Gut Check. FERPA Procedures

By: Brenda Hicks

GutCheckOctober 1 is nearly upon us and with it comes the opening of the 2018-2019 FAFSA! There are TWO tweaks to this year’s process:

  1. Due to increased security measures surrounding the exchange of data between IRS and ED, families who use the IRS Data Retrieval tool will not be able to see data they transfer from IRS. Any data that is transferred will be masked on the SAR and on the FAFSA screens. The ISIR, however, will be unchanged to allow schools to verify the information submitted by the student during professional judgment decisions.
  2. Institutions are reminded that they are prohibited from releasing FAFSA data unless the release is for one of the specific purposes permitted by law, even with the student’s written authorization. In other words, no sharing of an individual’s FAFSA data unless the sharing is for the purpose of application, award and administration of federal, state or institutional student aid programs.


NASFAA is recommending that institutions examine their FERPA and FAFSA data sharing procedures and shore them up. Why?

The financial aid community expects an increase in the amount of calls from students and families asking about the information that was transferred from IRS which they will not be able to see.  Each institution needs to make sure everyone is clear about what can be shared over the phone and in person to whom and the procedures institutions are using to identify that the individuals being spoken to are who they say they are.

Institutions are also reminded that sharing FAFSA data with private scholarship providers is not permissible under these regulations because the release of information is not related to federal, state, or institutional aid.  A Today’s News article from September 13, 2017 dealt with this particular sticky wicket.  Institutions are not able to share even if there is a signed statement from the student on the form authorizing the release of information.

Note that the privacy guidance is, at this point, primarily verbal. As the NASFAA article indicates, “It is still undetermined when and how PTAC will release the guidance formally.”




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