# FAFSA Completion Initiative:  Questions & Answers

# March 2014

As part of the U.S. Department of Education’s new *FAFSA Completion Initiative*, state student grant agencies may provide participating secondary schools, school districts, and certain designated entities with limited data about students’ progress in completing and filing the Free Application for Federal Student Aid (FAFSA) form.  While the detailed requirements for state student grant agencies to participate and enroll in the *FAFSA Completion Initiative* will be provided in the revised Student Aid Internet Gateway (SAIG) agreement for state student grant agencies, these Questions and Answers (Q&As) summarize this new initiative, including its goals, requirements, and procedures.  

**Q1.  What is the *FAFSA Completion Initiative*?**

A1.The *FAFSA Completion Initiative* is a new initiative through which the U.S. Department of Education (the Department) is partnering with state student grant agencies to allow these agencies to provide secondary schools, school districts, and certain designated entities with limited, yet important, information on student progress in completing the FAFSA form.  This limited information is referred to as FAFSA Filing Status Information.

To participate, a state student grant agency must sign a new SAIG agreement with the Department (as described in Question 4) and enter into a data sharing agreement with a secondary school, school district, or a specific designated entity (as discussed in Question 8).  The agency can then share only the specified FAFSA Filing Status Information with the secondary school, school district, or designated entity. 

The *FAFSA Completion Initiative* builds and expands on the success of the Department’s FAFSA Completion Pilot Project, in which the Department partnered directly with selected secondary schools and school districts to share this limited information.

**Q2.Why has the U.S. Department of Education launched the *FAFSA Completion Initiative*?**

A2.To accomplish the President’s goal of once again having the highest proportion of college graduates in the world by the year 2020, the United States must dramatically increase its high school graduation and college completion rates, especially among students from low-income families.  Because the timely completion of a FAFSA form is an essential step for many families in obtaining financial aid to pursue a postsecondary education, the *FAFSA Completion Initiative*will enable state student grant agencies and their school and district partners to identify those students who have not filed a FAFSA form and better target counseling, filing help, and other resources to those students.  Because FAFSA completion is essential for receiving Federal financial aid, identifying such students can promote college access and success by ensuring students, particularly low-income students, have access to financial aid to fund their education.   

**Q3.Are state student grant agencies, secondary****schools, school districts, and designated entities required to participate in the *FAFSA Completion Initiative?***

A3.No.  Participation is voluntary for state student grant agencies, schools, districts, and designated entities.  However, the Secretary of Education encourages participation in the initiative in order to promote student access to financial aid that can help increase college enrollment and completion.   

**Q4.How can state student grant agencies participate in the *FAFSA Completion Initiative*?**

A4.In 2014, all state student grant agencies will execute a revised Student Aid Internet Gateway (SAIG) Agreement with the Department.  The revised SAIG agreement includes the requirements for the *FAFSA Completion Initiative*and, once executed, will provide the state student grant agency with the authority to share FAFSA Filing Status Information (in accordance with applicable laws and regulations) with secondary schools, districts, and designated entities under the SAIG parameters.  Thus, to participate, state student grant agencies will execute a revised SAIG agreement with the Department.  Nonparticipating state student grant agencies will execute the same SAIG, but will have no obligation to share the FAFSA Filing Status Information.**Secondary schools, school districts, and designated entities may participate only under agreement with state student grant agencies.

**Q5.What FAFSA Filing Status Information can a state student grant agency share with secondary****schools, school districts, and designated entities under the *FAFSA Completion Initiative*?**

A5.Only defined FAFSA Filing Status Information may be shared under the *FAFSA Completion Initiative* and only under certain conditions, as identified in Question 11 below.  Specifically, the state student grant agency may only disclose: (1) the student’s last name; (2) the student’s first name and middle initial; (3) the student’s date of birth; (4) the student’s zip code (not full address); (5) if filed, the date the FAFSA form was submitted to the Department; (6) the date the Department processed the FAFSA form, if applicable; (7) a flag indicating the need for the FAFSA applicant to provide additional information, if applicable; and (8) a FAFSA completion status flag, as determined by the state student grant agency (i.e., FAFSA not submitted, FAFSA complete, or FAFSA incomplete). 

**Q6.Does the creation of the *FAFSA Completion Initiative*mean that the Department will begin disclosing student FAFSA information to state student grant agencies for the first time?**

A6.No.  State student grant agencies already receive FAFSA information under the existing SAIG agreement.  Under section 483(a)(3) of the Higher Education Act, States (state student grant agencies) are specifically authorized to receive student FAFSA submissions provided to the Department.  However, the revised SAIG agreement and the new *FAFSA Completion Initiative*will permit state student grant agencies to make FAFSA Filing Status Information (as described in Question 5) available under certain conditions to permissible organizations. 

