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 Assistant Secretary for Postsecondary Education should correctly calculate its CCAMPIS program persistence rate and cost per persisting student measures. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation as it believes the currently reported persistence data are sufficiently accurate to support effective program management and oversight. In February 2020, Education noted that it was reviewing the concerns raised by GAO and taking action to address confirmed errors in its persistence calculations. Specifically, Education said it would correct a formula error in its spreadsheet and include students who transferred to another school as persisting and planned to publish corrected data. Further, it said that it was exploring the feasibility of developing a cohort model for its persistence rate measure. We appreciate the steps Education is taking to ensure that it is correctly calculating its program persistence measures. To close this recommendation, Education should provide its corrected calculations, as well as any publication with corrected persistence measures, to GAO to review and confirm that Education has corrected all of the errors we identified.

Recommendation: The Assistant Secretary for Postsecondary Education should either collect the CCAMPIS participant enrollment data needed to calculate a standard 3-year graduation rate or accurately define and calculate a different college completion measure. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: As of February 2020, Education stated that it continues to disagree with this recommendation, noting that more analysis is needed to determine whether it is appropriate to develop a more rigorous graduation rate measure for the CCAMPIS program. As we stated in our report, we recognize that collecting the enrollment data needed to calculate the standard graduation rate could place a burden on grantee schools. Our recommendation included the option to define a different college completion measure and calculate it correctly. Education reported that it will redefine its current graduation rate to be a different college completion measure and the agency will clarify the description of this metric in its information on CCAMPIS graduation rates. While the new graduation rate definition proposed by Education responds to this recommendation, Education's formula does not accurately calculate this redefined graduation rate measure. To close this recommendation, Education should correct the formula for its revised graduation rate measure and provide the updated formula and data to confirm that its calculations are accurate.

Recommendation: The Chief Operating Officer of Federal Student Aid should encourage schools—through appropriate means, such as the Federal Student Aid Handbook—to inform students via school websites about the availability of the dependent care allowance and how to request the allowance. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: While Education agreed with the spirit of this recommendation, it disagreed with the recommendation itself due to concerns that an increased emphasis on the availability of the dependent care allowance could lead to additional borrowing that might not be appropriate for all students based on their financial circumstances. To respond to the recommendation, Education told us in February 2020 that it has added a note to the 2019-2020 FSA Handbook that, when counseling students, schools should make clear the availability of the allowance and how to request it. Adding this language to the handbook is certainly helpful, but does not fully implement GAO's recommendation. Encouraging schools to provide this information to students who proactively contact a school's financial aid office to discuss their finances will likely make this information available to a relatively small number of students; however, it does nothing to make this information more broadly available to all students who may benefit from it. We are not recommending that schools should encourage all student parents to borrow more to pay for child care. Instead, we recommend that Education encourage schools to make students aware of this potential option-which federal law makes available to students-via school websites to allow them to make informed financial decisions based on their personal circumstances. We will close this recommendation when Education takes additional actions to encourage schools to make this information more broadly available to students on their websites.

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: The Secretary of Education should complete its evaluation of Second Chance Pell in order to report on the pilot's findings and conclusions reached.

Agency: Department of Education
Status: Open

Comments: The Department of Education concurred with our recommendation to complete its evaluation of the Second Chance Pell pilot. As of August 2020, the pilot was still underway. We will continue to follow up with the Department to ensure an evaluation is completed.

Recommendation: The Administrator of FNS should make information on their website regarding student SNAP eligibility requirements easier to understand and more accessible, as a resource for colleges and state SNAP agencies. (Recommendation 1)

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

Comments: FNS partially concurred with this recommendation and in September 2019, the agency stated that it will take actions to address the recommendation by February 2020. First, FNS said it would review the information regarding student SNAP eligibility on its website and, where possible, revise this information to reduce legal and technical language. FNS also stated it will evaluate the placement of student SNAP eligibility content on its website and assess alternatives to increase accessibility of this information for colleges and state SNAP agencies. We continue to believe that changes to FNS's existing information are needed to improve the clarity and accessibility of information about SNAP student eligibility requirements on FNS's website. Once we receive additional information about improvements to FNS's website, we will update the status of this recommendation.

