When is help with a free process worth $80?

Charging $80 to fill out a free application for student aid?  Vox has a story about two websites that do so, using official sounding domain names.  Shades of DMV.org.  The story claims that the federal government’s recent registration of a trademark in the form acronym (FAFSA) might allow the government to shut these sites down, but as the DMV case indicates, false advertising law could do the same regardless—and of course registration isn’t a prerequisite for protection.  (James Grimmelmann makes the false advertising point in the Vox story.)  In any event, if the sites aren’t falsely advertising, the use of FAFSA might well be nominative fair use, though the presence of FAFSA in the domain name could be problematic.  Check out the terrible, tiny disclaimer in the upper right/top of these sites, with a better attempt in a block of text near the bottom.  I wonder what consumer testing would say about how well these work:

The Vox story suggests that the value-added claims to make the process simpler are overstated:

But the Education Department has simplified the FAFSA in recent years. Students can now import income information from the IRS, and they're allowed to skip some questions if they automatically qualify for financial aid because their family income is low. And while FAFSA.com offers a phone process that provides more assistance, the online option charges $79 for students to answer essentially the same questions that are on the Education Department's form.

The article also has some interesting evidence of the number of visits to each site--one of which is the top result for a search on FAFSA because of its advertising--versus visits to the free official site (several times more, but that may just indicate that students separate into groups of savvy and less savvy).  How would you advise (1) the Education Department, (2) these businesses?