Recommendation: The Administrator of FNS should develop and implement a process, documented in policies and procedures, to analyze SNAP state-level root causes to identify potential similarities among the states and develop and implement SNAP agency-level corrective actions, if appropriate, to help address them. (Recommendation 1)

Agency: Department of Agriculture: Office of the Secretary: Food, Nutrition and Consumer Services: Food and Nutrition Service
Status: Open

Comments: In commenting on our draft report, USDA stated that the Food and Nutrition Service should formalize its existing processes into a standard operating procedure to analyze the Supplemental Nutrition Assistance Programs (SNAP) state-level root causes to identify potential similarities among states, in order to improve development and implementation of SNAP agency-level corrective actions, if appropriate.

Recommendation: The Secretary of Agriculture should revise USDA's procedures to include processes for monitoring the progress and measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect USDA's corrective actions have on reducing improper payments. (Recommendation 2)

Agency: Department of Agriculture
Status: Open

Comments: In commenting on our draft report, USDA stated that a proposed action plan will be developed to revise USDA's procedures for monitoring the progress and measuring the effectiveness of improper payment corrective actions. Processes will focus on the impact corrective actions have on the root causes of improper payments.

Recommendation: The Secretary of Education should revise and document Education's process for measuring the effectiveness of its corrective actions based on its new statistical estimation methodology for Direct Loan and Pell Grant improper payments. This process should clearly demonstrate the effect Education's corrective actions have on reducing improper payments. (Recommendation 3)

Agency: Department of Education: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Education stated that Federal Student Aid (FSA) will continue to evaluate and refine its processes to measure corrective actions and the effectiveness of these actions. Further, Education stated that FSA's measurement of corrective action effectiveness and root cause identification will gain additional precision as FSA collects annual improper payment data and builds upon the new baseline of statistically valid improper payment estimates. Education stated that FSA annually measures the overall effectiveness of its corrective action plans collectively against the improper payment reduction targets, rather than measuring the effectiveness of each individual corrective action. However, OMB guidance directs agencies to measure the effectiveness of each individual corrective action annually.

Recommendation: The Secretary of Health and Human Services should document in policies and procedures HHS's improper payment corrective action plan process. As part of these procedures, HHS should include processes for (1) establishing planned completion dates, (2) monitoring the progress of implementing corrective actions, and (3) measuring the effectiveness of improper payment corrective actions. The process for measuring the effectiveness of corrective actions should clearly demonstrate the effect HHS's corrective actions have on reducing improper payments. (Recommendation 4)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, HHS elaborated on the improper payment corrective action plan process that is called for in OMB guidance. HHS stated that OMB guidance provides agencies the flexibility to measure the effectiveness of corrective actions and believes that this flexibility is vital to its oversight processes to reduce improper payments.

Recommendation: The Secretary of the Treasury should determine whether Treasury's current improper payment root cause analysis provides sufficiently relevant information that can be used as a basis for proposed corrective actions in reducing EITC improper payments and, if not, update the analysis using more timely data to ensure their reliability for identifying root causes of EITC improper payments. (Recommendation 5)

Agency: Department of the Treasury: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments.

Recommendation: The Secretary of the Treasury should update Treasury's strategy for addressing the root causes of EITC improper payments to include (1) coordinating with other agencies to identify potential strategies and data sources that may help in determining EITC eligibility and (2) determining whether legislative changes are needed, and developing proposals as appropriate, to help reduce EITC improper payments, such as those related to the inability to authenticate taxpayer eligibility. (Recommendation 6)

Agency: Department of the Treasury: Office of the Secretary
Status: Open

Comments: In commenting on our draft report, Treasury stated that each year it indicates in its corrective action plan that IRS will continue to work with Treasury to develop legislative proposals that will improve refundable credit compliance and reduce erroneous payments. Although Treasury has made certain legislative proposals, it has not made proposals to specifically help address EITC eligibility criteria issues. Additionally, Treasury's strategy does not include identifying and proposing additional legislative changes needed to help reduce EITC improper payments.

