This from a Case Western email.
Please note, families who anticipate applying for financial aid at any point during xxxx’s undergraduate career must complete our financial aid application requirements for the student’s first year in order to be eligible for need-based financial aid in subsequent years.
They need to be clearer. They must allow students to file for federal aid at any time. I assume they mean that students won’t be eligible for institutional need based aid if they don’t apply as an incoming student. Same with Case. But need based federal aid in this case would just be Pell, assuming the family would qualify, which doesn’t go far at expensive private schools. So filing as an incoming student, even if you’re sure you won’t qualify for need based aid, is wise.