Recommendation: The Assistant Secretary for the Office for Civil Rights should revise its CRDC business rule to require that every school district reporting zeros, regardless of district size or numbers of students with disabilities, affirm the zeros are correct during the CRDC data submission process. (Recommendation 1)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and school districts that report very low numbers of incidents and set data-driven thresholds to detect such incidents. (Recommendation 2)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should develop and implement a CRDC business rule that targets schools and schools districts that report very high number of incidents and set data-driven thresholds to detect such incidents. (Recommendation 3)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should apply the CRDC business rule targeting illogical data at the school level to all schools, regardless of the number of incidents reported. (Recommendation 4)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should identify the factors that cause underreporting and misreporting of restraint and seclusion and take steps to help school districts overcome these issues. (Recommendation 5)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their efforts.

Recommendation: The Assistant Secretary for the Office for Civil Rights should further refine and clarify federal restraint and seclusion definitions and take steps to ensure that this information is conveyed to school districts. This could include providing common classroom scenarios that highlight the differences between a restraint and an escort, and a time out and a seclusion. (Recommendation 6)

Agency: Department of Education: Office for Civil Rights
Status: Open

Comments: Education agreed with this recommendation stated that it would determine the best means to implement it. We will monitor the progress of their 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 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: The D.C. Mayor should direct the Deputy Mayor for Education and the Office of the State Superintendent of Education to deepen collaboration with PCSB and other relevant stakeholders, such as charter school local educational agencies, to develop a coordinated plan to continue progress in reducing discipline rates and, as part of this process, make explicit their respective roles, responsibilities, and authorities with regard to discipline in D.C. charter schools. This plan could include developing additional guidance, training, or resources, consistent with the unique autonomy of charter schools.

Agency: District of Columbia: Executive Office of the Mayor
Status: Open

Comments: In 2017, D.C. education officials stated they planned to continue to deepening their collaboration to reduce disciple rates. In May 2018, the D.C. Council passed the Student Fair Access to School Amendment Act of 2018 which, among other things, directs the Office of the State Superintendent of Education to provide schools (including charters) with a variety of supports and assistance on discipline and trauma-informed programs. We have reached out to OSSE and the Deputy Mayor's office for updates on implementation of the law and any additional collaboration. As of June 2020, we are awaiting a response.

Recommendation: To preserve the balance between the importance of repaying federal student loan debt and protecting a minimum level of Social Security benefits put in place by the Debt Collection Improvement Act of 1996, Congress should consider modifying Social Security administrative offset provisions, such as by authorizing the Department of the Treasury to annually index the amount of Social Security benefits exempted from administrative offset to reflect changes in the cost of living over time.

Agency: Congress
Status: Open

Comments: As of December 2018, Congress has not yet taken action on this matter.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should inform affected borrowers of the suspension of offset and potential consequences if the borrower does not take action to apply for a TPD discharge. Such information could include notification that interest continues to accrue and that offsets may resume once their disability benefits are converted to retirement benefits.

Agency: Department of Education
Status: Open

Comments: The Department of Education does not currently notify borrowers of the suspension of offset, but plans to implement a process to do so in the future using a new mailing sent to affected borrowers by their default servicer. The current budget situation does not allow for this type of enhancement, and it is not clear when that will change. In the interim, the agency is exploring alternative notification approaches that could be put in place prior to the implementation of an automated solution. Although Education reported in December 2018 that it has implemented this recommendation, we will consider closing it when we receive documentation that this effort has been completed. As of October 2020, Education's website includes information about the suspension of offset. However, affected borrowers may not know to check the website and the agency has not provided documentation that it has directly alerted affected borrowers.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should revise forms sent to borrowers already approved for a TPD discharge to clearly and prominently state that failure to provide annual income verification documentation during the 3-year monitoring period will result in loan reinstatement.

Agency: Department of Education
Status: Open

Comments: The FUTURE Act (H.R. 5363), signed into law on Dec. 19, 2019, requires the Department of Education (Education) to automate the income monitoring process for borrowers whose loans are discharged for total and permanent disability. As a result of automating the process, borrowers will no longer need to receive Education's forms requesting the borrower to individually provide their income verification documentation during the 3-year monitoring period.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should inform borrowers about the financial hardship exemption option and application process on the agency's website, as well as the notice of offset sent to borrowers.

Agency: Department of Education
Status: Open

Comments: The Department of Education agrees with the recommendation and said that they will include this change in upcoming revisions to the agency's web content. The agency reported that the Notice of Offset to borrowers is sent by Treasury and that they will share this recommendation with Treasury and discuss possible changes to the notice. As of October 2020, Education's website notes that borrowers can request a review of their offset , but it does not specifically note that they may do so because of a financial hardship. Although Education reported in December 2018 that it has implemented this recommendation, we will consider closing it when we receive documentation that the agency has notified borrowers about the financial hardship exemption process on its website and the notice of offset sent to borrowers.