Recommendation: The Commissioner of SSA should develop and implement a process, documented in policies and procedures, to measure the effectiveness of SSA's corrective actions for OASDI and SSI improper payments. This process should clearly demonstrate the effect SSA's corrective actions have on reducing improper payments. (Recommendation 7)

Agency: Social Security Administration
Status: Open

Comments: In commenting on our draft report, SSA stated that it will determine the most cost-effective strategies to remediate the underlying causes of payment errors and monitor, measure, and revise the strategies as needed.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, provide updated guidance for the oversight of privatized military housing, to include oversight objectives for each service to monitor the physical condition of privatized homes over the remaining duration of the ground leases. (Recommendation 1)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD (S)), as the Chief Housing Officer, issued guidance requiring the military departments to monitor work order completion for housing privatized under the Military Housing Privatization Initiative based on a combination of resident input, timeliness of work order completion, and number of repeat work orders for the same repair. The guidance also required increased tracking of MHPI project work orders by installation staff. Moving forward, the ASD(S) plans to issue quarterly program review guidance that establishes oversight objectives for the military departments to monitor the physical condition of MHPI housing over the duration of their project ground leases, formalizing the requirement that the data be monitored by the Chief Housing Officer. DOD expects this to be completed by December 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Army should take steps, in collaboration with the Army's private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 2

Agency: Department of Defense: Department of the Army: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Secretary of the Army has taken several steps toward addressing this recommendation. For example, the Army published the Portfolio and Asset Management Handbook creating a multi-tiered assessment approach of performance metrics to measure the health of each privatized home through inspection, assessment, satisfaction, and feedback. The Army and the private housing partners revised the Incentive Fee Performance Management Plan, placing increased emphasis on resident satisfaction and work order/maintenance management. The Army also put Commanders in charge, ensuring Army leadership at every Army installation is tracking housing quality and safety. In late 2020, the Army plans to review and evaluate these actions and make a determination by 31 Jan 2021 if any changes or revisions are needed to best implement the recommendation. As such, we will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Air Force should take steps, in collaboration with the Air Force's private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 3)

Agency: Department of Defense: Department of the Air Force: Office of the Secretary of the Air Force
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Air Force is engaging in several steps to address this recommendation. Specifically, in March 2020, the Air Force tasked each of the Military Housing Offices to inspect all move-in, move-out, and change of occupancy maintenance events and all emergency, urgent, and life, health, and safety work orders, which is outlined in Air Force guidance. The Air Force is also engaging in several ongoing actions. In response to a memo to the military departments to provide consistency of performance incentive fees, the Air Force was negotiating with the privatized housing project owners to update performance incentive fee metrics in accordance with ASD directed categories and weightings. As of August 2020, agreements had been finalized with 2 partners and work was ongoing with the remaining partners. In addition, the Air Force was working with the project owners to deploy Satisfacts, a survey tool to independently measure resident satisfaction with projects' work order performance, across all Air Force projects with an expected completion by December 2020. We will continue to monitor the status of these recommendations.

Recommendation: The Secretary of the Navy should take steps, in collaboration with the Navy and Marine Corps' private housing partners, to review the indicators underlying the privatized housing project performance metrics to ensure they provide an accurate reflection of the condition and quality of the homes. (Recommendation 4)

