Does the Deferred Compensation Listed On a Wage and Income Transcript Include Only the Types That Must Be Reported On the FAFSA?

Starting with the 2024-25 award year under the FAFSA Simplification Act, untaxed payments to tax-deferred pension and retirement saving plans represented by codes D, E, F, G, H, and S in Box 12 of IRS Form W-2 are not reported on the FAFSA, are not included in need analysis, and are not other financial assistance (OFA) when packaging the student.

Background: NASFAA obtained confirmation from the U.S. Department of Education (ED) that an amount identified on the Wage and Income Transcript as “Deferred Compensation” could only be some combination of elective deferrals with codes D, E, F, G, and H. These codes are evident on the Form W-2, but do not display on the Wage and Income Transcript. Other types of deferred compensation, including any amount identified on the Form W-2 with Code S, are clearly identified on separate lines on the Wage and Income Transcript.