Institutions will want to take note of updated guidance on the distribution of voter registration information and the allowable use of Federal Work Study (FWS) funds for these activities.
On August 19, 2025, the Department of Education (ED) released a Dear Colleague letter GEN-25-05 outlining their interpretation of the allowable use of Federal Work Study funds for the distribution of voter registration information requirements.
Institutions will no longer be permitted to employ students using Federal Work Study funds to assist with the voter registration process.
This guidance rescinds prior guidance issued in Dear Colleague Letters GEN-22-05 and GEN-24-03 that allowed FWS funds to be used for jobs associated with political activities. This includes jobs that involve partisan or nonpartisan voter registration, voter assistance at a polling place or through a voter hotline, or by serving as a poll worker (either on or off campus).
In the DCL, ED reminds institutions that they must have internal controls in place to avoid employing a FWS student in a job that involves any political activity or in work that serves the interests of a particular group.
The Department also reminds institutions that under their Program Participation Agreement (PPA), they are required to make a good faith effort to distribute voter registration forms to students who may be eligible to vote in federal, state, and municipal elections. The guidance does, however, give institutions flexibility by not requiring the institution to solicit voter registration information to students if they know the students are ineligible to vote.