Agency: Department of Defense: Department of the Navy: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Navy and Marine Corps are engaging in several steps to address this recommendation. Specifically, the Navy and Marine Corps have developed a centralized electronic data warehouse, which receives data from privatized housing partner maintenance systems to display work order and survey performance dashboards. By February 2021, the Navy expects to complete the development of metrics displayed by the data warehouse to include key service call performance metrics and resident feedback data. The Navy and Marine Corps are also developing a web-based monitoring matrix tool housing officials can use to evaluate the performance of privatized housing partners. The tool is intended to provide improved tracking capabilities and improved accessibility to information, thus providing more consistent oversight and improved advocacy service members and their families. The Navy is also working to hire 247 additional Navy and Marine Corps housing staff to review and analyze private partner provided recurring maintenance and customer satisfaction reports in an effort to strengthen oversight and monitoring, with an estimated completion of September 2020. Moving forward, we will continue to monitor the status of these and other efforts.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments and private housing partners, establish minimum data requirements and consistent terminology and practices for work order data collection for comparability across installations and projects and to track trends over time. (Recommendation 5)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: e Department of Defense (DOD) partially concurred with this recommendation. In its August 2020 response, DOD stated that the Assistant Secretary of Defense for Sustainment (ASD(S)), as the Chief Housing Officer, plans to issue a policy directing the military departments to establish, to the maximum extent practical, minimum data requirements and consistent terminology and practices for MHPI housing unit work order collection to aid in comparability across installations and projects, and for tracking trends over time. However, DOD noted that the department cannot mandate changes to existing MHPI project legal documents. DOD estimates that this effort will be completed by December 2021. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment require the military departments to establish a process to validate data collected by the private housing partners to better ensure the reliability and validity of work order data and to allow for more effective use of these data for monitoring and tracking purposes. (Recommendation 6)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)), as the Chief Housing Officer, issued guidance directing the military departments to exercise proper oversight to ensure Military Housing Privatization Initiative (MHPI) projects perform in accordance with legal agreements, to include due diligence in monitoring and auditing project maintenance records and other project performance data. The guidance also required military departments to review their entire portfolios of MHPI projects to ensure accurate and appropriate work order management processes. In response to the new guidance, DOD noted that the military departments put in place appropriate oversight measures and undertook the required reviews, though the investigations of project business practices were ongoing in some cases. As another step, the ASD(S) plans to issue guidance directing the military departments to establish a process to validate data collected by their respective MHPI Project Owners to better ensure the reliability and validity of work order data and to allow for more effective use of these data for monitoring and tracking purposes. DOD expects this to be completed by the end of September 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, develop a process for collecting and calculating resident satisfaction data from the military departments to ensure that the data are compiled and calculated in a standardized and accurate way. (Recommendation 7)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation based on the fact that the draft report listed the incorrect office as the source for addressing the deficiency, but subsequently changed its response to concur after the recommendation was directed to the appropriate office in the final report. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)) plans to issue guidance establishing a department-wide process for collecting and calculating resident satisfaction data to ensure that the data are compiled and calculated in a standardized and accurate way effective with the survey collection effort in Fiscal Year 2021. The department expects this effort to be completed by October 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of Defense should ensure the Assistant Secretary of Defense for Sustainment provides additional explanation of the data collected and reported in future reports to Congress, such as explaining the limitations of available survey data, how resident satisfaction was calculated, and reasons for any missing data, among other things. (Recommendation 8)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) partially concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment (ASD(S)) would provide additional explanation of the MHPI resident satisfaction data collected and reported in future annual Military Housing Privatization Initiative (MHPI) reports to Congress, effective with the annual report covering fiscal year 2019. DOD noted that the additional information will include, among other things, an explanation of the limitations of available survey data, how resident satisfaction was calculated, and reasons for any missing data. As of August 2020, the annual MHPI report covering fiscal year 2018 was in final coordination and the department noted that the report would addresses a vast majority, but not all, of the requirements identified in our recommendation. DOD noted that the additional information would be provided in the next annual MHPI report. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Army should develop and implement a plan to clearly and systematically communicate to residents the difference between the military housing office and the private partner. At a minimum, these plans should include the Army housing office's roles, responsibilities, locations, and contact information and should ensure that all residents are aware that they can directly contact Army housing office officials. (Recommendation 9)

Agency: Department of Defense: Department of the Army: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its response, DOD noted that the Army developed a "Plain Language" briefing as required by the 2020 National Defense Authorization Act that included the Army Housing Office's roles, responsibilities, location, and contact information at each privatized housing project site. DOD noted that the intent of the briefing was to ensure that all residents were aware of their ability to directly contact Army Housing Office and/or the Garrison Commanders. DOD stated that the briefing was disseminated to all of the Military Housing Offices, who are using it in newcomer briefings, and stated that the briefing would be provided to all current residents of privatized military housing, but that measure would not be tracked due to attrition. In addition, DOD noted that Headquarters, Department of the Army was tasking Army Materiel Command to develop a more detailed plan to communicate to residents the difference between the Army Housing Office and the private housing partner. The Army's intent is to not only capture residents upon their arrival at an installation, but making the services of the MHO known over the duration of a resident's time on at installation. We will continue to monitor the status of this recommendation.

Recommendation: The Secretary of the Navy should develop and implement a plan to clearly and systematically communicate to residents the difference between the military housing office and the private partner. At a minimum, these plans should include the Navy housing office's roles, responsibilities, locations, and contact information and should ensure that all residents are aware that they can directly contact Navy housing office officials. (Recommendation 11)

Agency: Department of Defense: Department of the Navy: Office of the Secretary
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Navy has taken various steps to address this recommendation, with additional steps planned. For example, the Navy has ensured that each installation has a specific issue resolution process description marketing flyer available, both in hard copy and on the public housing websites, with a reminder that residents can contact both the privatized housing property manager and the Navy housing office with any issues. Moreover, every housing unit has been provided with a refrigerator magnet reminding residents that they can and should contact the Navy housing office if they have any issues with their home. In addition, the Navy and Marine Corps have established a requirement to contact each privatized housing resident not later than 15 days after move-in and again 60 days after move-in to provide an opportunity to request assistance and remind them of available support. Moving forward, the Navy has an ongoing effort to require private housing companies to market the same messaging as the service issue resolution processes for the MHOs that they support, for consistent advocacy messaging to the tenants. The information will be added to PPV partner websites, printed material and resident handbooks. The Navy also plans to use its annual survey to tracks resident satisfaction and awareness of the Navy's issue resolution process, with expected completion by October 2020. In addition, the Marine Corps has identified a near-term initiative to procure name tags for all MHO employees to wear, identifying themselves as distinct and separate from privatized housing property management company, which will be standardized across all USMC installations. The Marine Corps also plans to develop a standard welcome aboard package to include magnets and other items with key point of contact information. The Marine Corps expects these efforts to be completed by the end of September 2020.

