Recommendation: The Associate Commissioner of the Administration for Children and Families Children's Bureau within the Department of Health and Human Services should develop a process to assess the reliability of grantee performance information contained within annual performance reports for tribal recipients of its Stephanie Tubbs Jones Child Welfare Services Program. (Recommendation 1)

Agency: Department of Health and Human Services
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Department of the Interior's Bureau of Indian Education should take steps to alert grantees of the Native Language Immersion Cooperative Agreement when they are late in submitting performance reports. (Recommendation 2)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of the Department of the Interior's Bureau of Indian Education should develop a process to assess the quality and reliability of a sample of grantee performance data for the Native Language Immersion Cooperative Agreement. (Recommendation 3)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health should fully define in VHA policy the oversight roles and responsibilities related to ensuring facilities' adherence to disbursement agreement policies, including roles related to ReDPro and the role of VISNs. (Recommendation 1)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health should more clearly define in VHA policy the purposes of the periodic independent audits and the ReDPro checklist reviews—including differentiating their purposes from one another and ensuring that they do not unnecessarily overlap. (Recommendation 2)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health should ensure that OAA and CBI modify the ReDPro checklist and associated guidance, to include ensuring that checklist items are clearly stated, relevant to the updated purpose of the ReDPro checklist, and not unnecessarily duplicative of items to be addressed by the periodic independent audits. The guidance should also include detailed instruction on what the compliance officers should review, and how they should determine the appropriate response for each checklist item. (Recommendation 3)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health should ensure that OAA and CBI develop and provide additional ReDPro training for compliance officers, consistent with the updated checklist and guidance. This training should include general information on GME programs and disbursement agreement oversight, as well as detailed information about how ReDPro reviews should be conducted. (Recommendation 4)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health should ensure that OAA implements a standardized independent audit tool that is consistent with the updated purpose of the periodic independent audits, and does not unnecessarily overlap with the ReDPro checklist. This could include modifying its existing recommended checklist, or developing a new tool. (Recommendation 5)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health should ensure that OAA develops guidance for periodic independent audits to assist the audit teams and facility management in understanding how audits are to be conducted. (Recommendation 6)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Under Secretary for Health should ensure that OAA develops substantive training for independent audit team members, consistent with the updated audit purpose, guidance, and tools. This training should include general information on GME programs and disbursement agreement oversight, as well as detailed information about how the independent audits should be conducted. (Recommendation 7)

Agency: Department of Veterans Affairs
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Assistant Attorney General for the Civil Rights Division should work with Education's Office for Civil Rights to provide state educational agencies and school districts with online information, technical assistance, or training materials related to federal accessibility requirements specific to public school facilities. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Assistant Attorney General for the Civil Rights Division should work with Education's Office for Civil Rights to provide state educational agencies and school districts with online information, technical assistance, or training materials related to federal accessibility requirements in public school facilities in the context of safety and security. This may include leveraging recent, online federal initiatives on school safety and physical security. (Recommendation 2)

Agency: Department of Justice
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of BIE should establish consistent requirements for schools on making up missed special education and related services and monitor schools to ensure that they follow these requirements. (Recommendation 1)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency acknowledges that it must refine the guidance provided by its special education subject matter experts to ensure that guidance on missed special education related services is consistent. They anticipate fully implementing reforms through formally published guidance to its special education professionals.

Recommendation: The Director of BIE should work with knowledgeable stakeholders in Indian education to establish a community of practice or other formal mechanism to identify and disseminate promising practices for schools—especially those in remote locations—on recruiting, hiring, and retaining special education teachers and contracting with providers. The Director of BIE could consider conferring with BIE's special education advisory committee, OSEP, and relevant tribal and state education officials in addressing this recommendation. (Recommendation 2)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency plans to work collaboratively with all of its special education stakeholders to build on its internal human capital capabilities, Strategic Workforce Plan and other human capital improvements.

Recommendation: The Director of BIE should rescind the policy of its division overseeing tribally controlled schools that does not meet Interior's requirement to annually review all schools' documentation to verify the provision of services for every special education student, and ensure that all divisions comply with this requirement. (Recommendation 3)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency is reviewing all of its special education policies and procedures and, as of May 2020, anticipates an updated, comprehensive special education policy and handbook in the coming months. This includes replacing the Tribally-Controlled School Division's 3-year review policy with an annual review. A first draft of the new special education handbook and policy is expected in the summer of 2020.

