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Open Recommendations (53 total)

Cybersecurity: Office of Federal Student Aid Should Take Additional Steps to Oversee Non-School Partners' Protection of Borrower Information

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1 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education The Secretary of Education should develop policies and procedures to gain assurance that FFEL lenders have appropriate security and privacy controls in place and that these controls are being regularly tested and monitored. (Recommendation 6)
Open
FSA did not concur with this recommendation. In June 2023, FSA officials stated that they are still working to determine an action that that will address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Federal Chief Information Officers: Critical Actions Needed to Address Shortcomings and Challenges in Implementing Responsibilities

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1 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education The Secretary of Education should ensure that the department's IT management policies address the role of the CIO for key responsibilities in the five areas we identified. (Recommendation 7)
Open
The department agreed with our recommendation. As of August 2023, the department has taken some steps to implement the recommendation. Specifically, of the 17 responsibility gaps we identified, Education has addressed nine and partially addressed two. The remaining six responsibilities have not been established through agency policy. We will continue to monitor the steps the department takes to address these requirements.

Information Technology: Agencies Need to Fully Implement Key Workforce Planning Activities

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1 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education The Secretary of Education should ensure that the agency fully implements each of the seven key IT workforce planning activities it did not fully implement. (Recommendation 2)
Open – Partially Addressed
As of December 2023, the Department of Education had fully implemented two of the seven key IT workforce planning activities that we reported it did not fully implement. Specifically, in April 2023, the agency demonstrated that it had developed an IT workforce planning process. In addition, in December 2023, the agency provided evidence that it had assessed competency and staffing needs regularly. According to the agency's IT workforce plan, it plans to address the other five activities, including assessing competency gaps by the end of fiscal year 2024. We will continue to monitor the agency's efforts to address our recommendation.

Cybersecurity: Office of Federal Student Aid Should Take Additional Steps to Oversee Non-School Partners' Protection of Borrower Information

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3 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education The Secretary of Education should enroll private collection agencies in FSA's continuous monitoring program, and, in the interim, require these entities to test all controls at an FSA-defined frequency and regularly report the results. (Recommendation 2)
Open
FSA stated that it concurred with this recommendation and that private collection agencies (PCA) were to be enrolled in the agency's Ongoing Security Authorization program. In June 2023, FSA officials stated that all PCAs are being decommissioned and projected completion of this action by the end of January 2024. When we confirm what actions, the agency has taken in response to this recommendation, we will provide updated information.
Department of Education The Secretary of Education should establish a process for continuous monitoring of guaranty agencies' implementation of security and privacy requirements between on-site assessments, to include testing all controls at an FSA-defined frequency and regularly reporting results. (Recommendation 4)
Open
FSA partially concurred with this recommendation and described actions it planned to take in response. Specifically, FSA provided a standard operating procedure for continuous monitoring of guaranty agencies' implementation of security and privacy requirements between on-site assessments. However, the agency did not provide evidence that this process had been implemented. In June 2023, FSA officials stated that they planned to complete this action by the end of January 2024, but did not provide additional details or documentation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.
Department of Education The Secretary of Education should include specific security and privacy requirements in agreements with the Federal Family Education Loan (FFEL) Program lenders based on FSA's categorization of the information shared with the lenders. (Recommendation 5)
Open
FSA stated that it partially agreed with this recommendation and provided an updated version of its Organization Participation Agreement (OPA) with FFEL lenders. This agreement contains a number of specific security requirements, but it is unclear whether these requirements were derived from a categorization of the information or other risk-based analysis. In June 2023, FSA officials stated that FSA continues to work with lenders on a viable compliance supplement and that the projected completion date for this action is the end of December 2023. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Historically Black Colleges and Universities: Action Needed to Improve Participation in Education's HBCU Capital Financing Program

