A Digest of Federal Tax Information

Carla Arsaga -

By Rick Cox and Siobahn Arbogast

  • There are specific rules regarding the access, use and disclosure of FAFSA information. The requirements differ depending on whether it is FTI Data, FAFSA Data or Derived FAFSA Data. If more than one law or rule applies, always use the most stringent (HEA, FERPA, Internal Revenue Code). Violations can result in fines or legal action, so protecting this information is extremely important.
  • Only the IRS can disclose FTI. This might require FTI data to be redacted before ISIR data is shared. This includes local and state investigations or subpoenas.
  • The Department of Education posted a new electronic announcement on November 7, 2024 (GENERAL-24-129) to provide updated guidance on the access, use and disclosure of FAFSA data.
  • A student’s written consent to disclose specific FAFSA data must be maintained for three years from the student’s last day of attendance. Administrators can find guidance here.

Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance. Siobahn Arbogast is Director of Title IV Accounting.