Recommendation: The Director of BIE should update the agency's workforce plan to include a strategy and timeframe for filling vacant staff positions responsible for overseeing and supporting schools' special education programs. (Recommendation 4)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation and plans to update and expand its Strategic Workforce plan to include new function areas. They expect to update it in the coming months to include special education and Johnson O'Malley functions.

Recommendation: The Director of BIE should fully implement the agency's high-risk monitoring policy for IDEA and other federal education programs, including requirements for agency-wide coordination, and ensure that schools selected for such monitoring receive reports and technical assistance plans within 30 days of agency on-site visits, as required by BIE policy. (Recommendation 5)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. Based on lessons learned in its first two years of implementation, the agency plans to make targeted refinements to the policy and process of high-risk monitoring. Regarding the timeliness of report submission and technical assistance delivery, the agency began a targeted reform designed to address this structural weakness, namely, the need to centralize the administrative functions of its oversight activities. The newly established Performance Office will assume the administrative and management oversight of the high-risk fiscal monitoring policy and handbook, including the timely delivery of monitoring reports and technical assistance plans.

Recommendation: The Director of BIE should establish special education training requirements for staff in the agency's Education Resource Centers who are responsible for supporting and overseeing schools' special education programs, and ensure that staff complete those training requirements. (Recommendation 6)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. The agency will ensure that special education training and professional development requirements are identified as part of its planned Strategic Workforce Plan update and expansion.

Recommendation: The Director of BIE should take steps to ensure that all of the agency's Education Resource Centers conduct outreach with schools to inform them of their new roles in overseeing and supporting schools' special education programs under BIE's reorganization. (Recommendation 7)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: BIE agreed with this recommendation. As BIE makes targeted reforms to improve the delivery of special education services, it will ensure that the roles and responsibilities of Education Resource Centers (ERC) are clearly identified and communicated to responsible BIE personnel. Specifically, as it updates and expands the Strategic Workforce Plan, it will clearly and directly define the role of ERC personnel with respect to special education services. In addition, as the new Performance Office establishes timely and routine technical assistance plans, the agency will operationalize the day-to-day engagement and outreach between ERC and school level personnel regarding special education related technical assistance.

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: The Director of the Bureau of Indian Education should develop a systematic process for identifying JOM contractors and maintaining an accurate and complete list of contractors and other relevant information about contractors, such as the amount of JOM funds they receive and their current points of contact. (Recommendation 1)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: Interior concurred with this recommendation. They expect their newly expanded JOM program workforce to develop, publish and implement a comprehensive JOM policy and procedure that includes a systemic process for identifying JOM contractors and maintaining a complete and accurate list of contractors. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education, in coordination with the Bureau of Indian Affairs as needed, should establish a process to track and monitor the timeliness of JOM disbursements to non-tribal contractors, including identifying a target date for disbursing funds to these contractors. (Recommendation 2)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: Interior concurred with this recommendation. The BIE, BIA and other partners will work collaboratively to publish and implement a policy and procedure that accurately tracks and monitors timely disbursement of JOM funds to these contractors. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education should develop a timeline to assess the usefulness of the information they are collecting from JOM contractors and update JOM information collection forms, including converting them to an electronic format to reduce the burden on contractors to complete them. (Recommendation 3)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: Interior concurred with this recommendation. They expect that their newly expanded JOM program workforce will expedite the BIE's review and information collection efforts. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education should develop and provide training to contractors on administering the JOM program. (Recommendation 4)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: Interior concurred with this recommendation. SIE and JOM staff will be tasked with developing a technical assistance framework for contractors and a training plan as part of the wider JOM program policy and task procedures. We will monitor the progress of these efforts.

Recommendation: The Director of the Bureau of Indian Education should clearly define the roles and responsibilities and identify the staff necessary for conducting critical JOM functions, including administering contracts, reviewing the appropriateness of contract types, and overseeing those contractors that are subject to BIE oversight. (Recommendation 5)

Agency: Department of the Interior: Bureau of Indian Education
Status: Open

Comments: Interior concurred with this recommendation. The BIE, BIA and other partners plan to work collaboratively to develop an inter-bureau policy that clearly identifies each agency's roles and responsibilities. They are also developing a data-informed workforce analysis for the JOM program. They will continue to develop and implement a data-informed workforce strategy to identify human capital needs and clearly identifies and assigns critical JOM-related functions among BIE divisions, offices and staff. We will monitor the progress of these efforts.

