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My thoughts on GEN-24-71 (Resolving Conflicting Information) and important Federal Tax Information (FTI) Updates
A colleague brought GEN-24-71 to my attention when I was in the Federal Tax Information (FTI) session at the NASFAA conference in Milwaukee, Wisconsin. I was able to quickly review the document and talk to some representatives from Federal Student Aid (FSA) at the conference, so this update includes some information learned by talking with Federal Student Aid (FSA) representatives who were available at the NASFAA conference. (Read the full Electronic Announcement below).
Before I get into the new information, I want to share something from the NASFAA conference that I think may be one of the most important instructions announced by FSA. Do not include FTI in emails, even to representatives of the Department of Education (ED) or others who have access to it. Email is not a secure medium, and including FTI in an email is a data security breach. You can mention your concerns in communications to ED and name the fields you are concerned about but should not include the values in those fields. If ED needs more information, they will reach out with instructions about what they need and if it needs to be shared in a secure manner, how to do that.
This serves as a reminder about how easy it is to casually share sensitive and protected data, creating reporting requirements and liability.
What’s New in FTI?
FSA has been promising to release comprehensive guidance about how FTI can and cannot be used for months. It is clear they are negotiating with the IRS, who owns the FTI, to make the data as available as possible while remaining in compliance with the IRS Code. In the NASFAA FTI session, FSA shared a few new and very important details, indicating that they are making progress in their negotiations.
Remember, staff members and consultants under the control of the institution are authorized to access FTI “solely for the use in the application, award, and administration of financial aid…”. Institutions cannot use FTI for functions that are not covered by these activities...
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