NASFAA Publishes Updates to Data Sharing Decision Tree
By NASFAA Policy & Federal Relations Staff
NASFAA is pleased to provide updates to its data sharing decision tree based on clarification received in conversations with the Department of Education (ED). Section 483 of the Higher Education Act (HEA) allows schools to use FAFSA data for the application, award, and administration of aid and for research pertaining to college attendance, persistence, and completion that does not release any personally identifiable information about any student. ED clarified that disclosing FAFSA data without student consent (consistent with Section 494 of the HEA) for any other purpose is not permitted.
While the Family Educational Rights and Privacy Act (FERPA) permits disclosures that meet an exception, the HEA is more restrictive. Because of this, if the disclosure is not permitted by the HEA, it does not matter if a FERPA exception would apply. The decision tree was updated to reflect this clarification accurately.
For an example of this scenario, see AskRegs Q&A: Can We Share Pell Eligibility Status With Our Admissions or Academic Advising Staff to Provide Support Services to Students?
NASFAA has confirmed that ED will release new guidance that supersedes what is provided for this scenario in Electronic Announcement GENERAL-24-129.
Publication Date: 8/26/2025
You must be logged in to comment on this page.