Recommendation: The SBA Administrator should assign and document clear roles, responsibilities, and reporting lines for headquarters offices' implementation of SBA's plan for addressing the White House Initiative on HBCUs in a timely manner. (Recommendation 1)

Agency: Small Business Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Associate Administrator of the Office of Entrepreneurial Development should take and document steps to ensure that the office's reporting mechanisms collect the information needed to establish a baseline for, and also inform future monitoring and assessment of, efforts to support HBCUs. (Recommendation 3)

Agency: Small Business Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Associate Administrators of the Office of Entrepreneurial Development and Office of Field Operations should communicate planned efforts to support HBCUs, including expectations, goals, and related measures, to the district offices and Small Business Development Centers with HBCUs in their service areas. (Recommendation 2)

Agency: Small Business Administration
Status: Open

Comments: When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Attorney General should ensure that relevant DOJ offices update information about religious-based hate crimes on college campuses, practices to address them, and available DOJ resources to help colleges, campus law enforcement, and other stakeholders monitor and address these crimes. (Recommendation 1)

Agency: Department of Justice
Status: Open

Comments: DOJ has taken a number of steps to address this recommendation, including creating a campus-specific brochure that highlights the Community Relations Service's (CRS) hate crimes prevention and response resources for campus stakeholders. CRS is also in the process of developing a comprehensive guide with best practices for and tools to aid in the planning and implementation of Campus SPIRIT programs and a "spotlight" article for the Department's hate crimes website. DOJ noted that the Office of Community Oriented Policing Services (COPS) is developing hate crimes-specific training curriculum to provide technical assistance to law enforcement agencies, including those on campus. These are important steps to implement this recommendation, but because these resources are currently under development, this recommendation remains open.

Recommendation: The Attorney General should ensure that relevant DOJ offices share more information about available DOJ resources with colleges, campus law enforcement, and other stakeholders to help them monitor and address religious-based hate crimes on college campuses. (Recommendation 3)

Agency: Department of Justice
Status: Open

Comments: DOJ outlined steps it will take to work with campus-based law enforcement organizations such as the International Association of Campus Law Enforcement Administrators, the International Association of Chiefs of Police's University and College Police Section, and the National Association of Student Affairs Professionals. This includes participating in a conference in June 2020 and contacting the groups to increase awareness of its hate crimes website. GAO has requested documentation to demonstrate this outreach has occurred.

Recommendation: The Secretary of Education should develop an online clearinghouse of sample documents from states and localities who wish to share them, past webinar recordings and their related documents, and links to other relevant resources that all SEAs can access. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation. The agency said that its Office of Elementary and Secondary Education will restructure its entire website to better organize its information, and create a new web page to house all foster care-related information and resources. Additionally, Education said this office will launch a virtual portal through which SEA foster care points of contact may collaborate and share resources. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Director of OHS should perform a fraud risk assessment for the Head Start program, to include assessing the likelihood and impact of fraud risks it faces. (Recommendation 1)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open
Priority recommendation

Comments: In February 2020, HHS told us that the Administration for Children and Families (ACF) is developing a Fraud Risk Assessment template for all of its programs (including the Office of Head Start) and is on track to complete the initial Fraud Risk Assessment for its pilot program by June 30, 2020. Upon completion of the Fraud Risk Assessment for the ACF pilot program, ACF anticipates completing its initial Fraud Risk Assessment for OHS, by March 31, 2021. We will assess these actions once completed.

Recommendation: The Director of OHS should establish procedures to monitor and evaluate OHS's new internal workflows for monitoring reviews, to include establishing a baseline to measure the effect of these workflows and identify and address any problems impeding the effective implementation of new workflows to ensure timeliness goals for monitoring reviews are met. (Recommendation 3)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: HHS did not concur with this recommendation. In February 2020, HHS stated that OHS regularly evaluates its effectiveness of its workflows to determine how to best adjust the system to support effective follow-up. HHS also stated that, for Fiscal Year 2020, OHS has updated its internal workflow timelines to increase responsiveness to identified findings and ensure grantee support. We will continue to monitor HHS's efforts in this area.

Recommendation: The Director of OHS should provide program-wide guidance on when a student's slot should be considered vacant due to absenteeism. (Recommendation 5)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: In February 2020, OHS told us that it is finalizing program guidance that will address when a child's slot should be considered vacant due to absenteeism and what a program should do fill it. OHS stated that it anticipates having a final paper published by summer, 2020. We will continue to monitor OHS's efforts in this area.