Recommendation: The Secretary of Defense should ensure that the Assistant Secretary of Defense for Sustainment, in collaboration with the military departments, assess the risks of proposed initiatives aimed at improving the privatized military housing program on the financial viability of the projects. (Recommendation 12)

Agency: Department of Defense: Office of the Secretary of Defense
Status: Open

Comments: The Department of Defense (DOD) concurred with this recommendation. In its August 2020 response, DOD noted that the Assistant Secretary of Defense for Sustainment, as the Chief Housing Officer, planned to issue a policy establishing the assessment of Military Housing Privatization Initiative (MHPI) project financial viability as part of quarterly program reviews as a long-term requirement. The department noted that the program review data would be augmented by input from the MHPI companies, who are assessing the likely impact of proposed initiatives in conjunction with their third party lenders. The department expected this effort to be completed by December 2020. We will continue to monitor the status of this recommendation.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should integrate the TEPSLF request into the PSLF application, for example, by including a checkbox on the PSLF application, to provide borrowers a more seamless way to request TEPSLF consideration. (Recommendation 1)

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education agreed with this recommendation. To make the TEPSLF loan forgiveness process easier for borrowers, Education stated that it will integrate the TEPSLF request into the PSLF application as part of the improvements planned for the PSLF application under its new online interface for student borrowers. On April 15, 2020, Education published a notice in the Federal Register, seeking comments on its plans to consolidate the forms that borrowers must complete if they want to request either PSLF or TEPSLF loan forgiveness, so that borrowers would only need to submit a single form to obtain public service loan forgiveness. In June 2020, Education reported that its consolidated form to request PSLF or TESPLF loan forgiveness is in the final stages of the Office of Management and Budget clearance process, and they expect it to be finalized by October 2021. This consolidated form should provide borrowers a more seamless way to request public service loan forgiveness for whichever program they are eligible for. We will update the status of this recommendation once this consolidated loan forgiveness form is in place and borrowers are able to use it.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should provide certain borrowers, for example, those who are denied TEPSLF for not having 120 qualifying payments, with more information about options available to contest TEPSLF decisions on the TEPSLF website and in their denial letters. (Recommendation 2)

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education agreed with this recommendation. In March 2020, Education reported that it will add language to the TEPSLF website to provide borrowers with information on available options for contesting TEPSLF decisions. With respect to including this information in denial letters, Education noted that it is creating a new student loan infrastructure (Next Gen) and that it is not worth the time and resources to update the denial letters in the old system. However, Education reported that it will incorporate this information in denial letters created in the new Next Gen infrastructure, which is expected to be in place in October 2021. We will consider closing this recommendation when Education provides documentation that it has included information about options available to contest TEPSLF decisions on the TEPSLF website and in denial letters, as recommended.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should include TEPSLF information in its PSLF Online Help Tool. (Recommendation 4)

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education agreed with this recommendation and stated that it will include TEPSLF information in the PSLF Help Tool. In March 2020, Education noted that it is creating a new student loan infrastructure (Next Gen) and that it is not worth the time and resources to update the PLSF Online Help tool with TEPSLF information under the old system. However, Education reported that it will respond to this recommendation when the new Next Gen infrastructure is in place, which is expected to be in place in October 2021. We will consider closing this recommendation when Education provides documentation that it has included TEPSLF information in its PSLF Online Help Tool.

Recommendation: The Chief Operating Officer of Federal Student Aid should obtain data in order to verify income information for borrowers reporting zero income on IDR applications. For example, Education could pursue access to federal data sources or obtain access to an appropriate private data source. (Recommendation 1)

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education generally agreed with this recommendation. Education stated that the President's fiscal year 2020 budget request includes a proposal that Congress pass legislation allowing the IRS to disclose tax return information directly to the department for the purpose of administering certain federal student financial aid programs. According to the agency, such legislation, if enacted, would allow borrowers to more easily certify their income on an annual basis to maintain enrollment in IDR plans, and allow the department to use the information to mitigate improper payments to borrowers as a result of misreported income data. Section 3 of the Fostering Undergraduate Talent by Unlocking Resources for Education Act (FUTURE Act), enacted in December 2019, provided Education with statutory authority to access certain Internal Revenue Service data for the purpose of determining eligibility for IDR plans, among other things (Public Law 116-91). As of August 2020, Education had begun planning for the implementation of the legislation. The Congressional Budget Office estimated that use of this authority to verify eligibility for IDR plans could result in over $2 billion in savings for 2020-2029.

