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FERPA and Financial Aid

The Family Educational Rights and Privacy Act of 1974 (FERPA) protects
the privacy of student records by requiring prior written consent
before disclosing personally identifiable information to a third
party. It applies to colleges and universities that receive funding
from the federal government.

FERPA applies to the Financial Aid Office

Records created and maintained by the financial aid office are
considered to be education records and may not be disclosed without
the student's consent. This includes at least all of the following
records:

Records relating to eligibility and disbursement of Federal
 student aid funds

Student account

Federal work-study payroll records

Financial aid applications

SARs and ISIRs

Documentation of professional judgment decisions

Documentation relating to a refusal to certify Federal education
 loans

Financial aid history information (for transfer students)

Cost of attendance information, including documentation relating
 to any adjustments

Satisfactory Academic Progress (SAP) documentation

Documents used for verification

Entrance and exit counseling records

Financial records

Educational records include any materials received from the student
and/or parents. It also includes any records that were used to make
decisions about the student.

Only those records that are directly related to the student are
considered to be educational records.

Although employment records are not considered education records by
FERPA, student employment records are considered to be education
records. So the employment records of a university employee who takes
a class are not protected by FERPA, but the employment records of a
work-study student are protected by FERPA. The distinction is whether
the employment resulted from the individual's status as a student.

Medical records are not necessarily protected by FERPA. If such
records are not protected by FERPA, they may be protected by HIPAA.

Format of Records

Educational records include records, files, documents, video tapes,
audio tapes, film, microfilm, microfiche, electronic records and other
materials that contain information that is directly related to the
student (i.e., personally identifiable information).

Certain documents must be maintained either in hardcopy format or in
an imaged media format. This includes any documents for which a
visible mark is used to validate authenticity, such as documents that
contain a signature, seal or other certification. Examples include
income tax returns, notarized documents, verification statements, and
SARs.

Record Retention

FERPA proper only requires that one keep a record of all disclosures
of education records and that one retain any records that are subject
to a pending disclosure request. The General Education Provisions Act,
as amended by the Improving America's Schools Act of 1994, requires
education records to be retained for at least three years. In most
cases this means that records must be kept at least three years from
the end of the award year. For some records, a different reference
date is used. For example, records concerning education loans must in
most cases be kept for at least three years from the end of the award
year in which the student last attended.

Right to Review and Challenge Records

FERPA also requires the school to give the student the opportunity to
review his or her records and request a change to the records. If the
request to change the records is denied, the student may request a
hearing to challenge the contents on the grounds that the records are
inaccurate, misleading, or violate the rights of the student. If the
school does not amend the records after the hearing, the student has
the right to place a statement in the record concerning the contested
information.

While FERPA requires the school to allow the student to inspect and
review his educational records, it does not require the school to
provide the student with copies of those records, unless the
requirement to inspect the records in person would effectively deny
access to the records. No fees may be charged for retrieving the
records, but a reasonable fee may be charged for providing copies of
the records, provided that the fee would not prevent access to the
records.

The school may disclose the education records of a student to his or
her parents, without the student's consent, if the student is
dependent according to IRS rules (i.e., claimed as a dependent on the
parents' income tax return, per IRC Section 152). This includes both
parents even if the parents are divorced. The non-custodial parent may
see the student's education records even if he or she doesn't claim
the student as a dependent, so long as the other parent claims the
student as a dependent. (This may also include financial records,
which is often a concern to parents who are divorced. 34 CFR 99.12(b)
specifies that a school does not have to permit a student to review
the financial records of his parents. Accordingly, many schools have
more restrictive disclosure policies, requiring consent of the
individual who supplied the education records before disclosing that
information to the student or the other parent.) If the student is not
claimed as a dependent by his or her parents, the parents do not have
the right to review the student's education records, not even if they
pay the tuition bills.

If a divorce decree, separation agreement, custody agreement,
restraining order, or other legally binding agreement or court order
revokes a parent's right to see the student's education records, the
school may not disclose the student's education records to that
parent.

The student's spouse or ex-spouse does not have the right to review
the student's educational records. For example, if a student's
ex-spouse alleges that the student provided false information on her
financial aid application, the school may not disclose the student's
records to the ex-spouse. (This is a tricky situation, and the school
should generally seek the advice of counsel before proceeding.) The
school may receive information from the ex-spouse and treat it as
conflicting information, but should take care to avoid disclosing any
information in the student's file to the ex-spouse and may wish to
have the ex-spouse sign a FERPA waiver if the ex-spouse is also a
student. If the school receives a subpoena for the information, the
school should refer the matter to the school's attorneys and wait for
instructions from the attorneys before disclosing any information.