Recommendation: The Director of OHS should develop and implement a method for grantees to document attendance and services under EHS pregnancy programs. (Recommendation 6)

Agency: Department of Health and Human Services: Administration for Children and Families: Office of Head Start
Status: Open

Comments: In February 2020, OHS told us that it is developing a toolkit of resources specifically designed to offer best practice tips for Early Head Start programs on how to track attendance and services to pregnant women. OHS is surveying the Head Start community to better determine what resources are already available and how programs in different regions and cities track services to pregnant women. OHS anticipates a rollout for the toolkit by summer, 2020.

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 Assistant Secretary for the Office for Civil Rights should immediately remind and clarify for all school districts that they are to only report zero incidents of restraint and seclusion when there are none and that they are to leave cells blank to indicate when data are not collected or incomplete. The Assistant Secretary should also ensure that instructions for when to record zeros and when to leave cells blank are prominently displayed and readily available to districts as they complete the CRDC. (Recommendation 1)

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

Comments: The Department of Education agreed with this recommendation, but in its initial comments said that it was too late to send such a reminder for the 2017-18 data collection because 94 percent of districts had already submitted their data. Education agreed to feature the instructions more prominently on the website and consider other changes, such as targeted communications and changes in the placement of the instructions for the 2019-20 collection. However, in August 2019 Education emailed districts that had reported zero incidents for the 2017-18 school year and told them to review their data and submit corrections if necessary. It also sent separate emails to all districts that clarified and reminded districts when to report zero and when to leave cells blank. For the next CRDC survey, covering the 2019-20 school year, Education said that it was proposing changes to the survey, including featuring instructions and technical assistance more prominently on the online form. We will continue to monitor Education's efforts to implement this recommendation.

Recommendation: The Assistant Secretary for the Office for Civil Rights should monitor compliance with its action plan requirement, and ensure plans are submitted and address all missing data. (Recommendation 3)

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

Comments: The Department of Education agreed with this recommendation. Education stated that it had taken steps to more closely scrutinize action plans for the 2017-18 data collection, including directly communicating with districts about their action plans and scheduling calls with any district that requests similar or repetitious action plans over the course of two or more collections. In December 2019, Education stated that for future collections, it would contact each district with an approved action plan before the start of each new collection and reconfirm that the district will take the needed steps to collect and report the data. Moreover, Education is studying ways to augment the online submission system to send automated reminders regarding data elements covered by action plans. We will continue to monitor Education's efforts to implement this recommendation.

Recommendation: The Assistant Secretary for the Office for Civil Rights should prominently disclose for past collections the potential problems with using restraint and seclusion data given the known misreporting issues, such as those detailed in this report involving 9 of the nation's large public school districts. (Recommendation 4)

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

Comments: The Department of Education initially disagreed with this recommendation, but subsequently said that for the 2015-16 data collection, it would amend the data notes to ensure the public is aware of potential changes by prominently displaying the data notes and clearly delineating the data flaws on its website. We will continue to monitor Education's efforts to implement this recommendation.

Recommendation: The Director of CFPB should provide written clarification to nonbank private student loan lenders on their authorities under the Fair Credit Reporting Act to offer private student loan rehabilitation programs that include removing information from credit reports. (Recommendation 1)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: As of November 2019, CFBP does not plan to act on this recommendation because the law does not require nonbank private student loan lenders to seek CFPB's approval of student loan rehabilitation programs. CFPB stated that if a financial institution chooses to offer a private student loan rehabilitation program it would be protected under the Fair Credit Reporting Act. We maintain that clarification from CFPB that nonbank lenders have the authority to offer these programs could--depending on CFPB's interpretation--result in additional lenders offering rehabilitation programs that would allow more borrowers the opportunity to participate, or it could help ensure that only those entities CFPB has interpreted as being eligible to offer programs are doing so.

Recommendation: The Director of CFPB, after consulting with the prudential regulators and relevant industry groups, should provide written clarification on what information in a consumer's credit report constitutes a private student loan reported "default" that may be removed after successful completion of a private student loan rehabilitation program. (Recommendation 2)

Agency: Consumer Financial Protection Bureau
Status: Open

Comments: As of November 2019, CFPB stated that action on this recommendation is premature pending ongoing work by an industry association on what information may be removed from a credit report after successful completion of a private student loan rehabilitation program. We will continue to follow up with CFPB on its monitoring of this effort and consultation with relevant regulators.