Recommendation: To improve program design for Social Security offsets and related relief options, the Secretary of Education should implement an annual review process to ensure that only eligible borrowers are exempted from offset for financial hardship on an ongoing basis.

Agency: Department of Education
Status: Open

Comments: The Department of Education reported that it plans to fully automate their process for tracking hardships and other exceptions from offset. However, due to competing priorities and funding limitations, full implementation of these improvements have not been scheduled. As they fully implement this process, they will review complementary strategies to assist borrowers in complying with annual reporting requirements. As of December 2018, Education reported that it is in the process of re-designing the student loan financial services environment, which will lead to major improvements such as offset exceptions. They are conducting market research on the new environment, then plan to develop requirements and timelines in support of a procurement with a projected completion in September 2020. We will consider closing this recommendation when we receive documentation that the agency has implemented an annual review process.

Recommendation: To help lessen confusion among the public and policy makers regarding federal data on sexual violence, the Director of OMB should establish a federal interagency forum on sexual violence statistics. The forum should consider the broad range of differences across the data collection efforts to assess which differences enhance or hinder the overall understanding of sexual violence in the United States.

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

Comments: At the time of our report, OMB neither agreed nor disagreed with this recommendation but stated that it did not believe convening a forum was the most strategic use of resources because agencies were not far enough along with their data collection efforts. We disagree with OMB's assertion because 7 of the 10 data collection efforts have been in place for more than 10 years, and several have been in place for multiple decades. As of December 2019, OMB has not provided information on any new efforts to establish a federal interagency forum on sexual violence statistics.

Recommendation: To make the best use of federal resources directed toward combating FGM/C in the United States, the Attorney General and the Secretaries of Education, Health and Human Services, Homeland Security, and State should each develop a written plan that describes the agency's approach for conducting education and outreach to key stakeholders in the United States regarding FGM/C.

Agency: Department of Education
Status: Open

Comments: The Department of Education (Education) concurred with this recommendation. In February 2020, Education told us that it had awarded three grants that, while not focused on FGM/C, may be used for student safety and health at the U.S. state and local levels. After it evaluates grantees' need for information and resources related to FGM/C, Education will determine its next steps. In addition, Education reported that it continues to participate on the federal interagency workgroup devoted to FGM/C and has dedicated program staff to respond to issues related to FGM/C. Education expects to finalize its written plan by August 2020.

Recommendation: To make the best use of federal resources directed toward combating FGM/C in the United States, the Attorney General and the Secretaries of Education, Health and Human Services, Homeland Security, and State should each communicate the plan with other relevant federal agencies and stakeholder groups, as appropriate.

Agency: Department of Education
Status: Open

Comments: The Department of Education (Education) concurred with this recommendation, and noted in a February 2020 update that it is in the process of determining next steps for certain FGM/C awareness activities that may be included in the written plan it will develop. Education expects that it will finalize its written plan by August 2020, at which point it should also communicate that plan with other federal agencies and stakeholder groups to address our recommendation.

Recommendation: The Secretary of the Department of Health and Human Services should direct the Office of Refugee Resettlement to develop a process to ensure all information collected through its existing post-release efforts are reliable and systematically collected so that they can be compiled in summary form and provide useful information to other entities internally and externally.

Agency: Department of Health and Human Services
Status: Open

Comments: In March of 2016, the Office of Refugee Resettlement (ORR) created a new section in its unaccompanied children's policy guide that require ORR staff to make safety and well-being (SWB) follow-up calls to children and their sponsors after the child is release from ORR custody. In addition, in October of 2016, ORR added another section to its policy guide that included case reporting, records management, retention, and information sharing requirements for post-release service (PRS) providers. According to ORR officials, ORR collects and analyzes data from both its SWB calls and PRS providers. SWB call data include efforts made to contact both sponsor and child; participation rates; confirmation the child is currently residing with the sponsor; referrals made to the ORR National Call Center (NCC) for additional resources; any concerns regarding the child's safety and well-being; and whether any reports were made to the ORR Federal Field Specialist, child protective services, local law enforcement, and/or the ORR Sexual Abuse Hotline. PRS data include the reason for referral; level of services provided; services areas accessed by the child and/or sponsor; outcomes; any concerns regarding the child's safety and well-being; and when services were discontinued, according to ORR officials. According to ORR officials, because ORR is currently in the process of developing a new case management system, the majority of information from SWB calls and post-release efforts is collected manually, outside of ORR's current case management system. Information collected through ORR's SWB calls is aggregated quarterly and a fact sheet containing aggregate data is distributed internally to ORR leadership. ORR officials say the new case management system will include information on SWB calls and post-release efforts. ORR tentatively plans for the first phase of the system to be operational by November 2020 and to deploy a finished product with all planned enhancements in late 2021. GAO will close this recommendation once ORR completes this system and demonstrates that it can be used for the purpose of collecting reliable safety and well-being and post-release services data and disseminating it internally and externally, as appropriate.

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.

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.