# THE EVERY FUTURE FULFILLED ACT OF 2027

## Student Emergency Retention and Completion Act

**MODEL POLICY DRAFT FOR PUBLIC DISCUSSION — VERSION 0.1**

**NOT ATTORNEY-APPROVED LEGISLATIVE LANGUAGE**

**SUBJECT TO REVISION FOLLOWING LEGAL, FISCAL, RESEARCH, ACCESSIBILITY, PRIVACY, AND STAKEHOLDER REVIEW**

The Every Future Fulfilled Act is a proposed model policy developed by Esther Funds Foundation. It has not been introduced or enacted and currently has no bill number. Bracketed language identifies drafting options that must be resolved by the appropriate legislative body and qualified counsel.

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## Section 1. Short title

This Act may be cited as the “Every Future Fulfilled Act of 2027” or the “Student Emergency Retention and Completion Act.”

## Section 2. Findings and purpose

### (a) Draft findings

The [Congress/Legislature] finds that:

1. Unexpected financial, housing, food, transportation, child-care, health, technology, bereavement, family, and institutional emergencies can interrupt postsecondary enrollment and completion.
2. A temporary emergency may become an educational loss when a student cannot identify a clear application pathway, obtain a timely decision, reach an accountable point of contact, or access assistance that addresses the actual barrier.
3. Food pantries, basic-needs offices, counseling referrals, and community-resource lists are valuable but do not, by themselves, guarantee flexible emergency funding, coordinated case ownership, a written decision, temporary enrollment protection, or an appeal.
4. Institutions frequently coordinate billing, registration, housing, financial aid, academic standing, and collections functions. A comparable cross-department system is necessary when an emergency places a student at imminent risk of withdrawal or noncompletion.
5. Emergency assistance should be administered with dignity, accessibility, privacy, procedural fairness, and responsible public accountability.
6. Public reporting should measure access, processing, awards, denials, available funding, and educational continuation without identifying individual students or exposing small groups.

### (b) Purpose

The purposes of this Act are to:

1. require each covered postsecondary institution to maintain a funded Student Emergency Retention System;
2. establish one accessible entry point, one case number, and one assigned navigator for each request;
3. provide rapid triage and timely written decisions;
4. protect students from avoidable enrollment, class, housing, penalty, or collections consequences while a timely request or appeal is actively under review;
5. authorize nonrepayable assistance that addresses qualifying barriers;
6. establish notice, reconsideration, appeal, accessibility, privacy, nondiscrimination, and anti-retaliation protections; and
7. require privacy-protective aggregate reporting, evaluation, and continuous improvement.

## Section 3. Definitions

For purposes of this Act:

1. **Administering agency** means the [United States Department of Education/designated State higher-education agency/other authority] responsible for implementation and oversight.
2. **Complete standard application** means an application containing the minimum information published under Section 8 and sufficient to make an eligibility decision, excluding information the institution can obtain from its own records without requiring the student to resubmit it.
3. **Covered postsecondary institution** means an institution described in Section 4.
4. **Covered student** means an individual enrolled, accepted for enrollment, or within a defined completion or reenrollment period at a covered institution, subject to final jurisdictional drafting.
5. **Emergency enrollment protection** means a temporary pause on specified adverse administrative actions while a timely emergency request or appeal is under active review.
6. **Emergency Retention Fund** means dedicated and recurring funding used to provide nonrepayable emergency-retention assistance and necessary case-navigation support.
7. **Imminent risk of withdrawal** means a documented circumstance that, without timely intervention, is reasonably likely to cause the student to lose enrollment, housing, required access, academic progress, or the ability to complete the applicable term or program.
8. **Institutional balance** means an amount owed directly to an institution that creates or is reasonably likely to create a registration, enrollment, transcript, housing, course-access, or completion barrier.
9. **Navigator** means a trained employee or authorized program representative assigned responsibility for coordinating a student’s emergency-retention request, communications, referrals, decision timeline, and appeal information.
10. **Qualifying student emergency** means a sudden, urgent, or time-sensitive barrier described in Section 7 that threatens enrollment, housing, academic progress, or completion and is not excluded by published rules.
11. **Student Emergency Retention System** means the coordinated institutional structure required under this Act, including intake, triage, navigation, funding, decision, protection, appeal, referral, reporting, and improvement functions.
12. **Underserved student population** means a population identified by the administering agency through lawful, evidence-based criteria as experiencing barriers to access, persistence, or completion. This definition shall not authorize unlawful discrimination or individual presumptions.