FOIA

Some education lenders have been attempting to use the Freedom of
Information Act (FOIA, 5 USC 552) and similar state statutes to obtain
student information. When these efforts try to obtain anything other
than directory information, including directory information that has
been subsetted by any nondirectory information such as financial aid
status, they represent a violation of FERPA and the school should not
comply.

The US Department of Education wrote in Dear Colleague Letter
GEN-07-05 that "The Federal FOIA only applies to Federal agencies and
their employees. Institutions that participate in the Title IV, HEA
programs are not subject to the Federal FOIA and therefore are not
required to release any student information under this law."

State freedom of information laws are trumped by FERPA. It would be a
good idea to ask school counsel to review any request to obtain
student records under FOIA or other laws.

Exceptions to Consent

Disclosure of education records without consent is permitted in
certain circumstances.

FERPA does not preclude the disclosure of statistical, non-personally
identifiable information.

Disclosure of education records is permitted to authorized
representatives of the US Department of Education (including
contractors and the Office of the Inspector General) as well as state
and local education authorities.

Disclosure of education records is also permitted to the INS for
international students who have signed a Form I-20 or who are
attending under an M-1 or J-1 visa.

If the student applied for financial aid or received financial aid,
disclosure is permitted if needed to determine financial aid
eligibility or the amount of aid, or to enforce the terms and
conditions of the aid.

For example, the school must provide directory information to the US
Department of Education for recipients of Federal student aid funds
who attend or attended the school. Likewise, the school must provide
directory information for FFEL borrowers to the relevant lender and/or
guarantee agency.

Disclosures to other departments or business units of the school are
generally prohibited unless they have a legitimate educational
interest in the records. For example, the financial aid office may not
disclose information in the student's financial aid records to the
alumni or development office. (Typically, the development office will
want to use this information to identify wealthy parents. FERPA
prohibits providing the development office with this information,
since the disclosure is not narrowly limited to a legitimate
educational interest. Even if the college establishes it as a
legitimate educational interest in advance through the annual notice
of FERPA rights, one must ask whether this disclosure is for the
benefit of the student or the benefit of the institution. Disclosures
that are contrary to the interest of the student may have a chilling
effect. For example, many families say they prefer private education
loans over Federal education loans because of concerns over privacy.
They trust the education lenders with their private information more
than they trust the college.) When disclosure to a different school
department is permitted, the disclosure must be limited to just the
information for which they have a legitimate educational interest. For
example, although some information may be shared with the registrar,
the registrar does not have a legitimate educational interest in some
of the information contained in ISIR records, so the financial aid
office may not give the registrar copies of the full ISIR records.

Note, however, that at many schools the alumni office is a separate
corporate entity. If the alumni office is not part of the university,
it would be a FERPA violation to share educational records with them
even if they have a legitimate educational interest in the records.
FERPA only allows an exception to consent on the basis of an
educational interest when the records are being disclosed to
university employees, not a separate entity.

As part of the annual notice of the student's FERPA rights, the school
is required to identify which school officials (i.e., which offices
and employees) have a legitimate educational interest and may access
the student's education records without the student's consent.

The school must also control redisclosure of records. In particular,
if the financial aid office shares information with another office,
that office must agree to not redisclose the information it has
received.

The student's education records may be disclosed to either parent of a
dependent student, where dependent follows the IRS definition (i.e.,
50% support test), not the Federal student aid definition. Since this
technically means that divorced parents could see the information
submitted by the other ex-spouse, many schools go beyond the minimal
FERPA requirements in their own policies, requiring consent of the
party that provided the information before releasing it to the other
parent or to the student. FERPA does not require the school to
disclose the parent's financial records to the student. (See 34 CFR
99.4, 34 CFR 99.7, 34 CFR 99.10, 34 CFR 99.12(b), 34 CFR 99.31(8) and
34 CFR 99.32 for details.)

The health or safety emergency exception allows disclosure without
consent where the information that is disclosed will help prevent or
mitigate a serious threat to the health or safety of the student,
other students, or other members of the school community. The threat
must be imminent and the disclosure must be narrowly tailored to the
nature of the emergency.

