FundSvcs Community

We are currently having a discussion about scholarship reporting to donors. In the past we have shared student info with donors as long as students have provide consent to do so. After further investigation and discussion on HEA 483 (below), it seems like we are not allowed to do that regardless of student permission.  I apologize if this has been discussed previously but I'm having a hard time searching for things at the moment and we are on a time crunch.  Does anyone have insight on if and how you are providing this information to your scholarship donors? Or have you stopped providing names altogether?

"HEA 483(a)(3)(E) states that FAFSA data may only be used for the "application, award, and administration of aid."  FAFSA data is interpreted to include anything related to a student's FAFSA or FSA.  If a scholarship is awarded based on a FAFSA calculation (e.g., if only Pell-eligible students are eligible for the scholarship), then it would include sharing FAFSA data.  If the award is based on FAFSA data, sharing the scholarship award with donors would be prohibited, even with student consent.  In that situation, the information must come from the student (not from the College), such as by a thank you letter written by the student.  The College should be cautious in this approach and not attempt to force a student to write a thank you note, since doing so could be viewed as conditioning an award on revealing confidential information."

Hey there, Jennifer.

What does Counsel say about this? And where did that quote come from? FASA?

In a 2019 presentation made by FSA at the FSA Training Conference for Financial Aid Professionals, they seem to suggest that certain information can be released to donors under certain circumstances. The Q&A from that presentation is included below.

I'd be inclined to have Counsel ask FSA directly what they consider to be a permitted use of the data:

John H. Taylor

Principal

John H. Taylor Consulting, LLC

2604 Sevier St.

Durham, NC   27705

johntaylorconsulting@gmail.com

919.816.5903 (cell/text)

Serving the Advancement Community Since 1987

We are currently having a discussion about scholarship reporting to donors. In the past we have shared student info with donors as long as students have provide consent to do so. After further investigation and discussion on HEA 483 (below), it seems like we are not allowed to do that regardless of student permission.  I apologize if this has been discussed previously but I'm having a hard time searching for things at the moment and we are on a time crunch.  Does anyone have insight on if and how you are providing this information to your scholarship donors? Or have you stopped providing names altogether?

"HEA 483(a)(3)(E) states that FAFSA data may only be used for the "application, award, and administration of aid."  FAFSA data is interpreted to include anything related to a student's FAFSA or FSA.  If a scholarship is awarded based on a FAFSA calculation (e.g., if only Pell-eligible students are eligible for the scholarship), then it would include sharing FAFSA data.  If the award is based on FAFSA data, sharing the scholarship award with donors would be prohibited, even with student consent.  In that situation, the information must come from the student (not from the College), such as by a thank you letter written by the student.  The College should be cautious in this approach and not attempt to force a student to write a thank you note, since doing so could be viewed as conditioning an award on revealing confidential information."

Thanks for that info.  I need to confirm but I believe that text I included was the interpretation that came from our counsel. They are telling us that if a scholarship has any kind of "need" criteria that we can't disclose student info even with written consent from the student, which seems to contradict the first statement from the FAQ you provided.

We would certainly love it if all of our students would participate in sharing their story with our donors but it continues to prove a difficult task for us to motivate them to do so, leaving our hands somewhat tied on stewarding our donors they way they would like to be stewarded. 

Hey there, Jennifer.

What does Counsel say about this? And where did that quote come from? FASA?

In a 2019 presentation made by FSA at the FSA Training Conference for Financial Aid Professionals, they seem to suggest that certain information can be released to donors under certain circumstances. The Q&A from that presentation is included below.

I'd be inclined to have Counsel ask FSA directly what they consider to be a permitted use of the data:

John H. Taylor

Principal

John H. Taylor Consulting, LLC

2604 Sevier St.

Durham, NC   27705

johntaylorconsulting@gmail.com

919.816.5903 (cell/text)

Serving the Advancement Community Since 1987

We are currently having a discussion about scholarship reporting to donors. In the past we have shared student info with donors as long as students have provide consent to do so. After further investigation and discussion on HEA 483 (below), it seems like we are not allowed to do that regardless of student permission.  I apologize if this has been discussed previously but I'm having a hard time searching for things at the moment and we are on a time crunch.  Does anyone have insight on if and how you are providing this information to your scholarship donors? Or have you stopped providing names altogether?