## Section 4. Covered institutions

### (a) Federal drafting option

A covered postsecondary institution is an institution of higher education that participates in a federal student-aid program under Title IV of the Higher Education Act of 1965, as amended, or otherwise receives applicable funds administered by the Secretary of Education.

### (b) State drafting option

A covered postsecondary institution is a public postsecondary institution, and any additional institution designated by State law based on receipt of State student-aid or operating funds.

### (c) Final scope

The final legislative sponsor shall select and reconcile the applicable federal or State option after authority, fiscal, administrative-burden, and implementation review. Nothing in this model draft represents a final jurisdictional conclusion.

## Section 5. Required Student Emergency Retention System

Each covered institution shall designate an accountable office or coordinated team and maintain a Student Emergency Retention System that provides:

1. one accessible application available online, by telephone, and in person;
2. one case number used across participating departments;
3. one assigned navigator with responsibility for timely coordination and communication;
4. a published urgent-triage process;
5. a dedicated Emergency Retention Fund;
6. written eligibility, documentation, decision, reconsideration, and appeal standards;
7. temporary emergency enrollment protection as provided in Section 10;
8. coordinated access to financial aid, billing, registrar, housing, disability-access, academic, counseling, basic-needs, and other relevant offices without requiring the student to restart the request;
9. disability, language, technology, and communication access;
10. privacy, security, records-management, and data-minimization controls; and
11. aggregate reporting, quality review, and continuous improvement.

The institution may use an existing office to administer the System only if that office has the authority, staffing, procedures, coordination, and funding necessary to satisfy every requirement of this Act.

## Section 6. Emergency Retention Fund

### (a) Establishment

Each covered institution shall maintain a dedicated and recurring Emergency Retention Fund sufficient to provide qualifying assistance and administer the System.

### (b) Nature of assistance

Assistance under this Act shall be nonrepayable and shall not require a student to obtain a new loan, use a credit card, exhaust retirement assets, or accept an income-share arrangement as a condition of emergency consideration.

### (c) Funding sources

Subject to applicable law, the Fund may include federal or State appropriations, required institutional contributions, philanthropy, grants, recoveries, or other authorized sources. Restricted funds shall be used consistently with their restrictions.

### (d) No diversion

Funds designated for direct student assistance shall not be diverted to unrelated institutional operations. Administrative costs shall be separately identified and subject to a reasonable cap established by rule.

### (e) Supplement, not supplant

[Drafting option:] Amounts provided under this Act shall supplement and not supplant existing institutional emergency-aid commitments, except where the administering agency approves an implementation transition.

## Section 7. Qualifying emergencies and assistance

### (a) Eligible categories

Qualifying assistance may address an urgent barrier involving:

1. safe housing, temporary lodging, rent, utilities, or housing stabilization;
2. food or essential household needs;
3. local transportation, vehicle repair necessary for attendance, or emergency travel;
4. child care or dependent care;
5. health care, medication, insurance interruption, or other necessary health-related costs, without requiring unnecessary medical detail;
6. technology, internet access, books, course supplies, equipment, uniforms, licensure, testing, or other required educational expenses;
7. bereavement, family crisis, disaster, theft, violence, displacement, or other urgent personal circumstances;
8. a qualifying institutional balance that threatens registration, course access, housing, completion, or continued enrollment; and
9. another emergency category approved by the administering agency.

### (b) Flexible response

The institution shall evaluate the actual barrier and may use direct grants, vendor payments, institutional-account adjustments, transportation or lodging arrangements, coordinated benefit access, or another lawful intervention. Assistance shall not be limited to a referral when a funded intervention is reasonably necessary and available.

