ED Issues Follow-Up Guidance for Institutions and States to Use FAFSA Data to Connect Students With Federal Benefits
By Hugh T. Ferguson, NASFAA Managing Editor
Last Monday, the Department of Education (ED) issued new guidance for institutions and states looking to conduct proactive outreach to students by utilizing FAFSA data to inform students of various means-tested federal benefits that may be available to them.
On July 1 the full implementation of the FAFSA Simplification Act came into effect, which allows for state grant agencies and institutions to use FAFSA data for outreach about means-tested benefits and target direct student outreach about these programs going forward.
The guidance, a follow up to April’s notice, serves as an effort to promote access to a number of basic needs services by allowing institutions and state grant agencies to utilize FAFSA data like the applicant’s Student Aid Index, Pell Grant status, or email address to conduct outreach with new and returning college students.
The federal means-tested benefits programs covered in the outreach initiative include the Affordable Care Act; Affordable Connectivity Program; Child Tax Credit; Medicaid; and Supplemental Nutrition Assistance Program (SNAP).
Notably, the guidance addresses only FAFSA data use. In the guidance ED noted that it will issue “further guidance on access, disclosure, and use cases of FAFSA data and FTI data.”
The department also reminded institutions and state grant agencies that for means-tested benefits outreach, they should limit FAFSA data use to what is required to inform their student population about these benefits.
ED also specified that institutions are permitted to conduct outreach about these benefits with staffers outside of the financial aid office. These can include basic needs coordinators, advisors, or other institutional staff. However schools must “use reasonable methods” to ensure that staff outside the financial aid office obtain access to only FERPA-covered FAFSA data in which they have a legitimate educational interest.
In terms of disclosures of FASFA data to state and local means-tested benefits agencies, the guidance permits institutions and state grant agencies to develop a “process for a student to provide explicit prior written consent to share FAFSA data with Federal, State, or local government agencies or tribal organizations to assist such student in applying for and receiving Federal, State, or local government assistance, or tribal assistance for any component of the student’s cost of attendance.”
Publication Date: 8/5/2024
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