Recommendation: The Administrator of FNS should coordinate with its regional offices to collect and review information about existing SNAP flexibilities and examples of approaches state SNAP agencies are taking to assist eligible college students to access SNAP benefits, and share such information with state SNAP agencies. (Recommendation 2)

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

Comments: FNS partially concurred with this recommendation and, in September 2019, stated that it is currently evaluating strategies to address this recommendation utilizing existing resources. Specifically, FNS stated that by August 2020, it will assess suitable mechanisms (e.g., policy memos, webinars, conferences) for information sharing with state SNAP agencies and disseminate that material as resources allow. We continue to believe that FNS needs to work with its regional offices to identify and share additional information about state approaches to assist eligible college students with access to SNAP benefits. Once we receive additional information about FNS's information sharing activities, we will update the status of this recommendation.

Recommendation: The Secretary of Education should enroll loan servicers in FSA's continuous monitoring program and, in the interim, require these entities to report the results of security controls testing at an FSA-defined frequency. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: FSA concurred with this recommendation and the agency stated that loan servicers are scheduled to be enrolled in its ongoing security authorization program beginning in fiscal year 2019. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: 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)

Agency: Department of Education
Status: Open

Comments: FSA stated that it concurred with this recommendation, but the actions it said it planned to take would not fully address it. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Education should modify FSA's agreements with guaranty agencies to specify a required baseline of security controls based on the impact level of the information shared with these agencies, as determined by FSA. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: FSA concurred with this recommendation and described planned actions to address it. In November 2019, FSA officials told us that this recommendation has a pending date of 5/31/2020 for completion When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: 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)

Agency: Department of Education
Status: Open

Comments: FSA partially concurred with this recommendation and described actions it planned to take in response. However, we believe the entire recommendation is still warranted. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: 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)

Agency: Department of Education
Status: Open

Comments: FSA stated that it partially agreed with this recommendation; however, if effectively implemented, the planned actions it described would address this recommendation. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: 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)

Agency: Department of Education
Status: Open

Comments: FSA did not concur with this recommendation. However, we believe it is still warranted. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should develop a timeline for issuing a comprehensive guidance and instructions document for PSLF servicing. This could involve developing a new servicing manual or expanding upon the PSLF servicer's existing processing handbook. (Recommendation 1)

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

Comments: Education agreed with this recommendation and reported in September 2019 that it was continuing its efforts to improve and streamline guidance for the PSLF servicer. While Education said it is working on developing its comprehensive PSLF servicing manual, it does not yet have a timeline for how it will complete this manual and has indicated that it intends to deliver completed chapters on an iterative basis based on servicing priorities. To implement this recommendation, Education needs to develop a timeline for completing the PSLF servicing manual and demonstrate that it will provide comprehensive guidance and instructions for PSLF servicing.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should provide additional information to the PSLF servicer and borrowers to enhance their ability to determine which employers qualify for PSLF. This could involve Education developing an authoritative list of qualifying employers or improving the PSLF servicer's existing database, and making this information available to borrowers. (Recommendation 2)

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

Comments: Education agreed with this recommendation, and in December 2018, the agency released a new online tool to help borrowers better understand the PSLF eligibility requirements. Education has indicated that this tool could eventually be expanded to incorporate additional qualifying employer information. Education has also indicated that implementation of the recommendation is tied to the rollout of a new loan servicing system, which it expects to be fully operational in October 2021. To implement this recommendation, Education needs to demonstrate that it is providing information that will help the PSLF servicer and borrowers determine whether employment with specific employers will qualify borrowers for the program.

Recommendation: The Chief Operating Officer of the Office of Federal Student Aid should ensure that borrowers receive sufficiently detailed information from the PSLF servicer to be able to identify any errors in the servicer's counts of qualifying payments, including information on whether or not each payment qualified toward forgiveness. (Recommendation 4)

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

Comments: Education agreed with this recommendation, and in June 2020, reported that it is reviewing communications from the PSLF servicer to ensure that borrowers receive sufficiently detailed information regarding payment counts and payment history. Education also indicated that implementation of the recommendation is tied to the rollout of a new loan servicing system, which it expects to be fully operational in October 2021. We will close the recommendation once Education provides documentation of the changes in communications from the PSLF servicer that demonstrate borrowers are receiving sufficiently detailed information regarding payment counts and payment history.