Recommendation: The Chief Operating Officer of Federal Student Aid should implement data analytic practices, such as data matching, and follow-up procedures to review and verify that borrowers reporting zero income on IDR applications do not have sources of taxable income at the time of their application. (Recommendation 2)

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education agreed with this recommendation, and from January to March 2020 initiated a pilot program with three of its loan servicers to conduct additional verification of income or family size information on IDR plan applications for a random sample of borrowers each month. When initiated, the pilot focused on IDR borrowers who self-certified that they had no income or who reported certain family sizes. According to Education, selected borrowers would be asked to provide documentation to their servicers to support the income or family size reported on their IDR application. In the event errors were identified, servicers would work with the borrowers to update their applications. If these reviews resulted in changes to a borrower's monthly payment amount, the borrower would be expected to begin paying the new amount within the next 60 days. According to Education, as of the end of March 2020 when the pilot was put on hold, participating servicers selected 48,855 borrowers for verification. The verification pilot was put on hold as it implemented student loan relief for borrowers under the CARES Act in response to the COVID-19 global pandemic (Public Law 116-136). Specifically, on March 27, 2020, the CARES Act was enacted, which suspended student loan payments due, interest accrual, and involuntary collections for Direct and Federal Family Education Loans held by Education through September 30, 2020. According to Education, the Department suspended all IDR recertifications during this period. On August 8, 2020, the President issued a presidential memorandum directing the Secretary of Education to extend this relief to borrowers through December 31, 2020. Education reported that it will weigh options for resuming the pilot against other critical priorities and available resources, noting that its long-term strategy is to fully implement the authorities granted under the FUTURE Act, which provides Education with statutory authority to access certain Internal Revenue Service data for the purpose of determining eligibility for IDR plans, among other things (Public Law 116-91). GAO will continue to monitor Education's actions in this area, and will close the recommendation when Education provides documentation that it has implemented data analytic practices and follow-up procedures to review and verify that borrowers reporting zero income on IDR applications do not have sources of taxable income at the time of their application.

Recommendation: The Chief Operating Officer of Federal Student Aid should implement data analytic practices, such as data mining, and follow-up procedures to review and verify family size entries in IDR borrower applications. For example, Education could review and verify all borrower reports of family size or a subset identified as being most susceptible to fraud or error. (Recommendation 3)

Agency: Department of Education: Office of Federal Student Aid
Status: Open

Comments: Education agreed with this recommendation, and from January to March 2020 established a pilot program with three of its loan servicers to conduct additional verification of income or family size information on IDR plan applications for a random sample of borrowers each month. When initiated, the pilot focused on IDR borrowers who self-certified that they had no income or who reported certain family sizes. According to Education, selected borrowers would be asked to provide documentation to their servicers to support the income or family size reported on their IDR application. Education noted that under the pilot, loan servicers were required to request additional information from borrowers to verify family sizes greater than five; specifically, a statement listing each family member residing with the borrower and for whom the borrower pays at least 51 percent of the support. In the event errors were identified, servicers would work with the borrowers to update their applications. If these reviews resulted in changes to a borrower's monthly payment amount, the borrower would be expected to begin paying the new amount within the next 60 days. According to Education, as of the end of March 2020 when the pilot was put on hold, participating servicers selected 48,855 borrowers for verification. The verification pilot was put on hold as Education implemented student loan relief for borrowers under the CARES Act in response to the COVID-19 global pandemic (Public Law 116-136). Specifically, on March 27, 2020, the CARES Act was enacted, which suspended student loan payments due, interest accrual, and involuntary collections for Direct and Federal Family Education Loans held by Education through September 30, 2020. According to Education, the Department suspended all IDR recertifications during this period. On August 8, 2020, the President issued a presidential memorandum directing the Secretary of Education to extend this relief to borrowers through December 31, 2020. Education reported that it will weigh options for resuming the pilot against other critical priorities and available resources, noting that its long-term strategy is to fully implement the authorities granted under the FUTURE Act, which provides Education with statutory authority to access certain Internal Revenue Service data for the purpose of determining eligibility for IDR plans, among other things (Public Law 116-91). GAO will continue to monitor Education's actions in this area, and will close the recommendation when Education provides documentation that it has implemented data analytic practices and follow-up procedures to review and verify family size entries in IDR borrower applications.

