Probably, but not necessarily.
FERPA regulations apply to any public or private agency or institution “to which funds have been made available under any program administered by” the U.S. Department of Education. This includes funds provided “by grant, cooperative agreement, contract, subgrant, or subcontract” as well as funds “provided to students attending the agency or institution” which are paid “to the agency or institution by those students for educational purposes, such as under the Pell Grant Program and the Guaranteed Student Loan Program.”
If FERPA applies to any part of an educational agency or institution, then the regulations “apply to the recipient as a whole, including each of its components (such as a department within a university).”
FERPA does not apply if students attending an educational agency or institution solely receive non-monetary benefits under a program administered by the Department of Education