...it is reasonably possible for a FIRE parent to hack FAFSA in various ways...
Care to expand on this for the newbies? I have a kid who will be applying in a few years.
Sure. Thanks for asking!
For me there were several components to what I did:
0. As background, one key thing to know is that the FAFSA rules have changed in the past year or so. The new rules are due to a law called FAFSA Simplification, which was passed a few years ago but mostly only implemented last year. As you read web pages and blogs, keep this in mind. The new rules are very very roughly similar to the old rules but differ in many key details, and you don't want to be relying on outdated information because it will cost you.
My kids are all done with college, so I haven't been keeping up any more on the FAFSA news. What I actually did was sit down with the FAFSA Simplification law and read through the whole thing. That's a bit confusing because it's written in terms of a set of modifications or amendments to the previous law, so you have to sort of get your bearings and look up the previous law to understand the new law.
It does seem that there are very few blog articles out there that accurately describe all the loopholes and hacks contained in the new rules, but maybe I just haven't been looking for those articles.
1. Not specifically FAFSA related, but I did a "everything" strategy. When my kids were in junior high, I looked at all the various ways to pay for college, and between my three kids and four schools we used most if not all of them - I already listed those in my earlier post here.
2. I did sort of plan ahead a bit. One of the strategies I chose to do was to pay off my mortgage about the time my oldest started college. I know there are endless discussions about whether or not to pay off the mortgage, but here was my logic: With a paid off mortgage, I didn't need to have the income to make the mortgage payments. Therefore, I could have (a lot) lower income. With a lower income, my kids could qualify for more FAFSA aid, as well as various need-based scholarships. I never did the detailed math, but it does seem like the lost leverage opportunity was offset by the additional educational benefits.
Of course you need to decide on the ethics and politics of adjusting your circumstances to meet the requirements of the various programs. For programs with which I disagree with their system, I have decided that exploiting those systems helps expose their weaknesses and could help lead to positive change in those systems.
3. Specifically on FAFSA, there are a few basics to know: Retirement accounts and home equity are not included in the FAFSA parental asset formulas. When my kids went to college, that is where the large majority of my net worth was, and so it simply was not counted in the formulas. Knowing about the various ways to access retirement accounts before age 55/59.5 allowed me to FIRE in 2016 and still have most of my net worth sheltered from FAFSA.
4. CSS Profile. I didn't preclude, prevent, or otherwise influence my kids from going to a CSS Profile school if they wanted to, but thankfully they all chose FAFSA schools. Not surprising, really, since most schools are not CSS Profile schools. But a parent could choose to either rule CSS Profile schools out, or disincentivize them in some way. I think kids can adapt to whatever "college deal" the parents offer, but I think the "deal" should be consistent, fair, and well communicated well in advance. I started talking with my kids in generalities about my "deal" when they were in junior high.
5. Roth conversions. I was doing the Roth conversion ladder during my kids' college years. I came across the GEN-99-10 Dear Colleague letter at some point. The basic idea is that Roth conversions add to taxable income, which is an input to FAFSA, but are not available to be spent on college, so financial aid officers are encouraged to adjust for this:
https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/1999-03-10/gen-99-10-students-receiving-preparation-compete-and-succeed-twenty-first-century-workplaceThe process is to complete the FAFSA with the Roth conversion included (easy for me because we used the "import from my tax return" feature), then make a request for professional adjustment to the schools' financial aid office. I did this operation successfully with two different kids at two different years across multiple school years. The process wasn't that hard, the financial aid folks knew about it, and their responses were immediate and straightforward: "Oh, that applies? OK, what was the amount? OK, adjusted, done, your new aid package is $X"
6. Exempt from asset reporting. This is really one of the main ideas. Normally, taxable assets like brokerage accounts and savings and checking accounts need to be reported on the FAFSA and impact the aid assessment. The FAFSA Simplification law then provides various ways for the family (both parent and student) to be exempt from this requirement. There are *at least* three different ways to be exempt from asset reporting under the new FAFSA Simplification rules:
a. The easiest and probably best known is the FPL rule. If your family's income is below 175% or 225% of FPL for your family size, then you're exempt from asset reporting. If you have a paid off house and car, and live a simple lifestyle in a LCOL or MCOL area, then this is really pretty easy to do, especially if Roth conversions (see above) aren't included and/or if you're spending from taxable or savings.
b. Another way is if anyone in the family is receiving certain federal benefits, such as Medicaid. There are about nine different programs that make the family eligible - see the text of the law for the list. I don't remember all the details now, but some of my kids were on Medicaid during some of their college careers because of the way healthcare worked in my state during that time. Some of it was COVID-related I think.
c. A third way is if your AGI is under a certain amount ($60K I think?) and you file a return without most of the schedules. At least I think they still left this one in the law - a quick Google suggests it is but I'd recommend confirming that.
d. There are others, but I didn't investigate them too closely. What I would recommend is reading the FAFSA simplification law itself and pay attention to the details and look for opportunities that might apply to your family. Of note, some of the rules are a bit circuitous - a student qualifies to be exempt from asset reporting if they qualify for maximum Pell, but the rules for qualifying for maximum Pell are somewhere else in the law, so it's a bit of spaghetti code.
e. The above are summarized at
https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2023-08-04/fafsa-simplification-act-changes-implementation-2024-25 (towards the bottom).
7. 529s. The new FAFSA law exempts from reporting as income any qualified distributions from 529s that are owned by grandparents. This is a change which I didn't explore too much because it came after my kids were done. But 529s did work out well for my kids, because I got a nice state tax benefit, tax deferral, and tax free distributions if used for qualified expenses (which was pretty easy to do), and being exempt from asset reporting based on #6 above meant my 529s didn't count as assets either.
8. Not really directly a FAFSA thing, but if your kid goes to summer school then you can get an additional Pell Grant for the summer semester. And them finishing earlier means they start working sooner and compounding savings sooner.
9. Another not really FAFSA thing, but AOTC is a nice and juicy tax credit that we used for most of my kids' college years. One does need to understand how AOTC works, how it relates with LLC and 529 distributions, and some other things. Key tips: Learn about it, read the rules, and in particular learn about how it can often make sense to make some scholarships taxable in order to qualify for the full AOTC. Oh, and also learn about the requirements for the refundable portion of AOTC. And understand that most kids are in college at least five tax years but you can only claim AOTC for four, so strategize on that point.
Hope that helps.