### (c) Published exclusions

Any exclusion shall be published in plain language and applied consistently. An institution may not use an unpublished rule, an automatic presumption based on protected status, or a documentation demand unrelated to the request.

## Section 8. Application and documentation

### (a) Minimum necessary information

The application shall request only information reasonably necessary to identify the student, understand the barrier, determine eligibility, prevent duplication, select a lawful intervention, and meet audit requirements.

### (b) Existing institutional records

An institution shall not require a student to reproduce information reasonably available in its own records unless confirmation is necessary and the institution explains why.

### (c) Alternative documentation

When ordinary documents are unavailable because of the emergency, the institution shall provide reasonable alternatives, including a student attestation when permitted by law and program integrity requirements.

### (d) Sensitive information

The application shall instruct students not to submit Social Security numbers, passwords, verification codes, full bank-account information, complete tax returns, or detailed medical records unless a specific lawful requirement is explained through a secure process.

### (e) Notice of completeness

The institution shall promptly notify the student whether the application is complete, identify any missing item in plain language, and provide an accessible method to supply it.

## Section 9. Triage and decision timelines

### (a) Urgent response

A request indicating imminent loss of safe housing, food access, required medication, transportation necessary for attendance, class access, enrollment, or another time-sensitive barrier shall receive an initial human response no later than one business day after receipt.

### (b) Standard written decision

A complete standard application shall receive a written decision no later than three business days after it becomes complete, unless a shorter period is necessary to prevent imminent loss.

### (c) Delay notice

If extraordinary circumstances prevent a decision within the applicable time, the institution shall issue a written delay notice stating the reason, the information still required, the interim protection or assistance available, the responsible navigator, and the expected decision date.

### (d) No automatic denial for agency delay

A student shall not be denied solely because another office or third party failed to provide information the institution was responsible for obtaining.

## Section 10. Emergency enrollment protection

### (a) Required temporary protection

When a covered student submits a timely request that plausibly identifies an imminent risk of withdrawal, the institution shall pause avoidable adverse actions related to the stated emergency while the request and any timely appeal are actively under review. Protection may include a pause on:

1. class cancellation or administrative withdrawal;
2. removal from institution-controlled housing when legally and operationally permissible;
3. new late penalties connected to the disputed or qualifying barrier;
4. referral of the relevant balance to collections;
5. registration cancellation, loss of required course access, or another avoidable institutional action that would defeat the purpose of review.

### (b) Limits

Protection does not require an institution to ignore an immediate health or safety threat, a lawful disciplinary action unrelated to the emergency request, fraud, or a circumstance that the institution lacks legal authority to pause. Any exception shall be documented and communicated in writing.

### (c) Duration

Protection begins when the institution receives a qualifying timely request, or earlier when required by rule, and continues through the decision and any timely appeal, subject to reasonable maximum periods established by the administering agency.

## Section 11. Written decisions

Each decision shall state:

1. whether the request is approved, partially approved, denied, or requires additional information;
2. the approved amount or intervention, timing, and method;
3. the principal reasons for any partial approval or denial;
4. the policy criteria applied;
5. any immediate referral or interim protection;
6. the name or office of the navigator;
7. how to request reconsideration or appeal, the deadline, and the protection that continues during review; and
8. how to request an accessible format or language assistance.

A denial shall not rely solely on an automated system. Any automated prioritization or fraud-screening tool shall be subject to human review, bias assessment, security controls, and a process for correcting inaccurate information.

## Section 12. Reconsideration and appeal

### (a) Reconsideration

A student may request prompt reconsideration based on missing context, corrected information, changed circumstances, or a claimed misapplication of policy.

### (b) Independent appeal

A student may appeal an adverse decision to a trained reviewer who did not make the original decision and who has authority to affirm, modify, remand, or reverse it.

### (c) Timing

The institution shall acknowledge an appeal within one business day and issue a written decision within [three] business days after receiving a complete appeal, unless a shorter timeline is required by the emergency.