Recommendation: EXIM's chief operating officer should direct EXIM's Credit Review and Compliance Division to assess and document the practicality of incorporating into its preauthorization Character, Reputational, and Transaction Integrity (CRTI) reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants, and, if practical, implement relevant approaches—such as manual searches or batch matching. (Recommendation 1)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In June 2020, we met with EXIM to discuss its efforts to assess the practicality of incorporating into its preauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants. Prior to the discussion, EXIM provided some information on its efforts. As part of the June 2020 discussion, we requested that EXIM provide additional information on its assessment. EXIM agreed to do so. We will provide an update on the status of this recommendation when we confirm what actions EXIM has taken in response to this recommendation.

Recommendation: EXIM's chief operating officer should direct EXIM's Credit Review and Compliance Division to assess and document the practicality of incorporating into its postauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants and participants, and, if practical, implement relevant approaches—such as manual searches or batch matching. (Recommendation 2)

Agency: Export-Import Bank of the United States
Status: Open

Comments: In June 2020, we met with EXIM to discuss its efforts to assess the practicality of incorporating into its postauthorization CRTI reviews searches of data elements in SAM that indicate delinquent federal debts owed by applicants and participants. Prior to the discussion, EXIM provided some information on its efforts. As part of the June 2020 discussion, we requested that EXIM provide additional information on its assessment. EXIM agreed to do so. We will provide an update on the status of this recommendation when we confirm what actions EXIM has taken in response to this recommendation.

Recommendation: The Director of OMB should develop guidance on how agencies test to identify improper payments, such as using a risk-based approach to help ensure that key risks of improper payments, such as eligibility, are addressed through testing processes. (Recommendation 1)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Priority recommendation

Comments: OMB partially concurred with this recommendation. On July 31, 2019, we met with the Office of Management and Budget (OMB). At the meeting, OMB officials indicated that OMB's position has not changed since the issuance of the GAO report and what OMB had already communicated to GAO at the exit conference. Specifically, OMB stated that it should not have to develop more specific guidance as each program and activity has its own risks. Instead, inspectors general are better equipped and positioned to review the sampling and estimation plans as part of their annual Improper Payments Elimination and Recovery Act of 2010 compliance audits and that agencies, their statisticians, and inspectors general should work out the best testing procedures for their agencies. We continue to believe that OMB could provide suggestions during OMB's annual town meeting related to improper payments for areas that inspectors general may consider. Further, although we agree that programs and activities may face different risks of improper payment, we continue to believe that guidance from OMB on how agencies test to identify improper payments, such as using a risk-based approach, could help ensure that agencies address the specific risks they identify when developing improper payment estimates. In February 2020, OMB informed us that it had no status updates to provide at this time. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Director of OMB should develop guidance clarifying the appropriate treatment of nonresponse cases during improper payment testing. (Recommendation 2)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Priority recommendation

Comments: OMB concurred with this recommendation. On July 31, 2019, we met with the Office of Management and Budget (OMB). At the meeting, OMB officials indicated that OMB's position has not changed since the issuance of the GAO report and what OMB had already communicated to GAO at the exit conference. At the meeting, OMB officials stated that OMB will "consider" updating guidance in OMB Circular A-123, Appendix C, to direct agencies to treat nonresponse cases such as improper payments and to include a new category for tracking such cases but only after assessing the impact such guidance would have on the agencies testing and reporting of improper payments. OMB has not taken action to develop this guidance. In February 2020, OMB informed us that it had no status updates to provide at this time. We will continue to monitor agency's actions to address this recommendation.

Recommendation: The Director of OPM should assess the processes to estimate Retirement improper payments to determine whether they effectively address key risks of improper payments--including eligibility and whether older claims face different risks of improper payments than new claims--and take steps to update the processes to incorporate key risks that are not currently addressed. (Recommendation 4)

Agency: Office of Personnel Management
Status: Open

Comments: The Office of Personnel Management (OPM) partially concurred with this recommendation. Prior to 2006, the improper payment estimate sampling methodology used by OPM included both new and old adjudicated claims. After analyzing several years of data using this methodology, OPM found that including older claims in the sample could result in claimant's records being sampled multiple times. In addition, OPM also found that the variance in the number of errors detected in new claims versus old claims was very low. OPM also looked at the resources used in performing the audit of old and new claims and based on these factors, management determined that it was not an efficient use of resources to include both old and new claims in the review. The methodology was updated to make the process more efficient. By using new claims only, OPM was able to provide feedback to program managers more timely. As a result, management can address issues negatively impacting the improper payment rate and prevent improper payments promptly. OPM agrees with the intent of our recommendation; however, OPM does not agree with our recommendation regarding a risk assessment on eligibility. Eligibility is determined before annuity/survivor benefits are fully adjudicated. As part of its correction plan, OPM stated that it will conduct an audit of older claims to determine if there are different risks to new claims. In February 2020, OPM indicated that it is currently in the process of pulling/gathering the cases that should be in the universe of this audit. OPM plans to complete the corrective action by end of 4th quarter of fiscal year 2020. We will continue to monitor the agency's actions to address this recommendation.

