Late on Thursday, March 9, 2017, the IRS and U.S. Department of Education released a joint statement about the availability and status of the IRS Data Retrieval Tool (DRT) used to facilitate FAFSA completion. The statement called the temporary unavailability of the tool part of “a wider, ongoing effort at the IRS to protect the security of data.” The statement also pointed out that “the scope of the issue is being explored.” There are undertones that the DRT has been shut down under concerns of a cyber attack/hack, but this hasn’t been said in certain terms.
I’m all for data security. The owners of data have an obligation to ensure the security of the data they house. Cybersecurity breaches are on the rise everywhere. No organization, whether educational or corporate, can afford to be lax in terms of taking precautionary measures. The last time we pulled data from Symantec’s Internet Security Threat Report, educational services was tied for second in terms of the “Top 10 Sub-Sectors Breached by Number of Incidents.” Ranking first was health services. Educational services also made the list for the “Top 10 Sub-Sectors Breached by Number of Identities Exposed,” with 5,012,300—yes, that’s five million-plus.
Reminiscent of the Get Transcript Tool Issue
I applaud the IRS for taking action. However, I’m frustrated because this isn’t the first time the IRS has gone down this path. One would think that after the issues the IRS had with data security and the online Get Transcript Tool, officials would have better safeguards in place.
In May 2015, the IRS announced it had “discovered that criminals, using taxpayer information stolen elsewhere, had been able to pass procedures to access the Get Transcript application on IRS.gov.” Upon discovery of the issue, the Get Transcript Tool was made unavailable by the IRS—with very little communication or guidance to schools and students. At the time, the outage was identified as “temporary.” Fast forward a year and the tool was re-introduced. I hope that when we discuss “temporary outages” for the DRT, the IRS has a different definition of temporary than it has used in the past.
Data Retrieval Tool: Why Such a Big Deal?
The DRT being unavailable for, at a minimum of two weeks, is problematic. Students and financial aid offices are in crunch time. March and April are key months for creating and delivery financial aid award letters, and for students to make a choice and commit to a college. In addition, many states have deadlines for FAFSA submissions. As many as 15 states have deadlines falling between March to May. This means students need to complete the FAFSA on time to see a picture of the institutional, state, and federal aid options available to them. Without this clear picture, students cannot make well-informed financial decisions—something actively pushed by the entire higher education community.
Downtime Impacts Students
When discussing the impact on students, the joint IRS and Ed Department statement read: “This does not limit families’ ability to apply.” I beg to differ. It’s possible we have different definitions of the word limit, but I find this very limiting for students. While it is true that the unavailability of the DRT does not stop a student from completing the FAFSA, it certainly limits the likelihood of them completing it.
Additionally, May 1 is known as National Decision Day. It’s the deadline for students to identify the school they have chosen to attend. Making this decision is already incredibly stressful for students and families—and doesn’t need to be exacerbated.
Student Verification Impact
Students who use the DRT are less likely to be selected for the federal process called verification. During this process, a school is required to collect documentation from a selected student to ensure certain data elements on his or her FAFSA were reported correctly. The majority of the fields that get verified are of a financial nature. Use of the DRT eliminates the need for students to provide a copy of their Tax Transcript, obtainable only from the IRS.
Additionally, in October 2016 the industry shifted to prior-prior-year tax information, as opposed to prior-year tax information. With this shift, there exists a unique one-time possibility of a student having two FAFSAs filed that use the same 2015 tax data. That also creates an increased opportunity for financial information that should be the same on both applications to actually conflict.
The best way to avoid being selected for verification is to use the DRT. But, oh wait! You can’t do that for two weeks (minimum). One would anticipate that with the DRT down, verification and Comment Codes for conflicting information are going to increase significantly.