Student Data Sharing to Support Benefits Enrollment
Student Defense has advocated for and supported the development of two updates to federal guidance documents that the Biden Administration ultimately adopted to increase student data sharing for purposes of benefits enrollment.
Data sharing with State Agencies
In 2023, Student Defense proposed that the Department of Education update federal guidance to encourage the sharing of FAFSA data with state university systems, community college systems, and state student aid and authorizing agencies so they can inform students about federal benefits program eligibility. Doing so, Student Defense advised, would enhance accessibility to vital resources for students.
Student Defense’s proposal to update federal guidance can be found here.
On July 29, 2024, the Department of Education updated its guidance, allowing state grant agencies to share student FAFSA data to expand student access to federal benefits programs. The updated guidance can be found here.
The Department also published an Electronic Announcement on Nov. 7, 2024 to provide guidance on the permitted and prohibited access, disclosure, and use of personally identifiable information from the FAFSA by institutions of higher education, state grant agencies, and their respective contractors that receive this information beginning with the 2024-25 FAFSA cycle.
Expanding Opportunities for Students to Opt-In to Data Sharing for Benefits Enrollment Support
In January 2022, the Department of Education released guidance titled “Use of FAFSA Data to Administer Federal Programs” to encourage institutions to use FAFSA data to communicate with students about designated public benefits programs they may be eligible for and partner with state agencies to verify student eligibility. Recognizing that in 2023, only 1 in 4 of surveyed institutions of higher education reported that they inform students about public benefits programs, Student Defense sent a proposal to the Department in September 2024 to update the 2022 guidance and expand opportunities for students to opt-in to data sharing for benefits enrollment purposes.
The proposed guidance underlined that the Department of Education can do more to encourage institutions of higher education to share FAFSA and Federal Tax Information data with state and local agencies administering benefits programs. Student Defense also provided sample consent language institutions and state agencies can use to obtain the required consent to share student FAFSA and federal tax data.
Student Defense’s proposed guidance with sample consent language can be found here.
The Department adopted the recommendations in new guidance issued on Dec. 20, 2024, titled (GENERAL-24-149) Guidance on Consent for FAFSA Data Sharing and Automatic IDR Certification.