Law enforcement unit records may be released without the student's
consent. This includes, for example, records maintained by the campus
police.

Schools may disclose information concerning sex offenders that they
received under a State sex offender registration and community
notification program.

Educational records may be disclosed in response to a lawfully issued
subpoena or court order or an ex parte order in connection with the
investigation or prosecution of terrorism crimes. Since financial aid
office staff are not qualified to determine whether a subpoena or
court order is properly issued and qualifies for the disclosure
exception, all such requests for disclosure should be turned over to
the school's attorney. The school's attorney may take steps to
challenge the subpoena (e.g., have it limited, modified or quashed)
and will comply with any requirements to notify the student. Do not do
anything in response to a subpoena or court order until the school's
attorney tells you what to do. (Schools most often encounter this kind
of problem when a student is getting divorced. Such requests for
educational records may or may not satisfy the requirements for a
FERPA exception, and only the school's attorney can make that call.)

Directory information, which is information that is not considered
harmful or an invasion of privacy if released, may be disclosed
without consent. However, the school must provide students and parents
with the opportunity to opt-out of such disclosures. The school may
not disclose directory information for a subset based on non-directory
information, such as race or gender, as that would implicitly disclose
the non-directory information. Dear Colleague Letter GEN-07-05
emphasizes that directory information that is linked to non-directory
information, such as financial aid status, may not be disclosed.
Directory information includes the student's name, address, telephone
number, email address, dates of attendance, year in school, enrollment
status (full or part-time, graduate or undergraduate), photograph,
majors, degrees, honors and awards, age or date of birth, place of
birth, participation in extracurricular activities and sports, and
height/weight for members of athletic teams. Directory information
does not include race, gender, national origin, GPA, amounts of any
awards (e.g., donor awards), student ID number, or Social Security
Number.

Because the Solomon Amendment (10 USC 983 and 32 CFR 216) was enacted
after FERPA and is more specific than FERPA, it appears to override
FERPA. The Solomon Amendment gives the Armed Forces the authority to
request the following information about currently enrolled students
age 17 years and older: name, address, telephone numbers, date of
birth (or age), place of birth, level of education (e.g., freshman,
sophomore, junior, senior), academic majors, degrees received, and
most recent education institution in which the student was enrolled.
This means that the US Armed Forces may request directory information
for currently enrolled students for military recruitment purposes. (32
CFR 216.4(5) contains an opt-out requirement similar to FERPA.) So
there is apparently no real conflict with FERPA; FERPA permits the
disclosure of directory information without requiring consent when the
student hasn't opted-out, while the Solomon Amendment mandates the
disclosure to the US Armed Forces Recruiting. However, FERPA does
allow a school to have a more restrictive policy, and the Solomon
Amendment appears to trump that. If a school refuses to permit such a
disclosure, they will lose access to federal funds from the
Departments of Defense, Labor, Health and Human Services, Homeland
Security, and Education. However, Public Law 106-79, excludes Federal
Student Aid from the limitation, so a failure to comply with the
Solomon Amendment would not necessarily affect a school's eligibility
for federal student aid according to current law, although other US
Department of Education grants might be affected. The financial aid
office should forward all such requests to the school's attorneys.
(Enforcement of the Solomon Amendment is subject to ongoing
litigation. The US Court of Appeals for the Third Circuit ruled on
November 29, 2004 in FAIR et al. v Rumsfeld that colleges with
policies that prohibit discrimination against gays and lesbians may
bar military recruiters from their campuses without penalty because
the armed forces discriminate against openly gay men and women. The
ruling was focused on First Amendment issues, indicating that the
Solomon Amendment would violate the Constitution's guarantee of free
speech. The Third Circuit Court of Appeals includes Delaware, New
Jersey, Pennsylvania, and the Virgin Islands.)

FERPA does not apply to students who have been admitted but not yet
enrolled. This can allow more open discussion of education records
with prospective students. Once a student registers or begins
attending classes, consent is required. FERPA also does not apply to
records relating to alumni after they are no longer enrolled, provided
that the records do not pertain to the alumni's previous activities as
a student.

Most third party disclosures of a student's education records must be
documented in the student's file. The main exception is in response to
an ex parte order.

