ISIR Fields 306-321, which have intermediate and derived FTI values, should be treated like FTI.
By Rick Cox and Siobahn Arbogast
Financial aid administrators must ensure that all FAFSA data use and handling of Federal Tax Information comply with the strictest privacy and data protection laws. Here are guidelines for FAFSA data use and FTI.
- ISIR Fields 306-321 contain intermediate and derived FTI values. All of these fields should be treated like FIT.
- FAFSA information that’s not Personally Identifiable Information or FTI can be used for research to promote attendance, persistence and completion.
- When handling data, always use the most restrictive law – whether the Higher Education Act (HEA), the Family Educational Rights and Privacy Act (FERPA) or the Internal Revenue Code (IRC).
- Colleges must maintain written consent for at least three years from the student’s Last Date of Attendance (LDA).
- The FERPA exception still applies for disclosure of FAFSA data without consent for research purposes.
- Local, state or federal investigations, including subpoenas, don’t override IRC. Those investigating must instead go to the IRS to obtain FTI information. If any information is provided for an investigation, the college must redact all FTI.
- The college must have the student’s written consent to disclose FAFSA data to the parent or spouse of the student, even if they were a contributor. Please note that a contributor always has access to the data they provided.
- The Department of Education will publish updated guidance on FTI and FAFSA data in the near future.
Rick Cox is Global’s Executive Director of Regulatory Affairs and Compliance. Siobahn Arbogast is Global’s Director of Title IV Accounting.
August 15, 2025
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