### (d) Continued protection

Emergency enrollment protection shall continue during a timely appeal unless a written exception under Section 10(b) applies.

### (e) No retaliation

No covered institution or employee may retaliate against a student for requesting assistance, asking for an accessible process, appealing, reporting a concern, or participating in an authorized evaluation.

## Section 13. Accessibility, nondiscrimination, and communication

1. All applications, notices, meetings, documents, and digital services shall comply with applicable disability-access and nondiscrimination law.
2. Institutions shall provide reasonable accommodations, effective communication, and meaningful language access as required by law.
3. Digital forms shall be mobile responsive, keyboard accessible, compatible with assistive technology, and written in plain language.
4. Students shall have a telephone and in-person alternative when digital access is unavailable.
5. Eligibility and prioritization rules shall be applied consistently and reviewed for unlawful disparate treatment or impact.

## Section 14. Privacy, consent, and data security

### (a) Applicable law

Institutions shall administer the System consistently with the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g, 34 C.F.R. Part 99, applicable financial-aid confidentiality requirements, and other federal and State privacy laws.

### (b) Data minimization

Information shall be collected, accessed, used, shared, retained, and destroyed only as necessary for eligibility, assistance, coordination, audit, evaluation, or another disclosed lawful purpose.

### (c) Role-based access

Access shall be limited to trained personnel with a legitimate program responsibility. The institution shall maintain access controls, audit records, incident-response procedures, and periodic access review.

### (d) Separate consent

Where consent is legally required, including for information sharing beyond permitted institutional purposes, the institution shall obtain specific, informed, revocable consent. A request for assistance shall not be treated as consent to publicity, research participation, fundraising, or testimonial use.

### (e) Prohibited public disclosure

Public reporting shall not contain names, contact information, direct identifiers, detailed free-text narratives, small cells, or combinations of attributes reasonably likely to identify a student.

## Section 15. Outreach and navigator standards

### (a) Proactive notice

Institutions shall provide recurring, accessible information about the System through enrollment, financial-aid, billing, housing, advising, student-success, and emergency communications.

### (b) Focused outreach

Subject to applicable law, institutions may conduct evidence-based outreach to groups experiencing documented barriers, but shall not presume individual need or disclose a student’s status publicly.

### (c) Navigator training

Navigators shall receive training in program rules, trauma-informed and dignity-centered communication, accessibility, privacy, financial-aid coordination, fraud prevention, appeals, and available campus and community resources.

## Section 16. Institutional reporting and public accountability

### (a) Annual aggregate report

Each covered institution shall report, in a standardized form:

1. beginning and ending Fund balances, new contributions, direct assistance, and administrative expenditures;
2. the number of applications received, completed, approved, partially approved, denied, withdrawn, and pending;
3. median and distributional processing times for urgent and standard requests;
4. award amounts and emergency categories in privacy-protective aggregates;
5. the number and disposition of reconsiderations and appeals;
6. the number of students receiving emergency enrollment protection;
7. available aggregate continuation, retention, and completion outcomes; and
8. accessibility complaints, processing failures, and corrective actions in aggregate.

### (b) Privacy safeguards

The administering agency shall establish small-cell suppression, aggregation, and disclosure-control rules. The default minimum public cell size in this model is 10, subject to professional privacy review.

### (c) No unsupported ranking

Data shall not be used to create a public institutional ranking or scorecard without validated definitions, comparable denominators, methodology review, institution response opportunity, and privacy review.

## Section 17. Administration, oversight, and technical assistance

The administering agency shall:

1. issue regulations, model forms, accessibility standards, reporting definitions, and implementation guidance;
2. provide technical assistance and a reasonable implementation period;
3. establish a complaint and corrective-action process;
4. conduct periodic program-integrity, privacy, accessibility, and outcome reviews;
5. coordinate with financial-aid, civil-rights, privacy, housing, and other relevant authorities;
6. publish only verified aggregate information with methodology and limitations; and
7. consult students, institutions, disability advocates, privacy experts, basic-needs practitioners, financial-aid professionals, researchers, and community organizations.