Recommendation: Congress should consider strengthening schools' accountability for student loan defaults, for example, by 1) revising the cohort default rate (CDR) calculation to account for the effect of borrowers spending long periods of time in forbearance during the 3-year CDR period, 2) specifying additional accountability measures to complement the CDR, for example, a repayment rate, or 3) replacing the CDR with a different accountability measure. (Matter 1)

Agency: Congress
Status: Open

Comments: In the 115th Congress, provisions were included in the Transparency in Student Loan Consultation Act of 2018 (H.R. 6473) to require schools and their default management consultants to provide borrowers with information that is accurate and complete. We will continue to monitor congressional action.

Recommendation: Congress should consider requiring that schools and default management consultants that choose to contact borrowers about their federal student loan repayment and postponement options after they leave school present them with accurate and complete information. (Matter 2)

Agency: Congress
Status: Open

Comments: In the 116th Congress, legislation has been introduced to revise the cohort default rate calculation. The College Affordability Act (H.R. 4674), Acting on the Annual Duplication Report Act of 2019 (S. 2175), and Accountability in Student Loan Data Act (H.R. 4662) include provisions that, if enacted, would revise the cohort default rate calculation to change how borrowers who spend long periods in forbearance are accounted for in the calculation. We will continue to monitor congressional action.

Recommendation: The Secretary of Education should assess and improve, as necessary, the quality of data and methods used to forecast borrower incomes, and revise the forecasting method to account for inflation in estimates.

Agency: Department of Education
Status: Open
Priority recommendation

Comments: The Department of Education agreed to assess and improve its borrower income data, and adjust incomes for inflation. In model documentation prepared in advance of the agency's fiscal year 2017 financial statements, Education acknowledged problems in the estimated borrower income data it used to estimate income-driven repayment (IDR) plan costs, and said it was working to obtain access to actual borrower income data for use in its cost estimates. Education implemented part of this recommendation by adjusting borrower incomes for inflation, which caused a downward re-estimate of IDR plan costs totaling $17.1 billion. GAO will monitor Education's progress in implementing the other part of the recommendation.

Recommendation: 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.

Agency: Department of Education
Status: Open

Comments: 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. However, Education's current student loan model still does not allow for estimating the effects of repayment plan switching. In the interim, Education updated its repayment plan selection assumption to more accurately reflect recent trends in income-driven repayment plan participation. GAO will monitor the progress of Education's efforts to implement the planned model redesign with the capability to incorporate plan switching behavior.

Recommendation: To help address Education's strategic goal of providing superior customer service to borrowers, and to strengthen oversight of the Direct Loan program, the Secretary of Education should develop a minimum standard that specifies core call center operating hours to provide borrowers, including those on the West Coast, with improved access to servicers.

Agency: Department of Education
Status: Open

Comments: The Department of Education agreed with this recommendation and said it planned to establish core hours in the requirements for servicers to help borrowers access live customer service representatives. In May 2018, an Education official told us that the department is redesigning its loan servicing system, and one of the goals of this effort is to ensure a consistent experience for all borrowers. The official said all borrowers will have access to the same call center number and other customer service functions, but the specifics have not yet been decided. As Education completes its loan servicing redesign, it should ensure that borrowers have improved access to customer service representatives to aid them in managing their loans. In February 2020, Education officials said implementation of this recommendation was still in progress. The agency estimates a completion date of October 30, 2021, when the new system is expected to be fully operational.

Recommendation: To help address Education's strategic goal of providing superior customer service to borrowers, and to strengthen oversight of the Direct Loan program, the Secretary of Education should ensure the new unified borrower complaint tracking system includes comprehensive and comparable information on the nature and status of borrower complaints made to both Education and servicers, to allow Education to track trends and better manage the program to effectively meet borrower needs.

Agency: Department of Education
Status: Open

Comments: In May 2018, the Department of Education reported that as part of its redesigned loan servicing system, it plans to develop a single platform that maintains a record of all customer service interactions, including any complaints that borrowers submit. While the details have yet to be determined, the goal is to create a unified process consistent with the intent of this recommendation, according to Education. Education must ensure that it collects comprehensive and comparable information on borrower complaints in order to ensure the program meets borrower needs. In February 2020, Education officials said implementation of this recommendation was still in progress. The agency estimates completion in October 2021, when the new system is expected to be fully operational.