Be careful about disclosing information over the telephone or email.
Unless you've clearly authenticated the student's identity (e.g., via
a prearranged PIN or password), you have no way of knowing that you're
talking to the student. If it is merely someone pretending to be the
student (e.g., a roommate, significant other, or relative), you've
disclosed personally identifiable information without consent. Keep in
mind that these individuals may know many of the identifiers you might
ordinarily use to authenticate identity, such as date of birth, social
security number, and mother's maiden name, so those identifiers are
insufficient to guarantee the privacy of the student's information.

Even caller ID cannot be trusted, since it is relatively easy to spoof
the caller ID. (The caller ID information provided to businesses in
connection with a toll free number uses a different system that is
much more difficult to spoof.) If you are going to disclose
information over the telephone, only do so after you've called back
the individual at a telephone number you have on file for them.

The informal nature of a telephone call makes it very easy to
accidentally disclose information. Private investigators routinely use
pretexting (pretending to be someone that they aren't) and other
techniques to extract information. For example, getting someone to
correct an error is often used. They ask you "when did so and so
graduate" and when you say "they haven't graduated yet", you just
disclosed that they are a student.

It is also a good idea to establish disclosure rules governing who has
access to review educational records, modify educational records,
grant access to the records, and revoke access to the records. For
example, even though the student make consent to disclosure to a third
party, that third party then does not have the authority to redisclose
that information or grant access to someone else to the records.

Leaving messages by telephone, email and fax are also potentially
problematic, because you don't know who has access to their voicemail
or email account.

Consent Mandatory

Except for the exceptions mentioned above, the school must obtain
prior written consent from the student before making a disclosure of
the student's education records.

Disclosure Examples

A school may release directory information to a collection agency in
connection with collecting a delinquent student account, even if the
student opted-out of the release of directory information. However,
the school is liable for any failure by the collection agency to
comply with FERPA.

If the student's tuition is being paid by a third party (e.g., the
student's company is paying for his or her MBA degree), the school may
not disclose the student's financial aid information without consent.
In particular, if a student who is not dependent according to IRS
rules is receiving financial support from a parent, the parent does
not have the right to see that student's records without the student's
consent. It is generally a good idea to get the student to sign a
FERPA waiver that specifies who may access their records.

A school may not release a list of the recipients to an award donor or
other third party without prior written consent of the recipients
unless the disclosure is necessary for verifying eligibility,
selecting recipients (if the student applied for the award),
disbursing the award, or otherwise part of the terms and conditions of
the award. Even if disclosure is permitted, it is generally a good
idea to specify on the award letter whether the school releases
information about recipients to award donors, and to identify the
information that is disclosed. Note that the school may not release a
list of eligible students to the award donor to allow the award donor
to select the recipients unless the students have applied for the
award or have otherwise provided written consent to the disclosure.
Likewise, the school may not publish a list of the recipients of an
award without the students consent, unless the student applied for the
award and such disclosure was included in the terms and conditions of
the award.

FERPA prohibits posting lists of students with refund checks in the
bursar's office.

Computer screens that display educational records should not be
visible from public areas, nor should such computers be left unsecured
and unattended.

If the education records contain information about more than one
student, each student may only see the part that relates to them.
Generally, if allowing a student to review his or her education
records would violate the privacy of a different student's records,
either the other student's information must be redacted or consent
must be obtained before disclosure.

Mailing labels for mailings to students should contain only the
student's name and address. FERPA prohibits including the student ID
or Social Security Number on the label on envelope.

Since a Social Security Number represents non-directory information, a
school may not use a Social Security Number to interface with
databases maintained by third parties, as that would represent a
disclosure of education records in violation of FERPA. To use a Social
Security Number to index into a third party database, either the
school must obtain the student's consent or one of the exceptions to
the consent requirements must apply (e.g., the third party is an
authorized representative of the US Department of Education or the
student's lender/guarantor).

Since Social Security Numbers are education records that are
personally identifiable, schools may not post lists containing Social
Security Numbers, in whole or in part, in any public area. In
particular, the practice of posting lists of grades in a class
according to the last four digits of the students' Social Security
Numbers is prohibited by FERPA. Similar restrictions apply to the use
of the student ID number. The professor may, however, assign each
student a temporary number known only to the professor and the student
for the purpose of posting grades.