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 direct the Chief Operating Officer of FSA to establish and document a procedure for the destruction of records contained in electronic systems in accordance with approved disposition schedules. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: As of August 2019, FSA stated they have addressed the recommendation, but it is still undergoing an internal review. Once we receive documentation, we will determine if it addresses the recommendation.

Recommendation: The Secretary of Education should direct the Chief Operating Officer of FSA to ensure staff receive records management training annually. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: As of August 2019, FSA stated they have addressed the recommendation, but it is still undergoing an internal review. Once we receive documentation, we will determine if it addresses the recommendation.

Recommendation: The Secretary of Education should direct the Chief Operating Officer of FSA to conduct the triennial assessment of the FSA records management program. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: As of August 2019, FSA stated they have addressed the recommendation, but it is still undergoing an internal review. Once we receive documentation, we will determine if it addresses the recommendation.

Recommendation: The Secretary of Education should direct the Chief Operating Officer of FSA to ensure that privacy impact assessments address all required elements. (Recommendation 4)

Agency: Department of Education
Status: Open

Comments: As of August 2019, FSA stated they have addressed the recommendation, but it is still undergoing an internal review. Once we receive documentation, we will determine if it addresses the recommendation.

Recommendation: The Secretary of Education should direct the Chief Operating Officer of FSA to ensure that information security-related policies and procedures are reviewed at least annually, in accordance with FSA policy; updated as needed; and approved by security officials. (Recommendation 5)

Agency: Department of Education
Status: Open

Comments: As of August 2019, FSA stated they have addressed the recommendation, but it is still undergoing an internal review. Once we receive documentation, we will determine if it addresses the recommendation.

Recommendation: The Secretary of Education should update its regulation to include protections of personal information as an element of a school's ability to demonstrate its administrative capability. (Recommendation 7)

Agency: Department of Education
Status: Open

Comments: As of August 2019, FSA stated they have addressed the recommendation, but it is still undergoing an internal review. Once we receive documentation, we will determine if it addresses the recommendation.

Recommendation: To improve oversight of school finances and provide better information to schools and the public about its monitoring efforts, the Chief Operating Officer of the Office of Federal Student Aid should update the composite score formula to better measure schools' financial conditions and capture financial risks.

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

Comments: In September 2019, Education published updated regulations related to the financial responsibility composite score that include steps to address some of the limitations identified in our report. For instance, these regulations incorporate changes to better align the composite score calculations with recently updated accounting standards related to leases. In additional, these regulatory changes are designed to curb the ability of schools to manipulate their composite scores by clarifying what is considered "long-term debt" and requiring schools to disclose in their financial statements the terms of the debt and certify that the funds were used for capitalized assets rather than to fund operations. However, these regulatory updates do not fully address the current limitations of the composite score formula. For example, they do not reflect several other changes in accounting standards identified in our report or incorporate new financial metrics that would provide a broader indication of schools' financial health, such as liquidity, historical trend analysis, or future projections. Education has stated that it intends to explore further updates to the composite score methodology in future regulatory actions, and we will continue to monitor these efforts.

Recommendation: To improve oversight of school finances and provide better information to schools and the public about its monitoring efforts, the Chief Operating Officer of the Office of Federal Student Aid should improve guidance to schools about how the financial composite score is calculated, for example, by updating current guidance to include explanations about common areas of confusion and misinterpretation for schools.

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

Comments: Education agreed with this recommendation and that additional general guidance to schools would be helpful. The department also stated that it will update the guidance in its Federal Student Aid Handbook and may provide answers and related guidance to some frequently asked questions on its website. As of October 2019, Education had not completed these actions.

