Can We Give a Third-Party Servicer Access To Our School's FTI-SAIG Mailbox?

Scenario: We outsource verification to a third-party servicer who needs access to our federal tax information Student Aid Internet Gateway (FTI-SAIG) mailbox. The servicer will have access to all ISIRs if granted. Our concern is whether or not this is in compliance with rules governing the disclosure of FTI when a third-party servicer has access to all FTI-SAIG information.

Answer: Yes. If your institution has contracted with a third-party servicer to carry out duties related to the application, award, and administration of Title IV aid, then the third-party servicer may have access to your school's FTI-SAIG mailbox. 

NASFAA posed this question to the U.S. Department of Education (ED) and received the following response:

"If an institution has contracted with a third-party servicer to carry out duties related to the application, award, and administration (e.g., completing verification requirements), additional users at that organization are permitted to have access to the FTI-SAIG mailbox regardless of student selection for verification. Generally, the relationship between schools and servicers is not changed by the Simplification Act, and there is no mechanism to restrict SAIG access to just those ISIRs that have been selected for verification. However, institutions and their contractors must limit disclosures strictly to the application, award, and administration of student financial aid programs (at that institution) under 6103(l)(13) of the Internal Revenue Code (IRC) and 494 of the Higher Education Act (HEA), as amended. Individuals with job duties related to verification should be the only staff accessing FTI, and they should access only those ISIRs needed for such duties, (i.e., those selected for verification or, if the servicer performs other Title IV-related functions, those that need to be addressed).

We further remind institutions, including their contractors, they must protect federal student aid information provided to them by the Department or otherwise obtained in support of the administration of the federal student aid programs. The Department would like to emphasize that it is unlawful to access, view, use, or disclose (without the express written consent of the applicant) FTI for any other purposes than those authorized by federal law. Findings, including those during a program review, are reported to the Internal Revenue Service (IRS) for further investigation. Violations of the IRC can result in criminal and civil penalties for the unauthorized disclosure and inspection of FTI, including civil penalties that a taxpayer may bring for damages against an officer or employee who has inspected or disclosed, knowingly or by reason of negligence, such taxpayer's tax return or return information in violation of any provision of Section 6103 of the IRC. For more information, please review the Department’s May 12, 2023, Electronic Announcement (GENERAL-23-34) Access and Use of Federal Tax Information (FTI) for Federal Student Aid Programs Beginning with the 2024-25 FAFSA Processing Cycle (Updated April 18, 2024)."