What is IR’s and Reporting’s Access to Financial Aid Data

Scope: This article outlines Institutional Research’s and Reporting’s access to financial aid data as outlined by regulations.

Purpose: This article provides detailed information regarding the access level Institutional Research has to Financial Aid Data.

Detailed Information 

Federal financial aid regulations require that the institution appoint an individual who is responsible for oversight of all administrative and fiduciary activities including related oversight of federal data and related security. At all of our institutions, that individual is the Director of Financial Aid. Increasing regulatory focus on student data privacy requires that aid administrators adhere to legal restrictions that govern the sharing of student financial aid information with other institutional or UM System offices and outside entities. NASFAA's (National Association of Student Financial Aid Administrators) Statement of Ethical Principles also requires the protection of student data.

There are three important federal laws/statutes which control the release of student data:

1. Sections 483(a)(3)(E) and 485B(d)(2) of the Higher Education Act (HEA) as amended;
2. The Family Educational Rights and Privacy Act (FERPA); and
3. The Privacy Act

The HEA restrictions, in particular, place restrictions on financial aid data above and beyond those for enrollment data. The HEA restrictions apply to: data from the Free Application for Federal Student Aid (FAFSA)--also referred to as ISIR data (Institutional Student Information Record), key processing results, expected family contribution, and the student's financial aid history, as reflected in the National Student Loan Data System (NSLDS). The restrictions state that the use of these data be limited to the awarding and administration of aid and indicate that the resulting awards and disbursement data are also considered FAFSA data. That said, the Privacy Technical Assistance Center (PTAC) does state that the administration of aid includes "audits and program evaluations necessary for the efficient and effective administration of the student aid programs".
In adhering to these requirements, the following data governance policy recommendations are offered:

1. As outlined in the UMS Data Classification APL, data originating from the FAFSA is classified as Restricted, ensuring the highest standard of protection as required by the HEA.
2. When Institutional Research (IR) or data reporting staff of a campus in the University of Maine System need to access row-level (FAFSA/ISIR) data, hereafter referred to simply as ISIR data for the purposes of aggregating, analyzing, reporting or using in any manner, the request to access and use such data must be made with the Director of Financial Aid of that specific institution. If the request for student ISIR data is denied, the next level of appeal would be to the supervisor who is responsible for financial aid operations.
   
   There are certain areas where IR or data reporting staff must have access to data for reporting:
   1. Data reported to the US Department of Education, such as for IPEDs, and is required by law. This includes information on financial aid awards, as well as graduation rates by Pell Grant and Stafford Loan status
   2. Student-level data required for federal Title III and IV programs, or the Federal TRIO Program.
   3. Data for other voluntary Federal reporting requirements, such as the National Postsecondary Student Aid Study (NPSAS).
3. When IR or data reporting staff within the UM System wish to access ISIR data specific to another campus or more than one institution of the UM System for the purposes of aggregating, analyzing, reporting or using in any other manner, the request to access and use such data must be made with the Director of Financial Aid at each of the campuses where data is to be accessed. In addition, the request to access ISIR data must also be made to the University of Maine System Enrollment Management Council.
4. Users are responsible for knowing which variables are sourced from ISIR data tables; in cases where IR or reporting staff are unsure of a financial aid data element's origination point, guidance should be sought before utilizing the data.
5. The UMS First Generation indicators (student group & reporting flag) are partially populated from the ISIR tables. Approved usage for these data elements is detailed in UMS First Generation guidance, and is reviewed on an annual basis. Additional use cases may be requested from the Vice-Chancellor of Academic Affairs office using the First Generation Data Usage Request form.
6. Information that appears in ISIR data may also be collected separately through admissions or student records. Data originating in admissions or student records may be used without going through the approval process in section 3, however, approval must be sought if the source of the data is the ISIR tables, even if it otherwise looks identical to data originating from another source. Most ISIR information tables appearing in the UMS database contain the abbreviation ISIR in the table name. If there is any doubt regarding whether data originated from admissions, the student records data, or from the FAFSA-based ISIR tables, contact the Director of Financial Aid at the institution for clarification. Examples of ISIR data within MaineStreet include, but are not limited to, the following:
   1. Social Security Number or Social Security benefits
   2. Selective Service registration or status
   3. Federal PELL eligibility
   4. Citizenship status if the source comes from the ISIR tables
   5. Marital status if the source comes from the ISIR tables
   6. Veteran or active military status if the source comes from the ISIR tables
   7. Parent education level if the source comes from the ISIR tables
   8. Any student, parent, or legal guardian IRS income tax relevant information
   9. Asset, debt, investment, or income information
   10. Child support information
   11. Student's first, second, third, and other choices of school
   12. Interest in types of financial aid
   13. Drivers license information
   14. Dependency status

The following Data Sharing Decision Tree (next page) provided by the National Association of Student Financial Aid Administrators (NASFAA) is of great assistance when determining if and when financial aid data can be used. Again, any questions regarding the use of financial aid data must ultimately be discussed with the Director of Financial Aid on the campus.

DATA SHARING DECISION TREE

This decision tree is intended to assist financial aid administrators in their evaluation of the permissibility of common data requests under HEA 483(a)(3)(E) and the Family Educational Rights and Privacy Act. It does not include data requests under 485B(d)(2) of the HEA, which prohibits the use of NSLDS data for non-governmental research and marketing purposes, or the Privacy Act, which applies to the Department's student records to prevent the improper release of government-held student personally-identifiable information.
For further discussion and references, please see NASFAA's white paper Financial Aid Data Sharing

Note: A text-only version of the decision tree is coming soon.

Applies To

• System-Wide
• Reporting
• Institutional Research