"HEA 483(a)(3)(E) states that FAFSA data may only be used for the "application, award, and administration of aid."  FAFSA data is interpreted to include anything related to a student's FAFSA or FSA.  If a scholarship is awarded based on a FAFSA calculation (e.g., if only Pell-eligible students are eligible for the scholarship), then it would include sharing FAFSA data.  If the award is based on FAFSA data, sharing the scholarship award with donors would be prohibited, even with student consent.  In that situation, the information must come from the student (not from the College), such as by a thank you letter written by the student.  The College should be cautious in this approach and not attempt to force a student to write a thank you note, since doing so could be viewed as conditioning an award on revealing confidential information."

Does anyone have insight on if and how you are providing this information to your scholarship donors? We provide student info. If we cannot get a student written letter we provide basics. First Name, Last Name Initial, Major, Grade level & GPA. 

Thanks for that info.  I need to confirm but I believe that text I included was the interpretation that came from our counsel. They are telling us that if a scholarship has any kind of "need" criteria that we can't disclose student info even with written consent from the student, which seems to contradict the first statement from the FAQ you provided.

We would certainly love it if all of our students would participate in sharing their story with our donors but it continues to prove a difficult task for us to motivate them to do so, leaving our hands somewhat tied on stewarding our donors they way they would like to be stewarded. 

Hey there, Jennifer.

What does Counsel say about this? And where did that quote come from? FASA?

In a 2019 presentation made by FSA at the FSA Training Conference for Financial Aid Professionals, they seem to suggest that certain information can be released to donors under certain circumstances. The Q&A from that presentation is included below.

I'd be inclined to have Counsel ask FSA directly what they consider to be a permitted use of the data:

John H. Taylor

Principal

John H. Taylor Consulting, LLC

2604 Sevier St.

Durham, NC   27705

johntaylorconsulting@gmail.com

919.816.5903 (cell/text)

Serving the Advancement Community Since 1987

We are currently having a discussion about scholarship reporting to donors. In the past we have shared student info with donors as long as students have provide consent to do so. After further investigation and discussion on HEA 483 (below), it seems like we are not allowed to do that regardless of student permission.  I apologize if this has been discussed previously but I'm having a hard time searching for things at the moment and we are on a time crunch.  Does anyone have insight on if and how you are providing this information to your scholarship donors? Or have you stopped providing names altogether?

"HEA 483(a)(3)(E) states that FAFSA data may only be used for the "application, award, and administration of aid."  FAFSA data is interpreted to include anything related to a student's FAFSA or FSA.  If a scholarship is awarded based on a FAFSA calculation (e.g., if only Pell-eligible students are eligible for the scholarship), then it would include sharing FAFSA data.  If the award is based on FAFSA data, sharing the scholarship award with donors would be prohibited, even with student consent.  In that situation, the information must come from the student (not from the College), such as by a thank you letter written by the student.  The College should be cautious in this approach and not attempt to force a student to write a thank you note, since doing so could be viewed as conditioning an award on revealing confidential information."

Kirstie....

I would be very careful about releasing Major, Grade level and especially GPA.  Those are not considered directory data under FERPA, and thus are protected information.  Albeit you are you are only releasing last name initial, that still might be enough to identify an individual especially with grade level and major included. Have you considered omitting the name information all together?  

Terry Callaghan 

Does anyone have insight on if and how you are providing this information to your scholarship donors? We provide student info. If we cannot get a student written letter we provide basics. First Name, Last Name Initial, Major, Grade level & GPA. 

Thanks for that info.  I need to confirm but I believe that text I included was the interpretation that came from our counsel. They are telling us that if a scholarship has any kind of "need" criteria that we can't disclose student info even with written consent from the student, which seems to contradict the first statement from the FAQ you provided.

We would certainly love it if all of our students would participate in sharing their story with our donors but it continues to prove a difficult task for us to motivate them to do so, leaving our hands somewhat tied on stewarding our donors they way they would like to be stewarded. 

Hey there, Jennifer.

What does Counsel say about this? And where did that quote come from? FASA?

In a 2019 presentation made by FSA at the FSA Training Conference for Financial Aid Professionals, they seem to suggest that certain information can be released to donors under certain circumstances. The Q&A from that presentation is included below.

I'd be inclined to have Counsel ask FSA directly what they consider to be a permitted use of the data:

John H. Taylor

Principal

John H. Taylor Consulting, LLC

2604 Sevier St.

Durham, NC   27705

johntaylorconsulting@gmail.com

919.816.5903 (cell/text)

Serving the Advancement Community Since 1987

We are currently having a discussion about scholarship reporting to donors. In the past we have shared student info with donors as long as students have provide consent to do so. After further investigation and discussion on HEA 483 (below), it seems like we are not allowed to do that regardless of student permission.  I apologize if this has been discussed previously but I'm having a hard time searching for things at the moment and we are on a time crunch.  Does anyone have insight on if and how you are providing this information to your scholarship donors? Or have you stopped providing names altogether?