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1 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education The Executive Director of the HBCU Capital Financing Program should lead an agency effort to analyze various Capital Financing Program loan modifications, including the effects of the loan deferments authorized in the 2018 Consolidated Appropriations Act as well as other potential modifications, to assess the potential benefits to HBCUs participating in the program, the potential cost of these options to the government, and their effect on the program's overall financial stability. (Recommendation 2)
Open
Education partially agreed with this recommendation, commenting that it disagreed with the recommendation to the extent that it suggests a modification of loan terms. However, our recommendation does not endorse providing loan modifications to colleges but is focused on analyzing the costs and benefits of modifications authorized by law, as well as other potential modifications. Education noted it will continue to analyze loan modifications and develop cost estimates. Our report noted, however, that Education was not able to provide evidence of analysis it conducted on potential loan modifications. Regarding loan deferments, Education noted that it cannot complete its analysis until approximately two to three years after deferments have ended, allowing it to assess trends. The agency anticipates completing this effort by December 2025. Our recommendation is for Education to assess various modification options, and we continue to believe that analysis of costs and benefits is needed to determine whether additional loan modifications are necessary or beneficial for the program. We will close this recommendation once Education has assessed the effects of loan deferments as well as other modification options. In August 2022, the agency noted that the loans were forgiven along with other HBCU Capital Financing Program loans that were outstanding as of December 27, 2020. As such, there will not be a clear delineation between deferments and forgiveness. In addition, at the time of the recommendation, it was assumed that these loans would remain outstanding after the deferment ended to determine pre and post deferment effects.

Social Security Offsets: Improvements to Program Design Could Better Assist Older Student Loan Borrowers with Obtaining Permitted Relief

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1 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education To improve program design for Social Security offsets and related relief options, the Secretary of Education should inform borrowers about the financial hardship exemption option and application process on the agency's website, as well as the notice of offset sent to borrowers.
Open
The Department of Education initially agreed with the recommendation and said that they would include this change in upcoming revisions to the agency's web content. The Notice of Offset to borrowers is sent by Treasury and Education will share this recommendation with Treasury and discuss possible changes to the notice. On August 6, 2021, Education announced a final extension of the pause on student loan repayment and collections during the COVID emergency until January 21, 2022. During this time, defaulted borrowers are not subject to offset and do not need to request a financial hardship exemption. Prior to the pause, Education added information on its website to note that borrowers can request a review of their offset, but this information does not specifically say they can do so because of a financial hardship. In contrast, on the same website, Education informs borrowers they can request relief from wage garnishment for financial hardship. When Education resumes collection efforts, including offsets, we continue to encourage the agency to specifically inform borrowers about the financial hardship exemption option and application process on the agency's website. As of December 2023, we await the agency's update on its progress.

Social Security Offsets: Improvements to Program Design Could Better Assist Older Student Loan Borrowers with Obtaining Permitted Relief

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1 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education To improve program design for Social Security offsets and related relief options, the Secretary of Education should implement an annual review process to ensure that only eligible borrowers are exempted from offset for financial hardship on an ongoing basis.
Open
On August 6, 2021, Education announced a final extension of the pause on student loan repayment and collections during the COVID emergency until January 21, 2022. During this time, defaulted borrowers are not subject to offset and do not need to request a financial hardship exemption. Prior to the pause, Education reported that it plans to fully automate their process for tracking hardships and other exemptions from offset as part of its redesign of the student loan financial services environment. When Education resumes collection efforts, including offsets, and proceeds with planned changes to the student loan financial services environment, we continue to encourage the agency to implement an annual review process for financial hardship exemptions from offset. As of December 2023, we await the agency's update on its progress.

Federal Student Loans: Education Needs to Improve Its Income-Driven Repayment Plan Budget Estimates

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1 Open Recommendations
Agency Affected Sort descending Recommendation Status
Department of Education The Secretary of Education should complete efforts to incorporate repayment plan switching into the agency's redesigned student loan model, and conduct testing to help ensure that the model produces estimates that reasonably reflect trends in Income-Driven Repayment plan participation.
Open – Partially Addressed
The Department of Education (Education) agreed to incorporate repayment plan switching into its redesigned student loan model, reiterating that efforts to incorporate this capability into a new microsimulation model had begun despite challenges inherent in predicting borrower behavior. To address this recommendation, Education awarded a contract to develop a new microsimulation model with plans for the model to include predictions regarding repayment plan switching. As of December 2021, the contractor had completed the model's initial design phase, and Education had plans for the model to predict repayment plan switching. As of January 2024, officials stated that they plan to test and launch the model in Fall 2025 and launch it officially in Fall 2026 to generate estimates for the President's FY 2028 budget request.