FERPA prohibits telling anyone the student's current location without
the student's consent, unless the student's health or safety is in
imminent danger or the health or safety of another student or member
of the school community is in imminent danger. Schools should exercise
care before disclosing the student's current location, as often the
person requesting the information does not have the right to that
information and may be alleging an emergency in order to get access to
that information. In most circumstances the situation can be resolved
without disclosing the student's current location.

Class rosters and class schedules are not considered directory
information and may not be disclosed without consent. This is partly
because of concerns about student safety and partly because they may
lead to the indirect disclosure of sensitive information (e.g.,
enrollment in special education and remedial classes, student id
numbers and social security numbers included on class rosters).

If the student is transferring to another school, the old school may
provide the student's educational records to the new school without
consent, but must notify the student of the request for the records.

If a student is attending a school and applies to a different
component of that school (e.g., an undergraduate applying to graduate
school or to a different department), the student does not have the
right to review the education records maintained by that component
until the student is accepted and attends that component.

If the student signed a waiver of his right to see a letter of
recommendation, the school may not disclose the letter of
recommendation to the student. This includes letters of recommendation
for employment and awards, in addition to letters of recommendation
for admission. There is no defense of infancy with regard to such
waivers. If the letter of recommendation was added to the student's
file before January 1, 1975, the school does not have to allow the
student to review the letter even if the student did not sign a
waiver.

Examples of personally identifiable information include the student's
name, the name of the student's parents or other family members, the
address of the student, the address of the student's family members,
social security numbers, student id numbers, a physical description or
other personal characteristics that are easily traceable, and other
information that would make the student's identity easily traceable.

Personally identifiable information includes any single characteristic
or combination of characteristics which would make it possible to
identify the student. This includes any information which, when
combined with an external database, would enable the identification of
a particular student. All information which may be potentially traced
to an individual student must be redacted. If no information is left
after such information is removed, then no disclosure is permitted. As
a general rule, anonymized data about individual students should not
be disclosed, as the information is still potentially traceable. On
the other hand, information may be released in statistical aggregate
summaries so long as the cohorts are of sufficient size to prevent an
individual student from being identified. It is common to perturb data
in small data sets to prevent such disclosure, or to omit information
in small data sets if the mere existence of the data set is
problematic.

School disciplinary records are protected by FERPA and may not be
disclosed without the student's consent. The final result of a
disciplinary proceeding, however, may be disclosed.

Confirming the accuracy or inaccuracy of information about a student
represents a disclosure of information about the student, and so is
prohibited by FERPA without the student's consent. For example, it is
a common reporter's trick to make a statement of unknown accuracy
about a subject in order to get a confirmation or a correction.

It is a good idea to have every student (and possibly also the
parents) sign a document specifying the circumstances under which the
school may disclose information to third parties and specifying what
information may be released.

Colleges are able to withhold transcripts from students who owe them
money. FERPA just requires that they have access to their records.
FERPA does not require you to provide official certified copies of
those records in most cases.

It is also a good idea to have all work-study students who have access
to educational records in the course of their duties to sign a
confidentiality agreement and undergo FERPA training. Some schools
limit their access and prohibit them from making any disclosures of
confidential information. If they receive a request for this
information, ask them to always refer the matter to one of your
permanent staff, and have that staff make the disclosure, if it is
warranted. Besides allowing for the more seasoned judgment of
permanent staff, this also gets a second set of eyes reviewing a
request for confidential information.

Kassebaum-Kennedy Act

If the financial aid office receives health records as part of a
professional judgment review for medical expenses, it may also have to
fulfill the requirements of the Health Insurance Portability and
Accountability Act of 1996 (HIPAA), also known as the
Kassebaum-Kennedy Act. The Department of Health and Human Services
(DHHS) has issued privacy regulations for medical records as part of
the HIPAA requirements (see the HIPAA Privacy Rule).

Gramm Leach Bliley Act

The Gramm Leach Bliley Act, also known as the Financial Modernization
Act of 1999, regulates the disclosure of non-public personal
information held by financial institutions.

The Federal Trade Commission (FTC) has ruled that colleges and
universities that offer education loans (e.g., Perkins and
institutional loans) are subject to the provisions of the Gramm Leach
Bliley Act. The FTC agreed in May 2000 to consider colleges and
universities to be in compliance with the privacy provisions of the
Act if they are in compliance with FERPA. In particular, 16 CFR 313.1
states that "Any institution of higher education that complies with
the Federal Educational Rights and Privacy Act ("FERPA"), 20 U.S.C.
1232g, and its implementing regulations, 34 CFR part 99, and that is
also a financial institution subject to the requirements of this part,
shall be deemed to be in compliance with this part if it is in
compliance with FERPA.". However, the schools remain subject to the
provisions of the Act relating to the administrative, technical and
physical safeguarding of customer information. For more information,
see NACUBO's report, Colleges and Universities Subject to New FTC
Rules Safeguarding Customer Information (January 13, 2003). See also
NACUBO's GLB Act Resource Page.