Recommendation: The Administrator of the Food and Nutrition Service should establish a process to plan and conduct regular fraud risk assessments for the school meals programs that align with the leading practices in the Fraud Risk Framework. (Recommendation 1)

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

Comments: As of September 12, 2019, USDA stated that it will undertake, over the course of the next year, a re-evaluation of its existing research and oversight activity to measure and assess fraud risk, its efforts to manage that risk, and its work to minimize the occurrence and impact of fraudulent activity on the school meal programs. USDA also stated that it will look to GAO's Fraud Risk Framework as a model for this effort. USDA expects this effort to include some new activity, such as a deeper examination of the underlying causes of program error in the agency's periodic studies of improper payments. USDA also views this as an opportunity to clarify and highlight how the agency's existing approach to risk management currently addresses fraud risk. USDA agrees that it is appropriate to review and refine its existing controls on a regular basis and recognizes that a more formalized assessment of fraud risk is likely to uncover gaps in existing activity that point to opportunities for further agency action. USDA commits to the development of a response to the effort that is appropriate to the scale of the identified risk and the broader mission of the school meal programs. In September 2020, USDA stated that it has been reviewing agency research and administrative data, as well as conducting new analysis. USDA is concluding work on its risk assessment and plans to circulate it within the agency for review soon. We will continue to monitor USDA's progress in this area.

Recommendation: The Director of ICE should build on existing efforts to use data analytics by employing techniques, such as network analysis, to identify potential fraud indicators in schools petitioning for certification. (Recommendation 2)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should develop an implementation plan for the project aimed at strengthening background checks for DSOs; that plan should outline how the project will be executed, monitored, and controlled. (Recommendation 5)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should implement mandatory DSO training and verify that the training is completed. (Recommendation 6)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Director of ICE should complete the development and implementation of its plans for mandatory fraud-specific training for DSOs. (Recommendation 7)

Agency: Department of Homeland Security: United States Immigration and Customs Enforcement
Status: Open

Comments: As of March 2020, ICE officials indicated that they were in the process of addressing GAO's recommendation and would submit an update including supporting documentation when available. 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 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 Secretary of Education should establish timeframes for providing states with additional information on allowable expenditures of funds reserved for pre-employment transition services. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education agreed with this recommendation and stated that it would establish projected timeframes for providing states with additional information on allowable expenditures for the provision of preemployment transition services. Education also stated that it intends to provide states with additional information in at least two forums before the end of calendar year 2018 and to review and analyze previous guidance provided to states on allowable expenditures.

Recommendation: The Secretary of Education should take additional steps to provide states assistance on updating and finalizing their interagency agreements with state educational agencies to include pre-employment transition services. These steps could include, for example, accelerating their efforts to discuss the benefits of finalizing interagency agreements, and reminding states of existing technical assistance resources pertaining to updating and finalizing interagency agreements. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation, in large part, because there is no statutory provision authorizing the agency to identify such states. Nevertheless, Education stated that it is taking some steps as part of its ongoing monitoring of the VR program to provide assistance to states that have not updated their interagency agreements. This is consistent with the intention of our recommendation but we believe more could be done. The agency also noted that it would continue to offer and provide technical assistance if it becomes known through the onsite monitoring of the VR program or through other means that states have not updated their interagency agreements between VR agencies and state educational agencies. In addition, its Rehabilitation Services Administration (RSA) and Office of Special Education Programs will provide information related to sources of technical assistance, as appropriate, to VR agencies and state educational agencies. While these steps may be helpful, given the number of states that have not updated and finalized their agreements and the length of time Education officials say they will take to complete this round of monitoring where Education asks state VR agencies about these agreements, additional action by Education may be needed to help states more efficiently and effectively coordinate services to students with disabilities.

Recommendation: The Secretary of Education should develop a written plan with specific timeframes and activities for identifying and disseminating best practices that address, as appropriate, implementation challenges for pre-employment transition services, such as those identified in this report. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation believing it is premature to develop a timeline for the dissemination of best practices. The agency stated that the identification of "best" practices, meaning those that are clearly supported by a body of evidence derived from valid and reliable research findings, is still emerging as states implement the requirements. Education stated that as RSA identifies best practices through its monitoring and technical assistance activities, it will, in collaboration with its Office of Special Education Programs, consider when and how best to disseminate this information to state VR and educational agencies. With regard to including specific timeframes and activities in a written plan, by detailing the specific steps Education is taking and plans to take along with the amount of time it expects them to take, Education would be better positioned to complete those steps in a timely manner and meet the statutory requirement that Education highlight best state practices and support state agencies.

