Can We Use Drop Box Or Similar File Sharing Services To Collect Verification and Other Documents From Students?

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Important Note for 2021-22 Only: Beginning July 13, 2021 and for the remainder of the 2021-22 FAFSA processing and verification cycle, the U.S. Department of Education (ED) is waiving verification of FAFSA/ISIR information, except for identity/Statement of Educational Purpose and high school completion status in Verification Tracking Groups V4 and V5. See Dear Colleague Letter GEN-21-05 and AskRegs Q&A, How Do We Implement the Verification Waiver For the Remainder Of 2021-22?, for guidance specific to the waiver. The following guidance is still relevant depending on context and/or application of the waiver.

There is nothing in the Title IV regulations that would prevent a school from using a "drop box" or other similar document sharing services to collect verification and other student eligibility documents from students or parents.

According to guidance NASFAA has received from the U.S. Department of Education (ED), the use of any drop box method of collecting documents must comply with the standards of security necessary to protect the personally identifiable information (PII) that is being exchanged. You should confer with your school's information technology (IT) staff and contact ED's Privacy Technical Assistance Center (PTAC) for assistance as you implement policies and procedures to ensure your drop box system is adequate to protect the privacy of your students' data.

For additional resources, visit ED's Protecting Student Privacy website, particularly the Data Security and FSA Cyber Security Compliance pages. 

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AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.