"HEA 483(a)(3)(E) states that FAFSA data may only be used for the "application, award, and administration of aid."  FAFSA data is interpreted to include anything related to a student's FAFSA or FSA.  If a scholarship is awarded based on a FAFSA calculation (e.g., if only Pell-eligible students are eligible for the scholarship), then it would include sharing FAFSA data.  If the award is based on FAFSA data, sharing the scholarship award with donors would be prohibited, even with student consent.  In that situation, the information must come from the student (not from the College), such as by a thank you letter written by the student.  The College should be cautious in this approach and not attempt to force a student to write a thank you note, since doing so could be viewed as conditioning an award on revealing confidential information."

I agree about the statement on GPA but this is the first I've heard of grade level and major not being considered directory information? We have it listed in our definition of directory info for our students and I know of many other schools that include it as well. 

Kirstie....

I would be very careful about releasing Major, Grade level and especially GPA.  Those are not considered directory data under FERPA, and thus are protected information.  Albeit you are you are only releasing last name initial, that still might be enough to identify an individual especially with grade level and major included. Have you considered omitting the name information all together?  

Terry Callaghan 

Does anyone have insight on if and how you are providing this information to your scholarship donors? We provide student info. If we cannot get a student written letter we provide basics. First Name, Last Name Initial, Major, Grade level & GPA. 

Thanks for that info.  I need to confirm but I believe that text I included was the interpretation that came from our counsel. They are telling us that if a scholarship has any kind of "need" criteria that we can't disclose student info even with written consent from the student, which seems to contradict the first statement from the FAQ you provided.

We would certainly love it if all of our students would participate in sharing their story with our donors but it continues to prove a difficult task for us to motivate them to do so, leaving our hands somewhat tied on stewarding our donors they way they would like to be stewarded. 

Hey there, Jennifer.

What does Counsel say about this? And where did that quote come from? FASA?

In a 2019 presentation made by FSA at the FSA Training Conference for Financial Aid Professionals, they seem to suggest that certain information can be released to donors under certain circumstances. The Q&A from that presentation is included below.

I'd be inclined to have Counsel ask FSA directly what they consider to be a permitted use of the data:

John H. Taylor

Principal

John H. Taylor Consulting, LLC

2604 Sevier St.

Durham, NC   27705

johntaylorconsulting@gmail.com

919.816.5903 (cell/text)

Serving the Advancement Community Since 1987

We are currently having a discussion about scholarship reporting to donors. In the past we have shared student info with donors as long as students have provide consent to do so. After further investigation and discussion on HEA 483 (below), it seems like we are not allowed to do that regardless of student permission.  I apologize if this has been discussed previously but I'm having a hard time searching for things at the moment and we are on a time crunch.  Does anyone have insight on if and how you are providing this information to your scholarship donors? Or have you stopped providing names altogether?

"HEA 483(a)(3)(E) states that FAFSA data may only be used for the "application, award, and administration of aid."  FAFSA data is interpreted to include anything related to a student's FAFSA or FSA.  If a scholarship is awarded based on a FAFSA calculation (e.g., if only Pell-eligible students are eligible for the scholarship), then it would include sharing FAFSA data.  If the award is based on FAFSA data, sharing the scholarship award with donors would be prohibited, even with student consent.  In that situation, the information must come from the student (not from the College), such as by a thank you letter written by the student.  The College should be cautious in this approach and not attempt to force a student to write a thank you note, since doing so could be viewed as conditioning an award on revealing confidential information."

We are currently having a discussion about scholarship reporting to donors. In the past we have shared student info with donors as long as students have provide consent to do so. After further investigation and discussion on HEA 483 (below), it seems like we are not allowed to do that regardless of student permission.  I apologize if this has been discussed previously but I'm having a hard time searching for things at the moment and we are on a time crunch.  Does anyone have insight on if and how you are providing this information to your scholarship donors? Or have you stopped providing names altogether?

"HEA 483(a)(3)(E) states that FAFSA data may only be used for the "application, award, and administration of aid."  FAFSA data is interpreted to include anything related to a student's FAFSA or FSA.  If a scholarship is awarded based on a FAFSA calculation (e.g., if only Pell-eligible students are eligible for the scholarship), then it would include sharing FAFSA data.  If the award is based on FAFSA data, sharing the scholarship award with donors would be prohibited, even with student consent.  In that situation, the information must come from the student (not from the College), such as by a thank you letter written by the student.  The College should be cautious in this approach and not attempt to force a student to write a thank you note, since doing so could be viewed as conditioning an award on revealing confidential information."