Can a Contributor Consent and Manually Provide FAFSA Data Before the FSA ID Is Finalized?

Yes, but it should not be recommended or encouraged.

The following example was provided by the U.S. Department of Education (ED) in its Manual Tax Information microlearning video: 

"Bonnie's mother, Rita, is a required contributor and has not created her StudentAid.gov account in advance of filling out the FAFSA form. Because her account has not yet been verified, it cannot be used immediately to pull Federal Tax Information from the IRS. So how might the process of filling out the FAFSA form play out for Bonnie and Rita?

The ideal situation would be for Rita to create her StudentAid.gov account in advance of filing the FAFSA form with Bonnie. Encouraging contributors to get this step completed at least a few days in advance can make the process smoother. A verified StudentAid.gov account means that it can be used to provide consent and allow Federal Student Aid to query the IRS for tax information. If Rita chooses to proceed with filing the FAFSA before the matching process is complete, the FAFSA form will display messaging to let her know that she will need to manually enter her information unless she can wait and come back after the matching process is complete. If she chooses to proceed, manual entry of tax information would be required. Once the match is complete and her StudentAid.gov account is verified, FSA will then query the IRS for tax information, which will overwrite the manual information provided. This will generate a correction transaction. To avoid manual entry, encourage contributors to create their StudentAid.gov accounts prior to filing."

If ED queries the IRS after the match is complete, this means the parent can consent before the FSA ID account is verified with the Social Security Administration (SSA). ED does not want to encourage this practice as it defeats the goal of simplification.

It is NASFAA's understanding from discussions with ED that the Institutional Student Information Record (ISIR) will not be processed or sent to the school until the FSA ID has been verified, so the school should never see the manually entered federal tax information (FTI) in these situations. ED added that we "will have to see if this happens in practice.”