Can The Office Of Institutional Research Access Federal Tax Information (FTI) To Complete IPEDS Reporting?

It depends. If the office of institutional research (OIR) falls under the governance structure of the institution and is using the federal tax information (FTI) to complete the Integrated Postsecondary Education Data System (IPEDS) report, the U.S. Department of Education (ED) considers disclosure and use of FTI to fall under the application, award, and administration of Title IV aid.

The disclosure and use of FTI retrieved from the Internal Revenue Service (IRS) via the FUTURE Act Direct Data Exchange (FA-DDX) are implicated under the Higher Education Act of 1965, as amended (HEA), and the Internal Revenue Code (IRC). FTI may be disclosed and used by other internal offices, such as staff in the OIR, executing job duties and business functions related the the application, award, and administration of student aid programs.

Note that ED stated during its April 18, 2024 Better FAFSA Better Future Q&A--Session 3 webinar that the institution is allowed to use FTI to complete IPEDS reporting so long as the data are aggregated at three or more individuals and that aggregation can only be completed by those individuals with authorized job duties related to the application, award, and administration of student financial aid programs. The following question and answer was addressed at the 1:02:26 minute mark during the webinar:

"Question: Does the office of institutional research meet the criteria for FTI aggregation?

Answer: Yes, the office of institutional research, underneath the umbrella of the institution’s governance structure, would be able to access the FTI to do the aggregation and to do the reporting to IPEDS. The reason why we  are sort of broad in this is we acknowledge that not every institution has the same governance structure so it may or may not be the office of institutional research that is conducting or doing the IPEDS reporting or the data pull. There are institutions where this is split where the financial aid office may provide the data, aggregate it, give it to OIR to then report to IPEDS. So we just wanted to leave it open-ended mainly because the institution needs to assess the job duties of the individual who is doing the IPEDS reporting to ensure that it meets the application, award, and administration of aid, which generally speaking doing IPEDS reporting and accessing and using FTI for that aggregation for IPEDS falls underneath the administration of student financial aid programs.”

Note: ED will be releasing additional guidance regarding the uses and disclosures of FTI. Be sure to review that guidance in case it changes the above information.