Recommendation: To help address Education's strategic goal of providing superior customer service to borrowers, and to strengthen oversight of the Direct Loan program, the Secretary of Education should evaluate and make needed adjustments to Direct Loan servicer performance metrics and compensation to improve assessment, including using baseline data, and alignment with Federal Student Aid's strategic goals aimed at superior customer service and program integrity, and to ensure that the assignment of new loans to servicers takes program compliance into account.

Agency: Department of Education
Status: Open

Comments: The Department of Education agreed with this recommendation and stated that it would evaluate existing and alternative performance metrics and compensation strategies as part of its process for procuring a new loan servicing solution. In February 2020, an Education official told us that Education's new loan servicing system would eventually address this recommendation. However, the official said the metrics that will be used to evaluate loan servicers have not yet been determined. Unless Education better aligns its servicer performance metrics, borrowers will continue to be at risk of experiencing errors and poor customer service. In October 2019, Education officials said implementation of this recommendation was still in progress, pending completion in October 2021, when the new system is expected to be fully operational.

Recommendation: To strengthen management of the Direct Loan Program and ensure good customer service for borrowers, the Secretary of Education should direct the Office of Federal Student Aid's Chief Operating Officer to review its methods of providing instructions and guidance to servicers, identifying areas to improve clarity and sufficiency, and ensure consistent delivery of instructions and guidance to ensure program integrity and improve service to borrowers. For example, the Department could consider implementing a detailed, common servicing manual for the Direct Loan program.

Agency: Department of Education
Status: Open
Priority recommendation

Comments: The Department of Education agreed with this recommendation and reviewed its process for providing guidance to servicers. It has issued a few clarifications to servicers to help with consistency and reported that it intends to incorporate this recommendation into its acquisition plan for a new loan servicing system. To fully implement this recommendation, the agency needs to demonstrate that the new Direct Loan servicing system will provide clear and consistent instructions and guidance to servicers to ensure program integrity and improve service to borrowers. As of February 2020, Education officials said implementation of this recommendation was still in progress, pending completion in October 2021. At that time, the agency expects the re-design of its student loan financial services environment, which will include additional guidance to servicers, to be fully operational.

Recommendation: To help ensure that Income-Based Repayment, Pay As You Earn, and Public Service Loan Forgiveness serve their intended beneficiaries to the greatest extent possible, the Secretary of Education should take steps to consistently and regularly notify all borrowers who have entered repayment of income-driven repayment plan options, including Income-Based Repayment and Pay As You Earn.

Agency: Department of Education
Status: Open

Comments: The Department of Education generally concurred with our recommendation, stating that it is committed to ensuring that federal student loan borrowers have the information they need to manage their debt, including details regarding income-driven repayment plans and loan forgiveness programs. However, Education stated that it is not clear that providing information on repayment options to all borrowers is the most efficient or effective way to achieve this goal. Beginning in 2015, Education directed its loan servicers to start sending detailed income-driven repayment information, such as projected monthly payment amounts and total amounts paid over the life of the loan under each plan, on a quarterly basis to all borrowers who are in school or in the 6-month grace period after leaving school. Education reported that in 2016 its loan servicers also began sending an email to borrowers in the fifth month of their grace period with information about applying for income-driven repayment plans and Public Service Loan Forgiveness. Education also reported that in December 2016 it began sending emails about the Revised Pay As You Earn plan directly to certain groups of borrowers, including those who expressed interest in income-driven plans during exit counseling, were less than 227 days delinquent, or had Federal Family Education Loans. In August 2018, Education indicated that borrowers are notified about income-driven repayment through information posted on websites; billing statements and forbearance and deferment notices; and during various points of delinquency. We acknowledged these efforts in our 2015 report and discussed their limitations. For example, while Education provides detailed information about income-driven repayment on its website, borrowers must actively seek out this information. In addition, we reviewed recent sample billing statements for each of the Department's loan servicers and found the information on income-driven repayment limited to the names of the specific repayment plans. The statements did not include information about how the plans work or eligibility requirements. Additionally, Education reported that in June 2019 it began sending emails about income-driven repayment plans and Public Service Loan Forgiveness directly to certain groups of borrowers, including those in the Standard repayment plan who were 31 to 270 days delinquent or in a discretionary forbearance. While a positive step, these emails were only sent to select groups of borrowers. We maintain that borrowers need sufficient and timely information to ensure they are aware of and can make informed decisions about repayment options. To fully implement this recommendation, Education should consistently and regularly notify all borrowers who have entered repayment about income-driven repayment options, including borrowers who have not been contacted by Education through its targeted notification efforts.