## Section 18. Funding authorization

There are authorized to be appropriated such sums as may be necessary for direct emergency assistance, institutional implementation, technical assistance, oversight, evaluation, and accessibility. Final legislation shall specify the allocation formula, institutional contribution, administrative-cost limit, maintenance-of-effort rule, grant period, audit requirements, and treatment of unspent funds following fiscal review.

## Section 19. Evaluation and continuous improvement

1. The administering agency shall establish a privacy-protective evaluation framework before requiring outcome reporting.
2. Evaluation shall distinguish descriptive findings from causal conclusions and shall disclose sample limitations, missing data, definitions, denominators, and suppression rules.
3. Student participation in research beyond required program administration shall be voluntary and governed by a separate consent process and appropriate ethics determination.
4. Institutions shall review processing failures, unmet need, appeals, accessibility barriers, and student feedback and shall document corrective actions.

## Section 20. Rulemaking, implementation, and effective date

1. The administering agency shall issue proposed regulations no later than [12 months] after enactment and final regulations no later than [24 months] after enactment.
2. Covered institutions shall submit an implementation plan no later than [12 months] after final regulations.
3. Core application, navigator, funding, decision, appeal, privacy, and reporting requirements shall take effect no later than [one academic year] after approval of the institutional plan.
4. The agency may authorize phased implementation for small or under-resourced institutions if students retain an accessible interim pathway and the institution meets published milestones.
5. The final effective date and transition rules remain subject to legislative, fiscal, and operational review.

## Section 21. Relationship to other law

1. Nothing in this Act shall be construed to reduce rights or duties under financial-aid, disability, civil-rights, consumer-protection, housing, privacy, public-benefits, labor, or other applicable law.
2. Assistance under this Act shall be coordinated with federal student-aid rules and other benefits to avoid unlawful overawards or adverse treatment, while preserving the maximum lawful assistance for the student.
3. Nothing in this model draft constitutes a final determination regarding preemption, sovereign immunity, enforcement authority, or a private right of action. Those questions require qualified legislative counsel.

## Section 22. Severability

If any provision of this Act or its application is held invalid, the remainder of the Act and its application to other persons or circumstances shall not be affected, to the extent permitted by law.

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## Drafting questions requiring professional review

1. Federal or State constitutional and statutory authority.
2. Final institutional and student coverage.
3. Appropriation level, allocation formula, matching requirements, and administrative-cost limits.
4. Interaction with Title IV student-aid rules, estimated financial assistance, cost of attendance, and institutional balances.
5. Scope and duration of enrollment and housing protections.
6. Appropriate enforcement mechanism, complaint process, remedies, and due process.
7. FERPA, State privacy, records-retention, cybersecurity, and data-sharing requirements.
8. Accessibility, language-access, civil-rights, and nondiscrimination review.
9. Institutional burden, staffing, rural and small-campus capacity, and phased implementation.
10. Evaluation design, reporting definitions, small-cell rules, and public-data governance.

## Selected official source notes for counsel and policy reviewers

- Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g and 34 C.F.R. Part 99.
- U.S. Department of Education, Student Privacy Policy Office, FERPA guidance for postsecondary institutions.
- Higher Education Act of 1965, as amended, including Title IV institutional participation requirements.
- U.S. Government Accountability Office, GAO-24-107074, *Supplemental Nutrition Assistance Program: Estimated Eligibility and Receipt among Food Insecure College Students*.
- U.S. Government Accountability Office, GAO-21-312R, *COVID-19: Emergency Financial Aid for College Students under the CARES Act*.

These sources identify relevant privacy, student-aid, and basic-needs context. They do not constitute endorsement of this proposal. All citations and legal references must be verified by qualified counsel before legislative introduction.

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**Issued for public discussion by Esther Funds Foundation**
**Written under the direction of Executive Director Shayna Vincent**
**Every Future Fulfilled.**
policy.estherfundsfoundation.org
nationals@estherfundsinc.org