Best Practices

Each school is required to have a written FERPA policy. Schools are
allowed to have an educational records policy that is more stringent
than FERPA. For example, even though FERPA allows one parent to see
the information submitted by the other parent (e.g., for dependent
students with divorced parents), most schools will require consent of
the party that provided the information before disclosing it to the
other parent or to the student.

In many cases the requirements of FERPA merely permit one to disclose
information, but do not require it. For example, one is permitted to
disclose directory information (except when the student has opted
out), but is not required to disclose it. The main exception is the
Solomon Amendment, which trumps FERPA. It is quite common for schools
to define directory information to the full extent as specified by
FERPA, but then to establish more restrictive institutional policies
concerning disclosure of directory information. Using the maximal
definition of directory information under FERPA establishes a safety
net that protects the school in case an employee accidentally
disclosed information that is contrary to the institution's disclosure
policy but which is within the safe harbors provided by FERPA.

Even directory information can cause harm to students, because it
reveals that they are students. It is not uncommon for scholarship
scams to rent lists of student names and addresses. Often this
information is obtained by someone getting a copy of the university's
telephone directory.

The financial aid office may forward a letter to students on behalf of
a university department that is not entitled to the student's
educational records (e.g., to notify Pell-eligible students about a
new departmental need-based scholarship), so long as the educational
records are not disclosed to the department. However, this can create
the appearance of a FERPA violation, so the financial aid office
should exercise caution before engaging in such a practice, take steps
to mitigate the appearance of a violation (i.e., send the notice on
financial aid office letterhead instead of forwarding the other
department's letter), and get approval of the school's FERPA
compliance officer before proceeding.

It's generally a good idea to go beyond the requirements of FERPA.
Consider the sensitive nature of the information. You are protecting
not just the student's name and GPA, but also income and asset
information. How would you feel if this was your information that was
disclosed without your consent? Establishing strong protections for
student records is often easy to implement and is just the right thing
to do. It avoids future problems, such as the potential for bad
publicity associated with questionable disclosures. How would you feel
if a student was stalked, raped or murdered because of your
disclosure?

Financial aid offices should apply careful scrutiny to any request
that is unrelated to eligibility for student aid, the application for
student aid, enforcing the terms and conditions of student aid, or the
provision of directory information. Be especially wary of any
information that can be combined with other information to reveal
private information.

FERPA Videos

Some colleges have created training videotapes to help educate staff
about FERPA. These include the following:

CVTC

University of Texas at San Antonio

Washington State University

Whitworth University

Legislative Authority, Regulations and Published Guidance

The Family Educational Rights and Privacy Act of 1974 (FERPA), also
known as the Buckley Amendment, appears in 20 USC Ch. 31, Sect. 1232g.
Regulations relating to FERPA appear in 34 CFR 99 (alternate).

The US Department of Education has published a set of guidelines to
help schools develop policies and procedures relating to FERPA,
Protecting the Privacy of Student Records: Guidelines for Education
Agencies, US Department of Education, NCES 97-527, July 1997. Please
note that this document was published in July 1997, and has not been
updated for changes in the law since then. More up-to-date information
can be found in the FSA Handbook (Volume 2, Chapter 7 "Consumer
Information" and Volume 2, Chapter 8 "Recordkeeping and Disclosure"),
which can be found on the IFAP web site. See also Forum Guide to
Protecting the Privacy of Student Information: State and Local
Education Agencies, National Forum on Education Statistics, NCES
2004-330, March 2004.

FERPA is managed within the Family Policy Compliance Office of the US
Department of Education. They are the definitive source of FERPA
regulations and guidance concerning FERPA. For more information, call
1-202-260-3887 (TDD 1-800-877-8339), fax 1-202-260-9001, write to
Family Policy Compliance Office, US Department of Education, 400
Maryland Avenue, SW, Washington, DC 20202-5901, or send email to
ferpa@ed.gov.

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