Federal Work-Study for Voter Registration
Using federal work-study funds for civic activities isn’t just encouraged of higher educational institutions – it’s required.
The Higher Education Act of 1965 outlines the Federal Work-Study (FWS) expenditure, requiring institutions of higher education to utilize a certain threshold of funds for community based positions unless provided a waiver from the Secretary of Education. This requirement is cited in Section 443(b)(2)(A) of the Higher Education Act of 1965, as amended (HEA) and the corresponding regulations at 34 CFR 675.18(g).
In particular within that legislation, section (4) states:
(i) In meeting the seven percent community service expenditure requirement in paragraph (g)(1) of this section, students may be employed to perform civic education and participation activities in projects that -
(A) Teach civics in schools;
(B) Raise awareness of government functions or resources; or
(C) Increase civic participation.
The April 21, 2022 "Dear Colleague" letter from the Department of Education to all US institutions of higher education clarifies through policy that "increasing civic participation" includes voter registration activities. Additionally, it links to Volume 2, Chapter 6, page 199 of the 2021-22 Federal Student Aid Handbook that states:
"If a participating school is located in a state that requires voter registration prior to election day and/or does not allow registration at the time of voting, then the school must make a good-faith effort to distribute voter registration forms to its students...The school must make the voter registration forms widely available to its students and must individually distribute the forms to its degree or certificate-seeking (FSA-eligible) students. The school can mail paper copies, or it may send an electronic message to each student with a voter registration form or with an Internet address where the form can be downloaded. The message must be devoted exclusively to voter registration."
So, not only is it included within the already required 7% FWS community service expenditure requirement, but by using those funds for voter registration, institutions are able to comply with other voter registration requirements as well.
The Department of Education then issued updated guidance on February 26, 2024, stating that FWS funds can be used to support “broad-based get-out-the-vote activities, voter registration, providing voter assistance at a polling place or through a voter hotline, or serving as a poll worker” at Federal, State, local, or Tribal public agency for civic engagement work that is not associated with a particular interest or group.
In recognition of the role postsecondary institutions play in promoting and supporting nonpartisan democratic participation, partners across the Students Learn Students Vote Coalition collaborated to put together a Federal Work-Study for Voter Registration Implementation Toolkit.
“If a student is employed directly by a postsecondary institution, the institution may compensate a student for FWS employment involving voter registration activities that take place on or off-campus.”
Department of Education Dear Colleague Letter, April 2022
Federal Work-Study Implementation Toolkit
This resource was made possible thanks to invaluable input gathered from 35 individuals who represent a range of public, private, two-year, and four-year postsecondary institutions and have direct experience with nonpartisan student voter engagement work and/or the Federal Work-Study application process.
The Implementation Toolkit is a comprehensive guide addressing common questions and challenges that arise when establishing the position, as well as detailed strategies informed by campuses that have successfully established FWS positions for nonpartisan voter registration.
Why use the toolkit to establish a FWS position for nonpartisan voter registration?
Voting is not just a right. It’s a rite of passage – a cornerstone of American democracy. Institutions of higher education provide an ideal environment for installing and nurturing voting habits among young Americans. This is an incredible opportunity to leverage federal resources to encourage students at your institution to participate in the democratic process. By establishing Federal Work-Study positions dedicated to nonpartisan student voter registration, you can empower student leaders, amplify peer-to-peer outreach efforts, and cultivate a vibrant culture of active citizenship on your campus.
What’s included?
Understanding Federal Work-Study (FWS) Funds
Benefits Of Utilizing FWS Funds For Campus-Based Voter Registration
Strategies to Address Potential Challenges
Process to Establish a Position
Using FWS Funds at Local Elections Offices
Sample Resources: Position Descriptions, Sample Emails, Talking Points and more!
Northampton Community College’s Federal Work-Study for Civic Engagement
This resource was created by Natalie Sobrinski as part of the 2022 Ask Every Student Codesigner Cohort.
Civic Engagement Federal Work-Study
Learn from 2022 Codesigner Natalie Sobrinski from Northampton Community College about how campuses can use federal work-study positions to promote civic engagement on campus. These resources include assets and guidelines for design and implementation.
Northampton Community College Work-Study Assets
-
Work-Study Job Posting
Use this template Student Job Requisition Request Form that includes workday information requirements, a work-study job description, and federally required questions.
-
Interview Questions
Use these sample interview questions with students who apply for the work-study positions you are hiring for.
-
Sample Work-Study Flyer
Check out Northampton’s Work-Study Flyer for inspiration on promoting your positions.