Recommendation: To help improve students' access to information so that they can make well-informed transfer decisions, the Secretary of Education should require schools to (1) disclose the list of schools with which they have articulation agreements online if the school has a website, and (2) clearly inform students, on the school's website if it has one, when no articulation agreements on credit transfer are in place. If the department determines that it does not have the authority to require this, it should nonetheless encourage schools to take these actions (through guidance or other means).

Agency: Department of Education
Status: Open

Comments: As of March 2020, Education continues to disagree with this recommendation, noting that it already requires schools to disclose a list of other schools with which they have established articulation agreements. However, we believe that posting this information online would make it more accessible to prospective students compared to publications located physically on a school's campus, particularly for those who live far away from the school. Education also noted that students should contact specific schools to obtain accurate and updated transfer information. However, we found that not all schools listed transfer-specific contacts on their websites. In addition, Education cautioned that placing special emphasis on articulation agreements could mislead students because the agreements - or lack thereof - do not fully reflect the transferability of credits However, we found that a majority of schools already disclose a list of partner schools on their websites. We believe that posting a list of partner schools online would complement credit transfer policies, which schools are already required to post online. Given that the purpose of required consumer disclosures on articulation agreements is to inform students, we continue to believe that posting this information online would make it more accessible to prospective students and their families while enhancing students' understanding of their transfer options.

Recommendation: To help ensure quality information is conveyed to servicemembers about how the Servicemembers Civil Relief Act (SCRA) interest rate cap applies to student loans, the Secretary of Defense should direct the secretaries of each service branch, and work with other secretaries as appropriate, to ensure that all information about the SCRA interest rate cap for student loans is accurate when provided to servicemembers and to those who work with servicemembers to help them obtain SCRA benefits, including information contained in outreach materials.

Agency: Department of Defense
Status: Open

Comments: The Department of Defense (DOD) disagreed with this recommendation believing it to be unnecessary because it is already providing accurate information. Specifically, DOD noted that the information provided in several documents GAO reviewed is accurately based on statute whereas Education's updated requirement to automatically apply the cap is based on policy that could change in the future. Moreover, the automated process applies only to federal and commercial FFEL student loans in contrast to other types of debt. DOD said that providing information based on statute rather than policy would cause less confusion and was a better approach than what we recommend. However, our report noted that Education formalized the automated process through federal regulations, effective July 2016, which legally require servicers to use this process for all federal and commercial FFEL loans. In addition, DOD said it was unable to verify whether DOD's Military OneSource website inaccurately states that the SCRA rate cap does not apply to commercial FFEL loans. However, our searches of the website still turned up this inaccuracy. DOD said it would look into a means of verifying website information but that in the meantime, it is satisfied that its training provides correct information. Given that Military OneSource is a key source of information for servicemembers and that some documents DOD provided state that the SCRA rate cap does not apply to student loans, we continue to believe that servicemembers are not always receiving accurate and up-to-date information. In August 2018, DOD reiterated that it continues to disagree with this recommendation based on the rationale above. DOD did not provide an update for 2020.

Recommendation: To ensure that all eligible servicemembers with student loans receive the SCRA interest rate cap, the Attorney General should direct the Department of Justice to consider modifying its proposed changes to SCRA to require use of the automatic eligibility check for private student loans.

Agency: Department of Justice: Office of the Attorney General
Status: Open

Comments: The Department of Justice (DOJ) stated that its current package of proposed legislative changes provides benefits to servicemembers with all kinds of loans, including private student loans. Rather than requiring servicemembers to submit written notice and a copy of military orders, they need only give oral or written notice of eligibility for the cap to their creditors. Creditors would then have to search the Department of Defense's records to verify the servicemembers' military service and apply the SCRA interest rate cap, when applicable. DOJ believes that these changes would significantly benefit all servicemembers with loans while providing a uniform standard for all types of creditors. The department added that it will consider its proposed changes to SCRA in future legislative proposals and plans to obtain feedback from stakeholders on how to improve SCRA's protections for servicemembers. However, as stated in our report, servicemembers with private student loans would still need to be aware of the rate cap in order to give notice, whether written or oral. Therefore, we encourage DOJ to consider updating its current proposal to require use of the automatic eligibility check by all student loan lenders and servicers. Not only would this ensure that servicemembers with private student loans receive a benefit for which they are eligible, but also that the interest rate cap is applied consistently across all types of student loans. DOJ did not provide an update for 2020.

Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: The Consumer Financial Protection Bureau (CFPB) stated that it is committed to working with the Department of Justice (DOJ) and federal financial regulators, when possible, to facilitate oversight of SCRA compliance and that it will support all relevant federal agencies in using their respective authorities to identify and address SCRA violations as efficiently and effectively as possible. While CFPB coordinates with DOJ and other federal regulators in general, there is still no single agency authorized to enforce SCRA compliance among nonbank private student loan lenders and servicers, and no entity is conducting onsite supervisory reviews of these lenders and servicers. In addition, while CFPB may refer complaints from servicemembers about the SCRA rate cap for private student loans to DOJ and other financial regulators, we believe this does not constitute routine, proactive oversight and also presumes servicemembers are aware of the SCRA rate cap. GAO will consider closing this recommendation when the bureau has provided evidence of actions it has taken to facilitate routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. CFPB did not provide an update for 2020.

Recommendation: To better ensure that servicemembers with private student loans benefit from the SCRA interest rate cap, the Director of the Consumer Financial Protection Bureau and the Attorney General of the Department of Justice should coordinate with each other, and with the four federal financial regulators, as appropriate, to determine the best way to ensure routine oversight of SCRA compliance for all nonbank private student loan lenders and servicers. If CFPB and DOJ determine that additional statutory authority is needed to facilitate such oversight, CFPB and DOJ should develop a legislative proposal for Congress.

Agency: Department of Justice: Office of the Attorney General
Status: Open

Comments: The Department of Justice (DOJ) believes that it is in full compliance with this recommendation and that the four federal financial regulators do not have statutory authority to examine nonbank private student loan lenders and servicers unaffiliated with a depository institution. DOJ stated that it already coordinates extensively with the Consumer Financial Protection Bureau (CFPB) and the financial regulators concerning SCRA compliance through such mechanisms as referrals from CFPB for any SCRA-related violations and access to its consumer complaint database, and regular meetings with CFPB, and that it will continue to be built upon these efforts. While these mechanisms are commendable, GAO believes they do not constitute exercising routine oversight of nonbank private student loan lenders and servicers who are not affiliated with a depository institution. We believe that additional interagency coordination, including working with CFPB to seek additional statutory authority, as needed, is necessary to ensure routine SCRA compliance. DOJ did not provide an update for 2020.

Recommendation: To help college financial aid administrators more effectively implement eligibility rules for unaccompanied homeless youth, the Secretary of Education should make available an optional worksheet or form that college financial aid administrators can voluntarily use to document unaccompanied homeless youth status or encourage the use of existing forms that are available.

Agency: Department of Education
Status: Open

Comments: Education agreed that it would be helpful to make forms developed by outside organizations knowledgeable about homelessness issues available for financial aid administrators to use for documenting the status of unaccompanied homeless youth. Education also said that it plans to highlight the availability of these forms and provide guidance at its annual conference and in updates to the Federal Student Aid Handbook. Education noted that it will not endorse the use of a specific form but that it will highlight forms that already exist that may be useful to financial aid administrators. In July 2020, Education reported that it planned to update the Federal Student Aid Handbook by the spring of 2021 to inform financial aid administrators about the availability of such forms that have been developed by outside entities. We will close this recommendation when Education provides GAO with the updated handbook.

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 enhance participation in and strengthen management of federal student aid programs for teachers, the Secretary of Education should direct Federal Student Aid's Chief Operating Officer to review the underlying cause of the known erroneous conversions to ensure steps Education has taken are sufficient to address the problem, and establish time frames for transferring the approximately 2,600 loan conversions currently with other loan servicers.