**Q7.When can state student grant agencies begin participating in the *FAFSA Completion Initiative?***

A7.After executing the revised SAIG Agreement and establishing the required agreements, systems, and processes with secondary schools, school districts, and designated entities, state agencies may share the information.  There is no deadline for participation in the *FAFSA Completion Initiative.*

**Q8.What “designated entities” can receive FAFSA Completion Information from state student grant agencies?**

A8.A designated entity that can receive FAFSA Completion Information from a state student grant agency is a public or nonprofit entity that the Department has designated as eligible to receive FAFSA Filing Status Information.   In order to be designated as eligible to receive FAFSA Filing Status Information, an entity must have an “established relationship” with the student, as defined in the SAIG.  An established relationship exists for a designated entity when the student is enrolled in or has registered with or is receiving services from the designated entity in pursuit of postsecondary education.  The Department expects to publish an initial listing of designated entities in 2014.

**Q9.Under the *FAFSA Completion Initiative*, can state student grant agencies share FAFSA Filing Status Information with any entity they choose?**

A9.No.  State student grant agencies may only provide FAFSA Filing Status Information to participating schools, districts, and designated entities, and only when certain conditions are met.  A state student grant agency may not provide FAFSA Filing Status Information to any other entity.  In all instances, before sharing any FAFSA Filing Status Information, the state student grant agency must have a written data sharing agreement with a secondary school, school district, or designated entity.

**Q10.Can state student grant agencies share students’ social security numbers (SSNs), student and parent financial information, or any other information from a student’s FAFSA form, under the *FAFSA Completion Initiative*?**

A10.No.  The only information that may be shared under the *FAFSA Completion Initiative*is the limited FAFSA Filing Status Information as described in Question 5.  State agencies cannot share students’ SSNs, student and parent financial information, or any other information from the FAFSA form.  

**Q11.What requirements must be met before a state student grant agency may share FAFSA Filing Status Information with secondary****schools, school districts, and designated entities under the *FAFSA Completion Initiative*?**

A11.A state student grant agency with a revised SAIG Agreement may not begin sharing FAFSA Filing Status Information until the agency has a written data sharing agreement with the school, district, or designated entity.  The written agreement must include procedures for oversight by the state student grant agency; appropriate privacy and data security provisions; and assurances from the secondary school, school district, or designated entity that it will appropriately safeguard the information, that it will not redisclose the information, and that it will comply with applicable privacy laws, including the Family Educational Rights and Privacy Act (FERPA).

**Q12.What participating secondary school, school district, or designated entity staff may have access to FAFSA Filing Status Information?**

A12.The revised SAIG agreement limits the use of FAFSA Filing Status Information to “authorized personnel.”  In general, the SAIG agreement defines “authorized personnel” to include employees, volunteers, and authorized agents, such as contractors or other parties to whom the LEA, secondary school, or designated entity has outsourced any of its services or functions and who are under the “direct control” of the participating secondary school, school district, or designated entity with respect to the use and maintenance of the information.  Any disclosure of FAFSA Filing Status Information to “authorized personnel” must comply with all applicable privacy laws, such as FERPA. 

**Q13.May a participating secondary school, school district, or designated entity redisclose or otherwise share FAFSA Filing Status Information received from a state student grant agency under the*FAFSA Completion Initiative*?**

A13. FAFSA Filing Status Information received by a participating secondary school, school district, or designated entity may not be redisclosed or otherwise shared with any other entity or individual other than the FAFSA applicant and, if the FAFSA applicant is under the age of 18, with his or her parents.  However, the FAFSA Filing Status Information may be shared with another party with the FAFSA applicant’s consent or the consent of the FAFSA applicant’s parents if the FAFSA applicant is under the age of 18, or if such sharing is required by law and such use is consistent with all applicable privacy laws, including the privacy provisions of section 483(a)(3)(E) of the Higher Education Act of 1965, as amended, 20 U.S.C. 1090(a)(3)(E) and FERPA, 20 U.S.C. 1232g.

**Q14.Are****there any Federal financial resources available to support a state student grant agency’s participation in the *FAFSA Completion Initiative*?**

A14.No Federal financial resources are available to support participation in the *FAFSA Completion Initiative*.