What Is Considered FAFSA Data For Purposes Of Data Sharing?

FAFSA Data: According to the U.S. Department of Education's (ED), FAFSA data is data collected on or derived from the FAFSA that is not federal tax information (FTI). In general, FAFSA data is what appears on the Institutional Student Information Record (ISIR), and includes the following:

• The fact that the FAFSA was submitted;
• Applicant and contributor information provided on the FAFSA, Institutional Student Information Record (ISIR), and FAFSA Submission Summary, including:
  • Personally identifiable information (PII),
  • Demographic information,
  • Student eligibility information, and
  • The list of colleges receiving the FAFSA;
• Manually provided income and asset information;
• Student aid index (SAI); and
• Federal Pell Grant eligibility (Yes/No).

Not FAFSA Data: Non-FAFSA data, or school data, are the terms for information that is originated by the schools or other entities rather than from the ISIR. The following are not considered FAFSA data:

• Title IV aid amounts, such as the Federal Pell Grant award amount and Federal Work-Study (FWS) awards and pay dates (even though providing the Pell amount confirms the student as Pell-eligible);
• Unmet need amounts;
• Loan disbursement records;
• Student admission records (e.g., admission application); and
• Other financial aid data and information, including the student’s financial aid history as reflected in the National Student Loan Data System (NSLDS).

Per ED, these items under "Not FAFSA Data" are not implicated by data sharing restrictions under Section 483 [20 USC 1090] and Section 494 [20 USC 1098h] of the Higher Education Act of 1965 (HEA), as amended. However, Family Educational Rights and Privacy Act (FERPA) and HEA Section 485B [20 USC 1098B for NSLDS data] restrictions may apply.

See GEN-25-08 (which supercedes GENERAL-24-129), which provides guidance on FAFSA and non-FAFSA data. 

Assistance with Data Sharing Determinations: See the NASFAA Data Sharing Decision Tree for assistance in making your determination, consulting with your school’s legal counsel (when needed).

Federal Tax Information: FTI retrieved using the FUTURE Act Direct Data Exchange (FA-DDX) is not considered FAFSA data. Be sure to see AskRegs Knowledgebase Q&A, What Is Federal Tax Information (FTI)?, as different and more restrictive rules apply.