Agency: Department of Education
Status: Open

Comments: In its initial response, Education noted it has already taken steps to implement this recommendation, such as a comprehensive assessment to identify the causes of the conversions and the grants affected. After identifying the reasons, the agency worked with current grant servicer to ensure accuracy and make sure they understood program requirements. Regarding time frames for transferring the converted loans, in September 2017, Education provided documentation that the loan conversions were transferred to one servicer in December 2014. In 2018, Education provided additional information on the comprehensive assessment it conducted including the results, a work plan to address the erroneous conversions, and sample letters to recipients they deemed eligible for reconversion. Two changes, however, are currently underway which could affect past and future erroneous conversions. In December 2018, Education announced a process for grant recipients to request reconsideration if their grant was converted in error. Additionally, in 2018, Education's Negotiated Rulemaking Committee began discussing TEACH Grant requirements and ways to reduce and correct the inadvertent conversion of grants to loans, among other things. In April 2019, the subcommittee reached consensus on the proposed rule language, which allowed for erroneous loan conversions to be reversed under certain conditions. As of November 2019, Education has not yet published proposed rules for the TEACH Grant program, and it is unclear the extent to which all eligible recipients will be provided adequate opportunity to have the errors corrected. Given the substantial and ongoing changes to the program administration this recommendation remains open.

Recommendation: To strengthen Education's oversight of accreditors through the recognition review process, the Secretary of Education should draw upon accreditor data to determine whether accreditors are consistently applying and enforcing their standards to ensure that the education offered by schools is of sufficient quality. For example, Education could systematically use available information related to the frequency of accreditor sanctions or could do additional analyses, such as comparing accreditor sanction data with Education's information on student outcomes, to inform its recognition reviews.

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation, noting that it is committed to identifying ways to use data about and from accreditors in its oversight. As of December 2017, Education has taken steps to track the number of accreditor sanctions issued by each accrediting agency. Education previously noted that this information will then be used to focus their limited resources on those accrediting agencies with extremely low or high sanction rates, to strengthen its oversight of accreditors. In April 2018, Education reported that it tracks accreditor sanctions and is aware of the number of sanctions when conducting agency reviews. They found no correlation between the number of sanctions an accrediting agency levies against its accredited institutions and compliance or noncompliance with the Criteria for Recognition, so they noted that this is not a useful tool. However, we continue to believe that implementing the recommendation could help inform Education's reviews of accreditors and ultimately reduce potential risk to students and federal funds. For example, analyses of accreditor sanction data could help reveal patterns in individual accreditor behavior and overall trends in sanctions. In addition, as we noted in the report, Education could compare accreditor sanction data with outcome data for accreditors' member institutions. These analyses could help Education determine how to better use data in decision-making, which is a goal listed in their 2014 strategic plan (cited in the report), as well as help to identify potential risks the accreditors might face. To close this recommendation, Education should show that it uses sanction data to inform its discussions of accreditor recognition and oversight.

Recommendation: To provide federal policymakers information on the relative effectiveness of Title IV programs and higher education tax expenditures, the Secretary of Education should take advantage of opportunities presented by recent and anticipated substantive program changes to sponsor and conduct evaluative research into the effectiveness of Title IV programs and higher education tax expenditures at improving student outcomes.

Agency: Department of Education
Status: Open
Priority recommendation

Comments: As of January 2020, the Department of Education (Education) had made some progress toward sponsoring and conducting evaluative research into the effectiveness of Title IV programs and higher education tax expenditures at improving student outcomes, as GAO recommended and Education agreed to in 2012. For example, Education took several steps to make data on higher education programs more accessible for research purposes. Education officials also said they are convening stakeholder panels including both governmental and nongovernmental researchers to identify and prioritize key policy questions related to Title IV and higher education tax expenditures. Afterward, Education is planning to partner with governmental or external researchers--via contracts or grants--to investigate the issues identified as priorities. GAO believes that Education's leadership of such efforts would represent a meaningful commitment to make progress on addressing this recommendation. Given that Education has identified a critical research gap in the area of linking higher education financing to student outcomes, GAO continues to emphasize that Education should ensure that its efforts result in actively sponsoring or conducting evaluative research specific to federal programs and assistance that can be used in future policymaking. Making these data-sharing and research efforts a priority will help policymakers make fact-based decisions on the merits and value of various federal assistance efforts.