update would have had on financial assistance for aid applicants, any limitations in the method for deriving the allowance, and strategies available to address them.

While Education has been required to revise the allowance annually since 1993, prior to 2004 it attempted to update the allowance only twice--in 1993 and again in 2003--but the latter update was suspended. As a result, the 1988 IRS tax data used for the 1993 update remained in effect. The lack of updates is primarily because Education did not annually seek data needed to update the allowance or establish effective internal control to guide the updating process. Also, Education did not consider alternatives when data were not readily available. Had the update been implemented in 2004-2005, the allowance would have decreased for most states; as a result, the EFC would have increased by about $500, on average, for a majority of aid applicants. Of those with an EFC increase, 38 percent would either have received less in Pell Grants ($144 less on average) or would have become ineligible for them; the percentage of recipients affected would have varied by income. Overall Pell Grant expenditures would have decreased by $290 million. Increases in EFCs could also have affected other forms of aid, including state aid; these effects in turn could have affected Stafford loans and Parent Loans for Undergraduate Students. The impact of the proposed update on Campus-Based, state, and institutional need-based aid would likely have varied based on state and institutional aid awarding policies and changes in state allowances. Due to certain limitations of the IRS dataset with respect to calculating the allowance, and problems with how Education uses this dataset, the current allowance may not reflect the amount of taxes paid by students and families. The dataset is limited because the taxpayers included in it are generally not representative of aid applicants, it does not include all state and other taxes paid by students and families, and the tax data are several years older than the income information reported by applicants on aid applications. In addition to these limitations, Education does not make full use of the dataset to better reflect the varying tax rates paid by taxpayers in different income groups. Strategies we identified for addressing the limitations of the tax allowance include (1) using IRS data with revisions to the method for calculating the allowance, (2) substituting IRS data with one of several alternative data sources, (3) using a standard allowance for all aid applicants irrespective of state of residence, or (4) collecting tax information directly from aid applicants. These could require modest to substantial changes, would differ in their impact on applicants and federal costs, and could require legislative changes

Recommendations for Executive Action

  1. Status: Closed - Implemented

    Comments: The Department of Education has developed formalized procedures for updating the federal need analysis formula's state and other tax allowance. The written procedures identify the needed data--Statistics of Income (SOI) data--and note where they may be obtained. The procedures also include steps on how to calculate the allowance for parents as well as various categories of students (dependent and independent) and stipulate that the most recent tax-year data available should be used for updating the allowance.

    Recommendation: To ensure that relevant tax data from the Statistics of Income are requested systematically and that the most recent data are obtained, in the short run, the Secretary of Education should develop formalized updating procedures and document such procedures in writing. Such procedures could include (1) making annual written requests to the Internal Revenue Service for state and local tax information and documenting those requests and (2) coordinating with the IRS to make sure Education knows when SOI data will be publicly released and to ensure that the most currently available data are used.

    Agency Affected: Department of Education

  2. Status: Closed - Not Implemented

    Comments: The Department of Education (Education) stated in 2006 that it prefers to continue to use publicly available information in the annual updates of all the need analysis formula parameters and thus could not accommodate this recommendation for the 2006-07 award year. In 2008, Education reported that it decided to propose a statutory change to increase the various income protection allowances in the need analysis formula as a substitute for the state-specific tax tables. Although OMB approved this approach, the statutory change was not implemented, and the formula still uses a state and other tax allowance. In 2009, Education reported that it had not released specific recommendations regarding its FY 2010 budget policy to streamline the financial aid process, thus it is premature to engage a process that would modify current practice regarding the need analysis formula.

    Recommendation: To better capture the amount of taxes paid by students and families, in the short run, Education should revise its methodology for calculating the state and other tax allowance. Revisions could include using tax figures reflective of the different income groups to calculate the allowance rather than figures based on all itemized tax returns.

    Agency Affected: Department of Education

  3. Status: Closed - Implemented

    Comments: In 2006, the Department of Education reported that it assessed the data and decided to propose a statutory change to increase the various income protection allowances in the need analysis formula as a substitute for the state-specific tax tables. In documentation provided by Education in July 2008, the agency explained that it decided to pursue the statutory change because IRS data are not timely and that the increased income protection allowances will provide larger benefits to lower-income applicants. OMB approved this approach to the issue. Education addressed this recommendation by assessing the data and seeking statutory changes.

    Recommendation: To determine whether alternative methodologies and data would better enable Education to annually update the allowance, in the longer run, Education should assess the cost and reliability of available data, including the alternative data sources identified in this report. If Education determines that statutory changes are needed to implement more effective alternatives, it should seek such changes from Congress.

    Agency Affected: Department of Education


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