The Department of Education has issued new guidance (PDF File) clarifying how colleges should use Federal Work Study (FWS) funds. The updated guidelines emphasize placing students in jobs that offer hands-on, career-relevant experience tied to their studies, while prohibiting the use of FWS wages for voter registration or election-related activities.

The FWS program, created to provide part-time employment for students with financial need, has long given institutions discretion in shaping job opportunities. As recently as 2024, the Department of Education allowed colleges to use FWS employment for voter registration drives or other non-partisan political activity. 

But the new Dear Colleague letter rescinds the previous directives, and makes clear that federal officials expect schools to connect students with work that helps build skills and experience for future employment.

Ending Past Guidelines On Political Activities

The Department rescinded prior guidance that allowed schools to use FWS wages for nonpartisan voter registration or related election activity. Officials stated that such work, even when nonpartisan, falls under “political activity” and is not a permissible use of federal funds under existing regulations.

That means students can no longer be paid through FWS for staffing voter hotlines, assisting with voter registration drives, or working as poll workers. The department stressed that while civic engagement remains important, these activities cannot be funded through Federal Work Study.

Colleges must also ensure that students are not placed in FWS jobs that serve the interests of a political group or involve partisan activities. The letter reminds institutions that compliance is a condition of their participation in other Title IV federal student aid programs.

Colleges Still Required To Engage In Voter Registration

Ironically, the Higher Education Act still requires colleges to distribute voter registration forms to students enrolled in degree or certificate programs. Institutions must request forms from their states well in advance of registration deadlines and make a good faith effort to distribute them.

The new guidance clarifies that schools can continue meeting this obligation by providing paper forms on campus or by sending electronic messages that contain the forms or a link to state election websites. However, such electronic messages must be devoted solely to voter registration information.

The department also encouraged schools to remind students about eligibility rules, including the prohibition against voting in more than one state, restrictions on non-citizen voting, and domicile requirements.

Officials noted that institutions may exclude foreign students or other non-eligible voters when distributing registration forms to avoid inadvertently aiding ineligible individuals.

Implications For Colleges And Students

The guidance signals a return to stricter limits on how institutions use federal dollars while highlighting the department’s push to connect financial aid programs with workforce preparation.

Students employed under FWS would ideally see more positions in labs, community service organizations, or employers related to their majors, and fewer generic campus jobs. However, changes like this cannot happen overnight, and the short term implications may be less campus jobs are available for FWS. That means less financial aid for students.

For colleges, the challenge will be to expand partnerships with employers and academic departments that can provide career-linked roles while ensuring compliance with the voter registration mandate. Schools that fail to follow the restrictions risk losing access to federal aid dollars, making the letter a clear directive for administrators.

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