Recommendation: The Commissioner of Education's Rehabilitation Services Administration should work with state VR agencies to determine whether and what additional information and assistance VR agencies may find helpful regarding on-demand training, such as online videos, to employers on disability issues. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation, noting that state VR agencies have the primary responsibility for determining how best to meet employers' needs, promote mainstream employment, and collaborate with other workforce programs in their states. Education recognized the importance of providing information and technical assistance to state VR agencies to help them serve employers, while stressing that it is a state matter how to best meet the training needs of employers. The agency did not provide an update in FY19.

Recommendation: The Commissioner of Education's Rehabilitation Services Administration should work with state VR agencies to determine how to most effectively disseminate information about the circumstances in which individuals who are employed may be eligible for career advancement services. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation, noting that state VR agencies have the primary responsibility for determining how best to meet employers' needs, promote mainstream employment, and collaborate with other workforce programs in their states. The agency recognized the importance of expanding career advancement opportunities for individuals with disabilities in accordance with the Rehabilitation Act as amended by WIOA. At the same time, Education said it is up to states to determine how to most effectively disseminate information about their services. Education noted it will continue to work with state VR agencies to determine what additional information may be necessary about the circumstances in which individuals who are employed may be eligible for career advancement services. The agency did not provide an update in FY19.

Recommendation: The Commissioner of Education's Rehabilitation Services Administration should work with state VR agencies to develop more complete information on when and how VR agencies should assess employment settings, including settings supported by the AbilityOne program, to determine if they meet the definition of competitive integrated employment. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: Education disagreed with this recommendation. The agency stated that it is a state matter to determine whether an employment location qualifies as an "integrated setting" for the purpose of the VR program, and that it is not Education's role to inform states as to when and how to make such determinations. Nevertheless, Education said it will continue to work with the states to determine if additional information would help them assess employment locations. The agency did not provide an update in FY19.

Recommendation: The Commissioner of Education's Rehabilitation Services Administration should encourage local areas to clarify and document the roles and responsibilities of partner agencies in working with employers and provide sample language of how local areas may document roles and responsibilities in their MOUs. (Recommendation 4)

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation. Education said it believes that state workforce development agencies are in the best position to lead employer engagement efforts, but will continue to collaborate with other federal partners to provide technical assistance to states in this area, including examples of state- and local-level collaboration on employer engagement. The agency did not provide an update in FY19.

Recommendation: The Commissioner of Education's Rehabilitation Services Administration should, in setting the employer performance measurement approaches with DOL after the pilot is concluded, take into account VR agencies' concerns and key attributes of successful performance measures, including clarity in what is meant by employer services, coverage of the VR agencies' core program activities, and consideration of factors outside of VR agencies' control. (Recommendation 5)

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation. Education said it will work with DOL to ensure that state VR agencies' concerns are considered when the performance measure for effectiveness in serving employers is finalized. The agency did not provide an update in FY19.

Recommendation: The Assistant Secretary of DOL's Employment and Training Administration should encourage local areas to clarify and document the roles and responsibilities of partner agencies in working with employers and provide sample language of how local areas may document roles and responsibilities in their MOUs. (Recommendation 6)

Agency: Department of Labor
Status: Open

Comments: DOL agreed with this recommendation, noting that local workforce boards and one-stop partners are in the best position to lead employer engagement, but that it will collaborate with federal partners in providing related technical assistance. In June 2019, DOL shared with GAO a local workforce area memorandum of understanding (MOU) that documents the workforce system partners' roles and responsibilities for engaging with employers. DOL has posted this MOU on its technical assistance web site, so it is available to other local workforce areas. However, in order to close the recommendation as implemented, GAO will need DOL to demonstrate that the agency has actively encouraged local workforce areas to document the roles and responsibilities of workforce partners--including the vocational rehabilitation program--for working with employers, through a Training and Employment Guidance Letter or other such guidance.

Recommendation: The Assistant Secretary of DOL's Employment and Training Administration should, in setting the employer performance measurement approaches with Education after the pilot is concluded, take into account VR agencies' concerns and key attributes of successful performance measures, including clarity in what is meant by employer services, coverage of the VR agencies' core program activities, and consideration of factors outside of VR agencies' control. (Recommendation 7)

Agency: Department of Labor
Status: Open

Comments: DOL agreed with this recommendation and said it will coordinate with Education to ensure state VR agencies' concerns are considered in defining the performance measure. In June 2019, DOL told us the two agencies expected to complete their evaluation of the pilot performance measures for effectiveness in serving employers by June 30, 2020, and then make a final decision about which measures to put in place. DOL also said the two federal agencies are working to consider VR agencies' concerns during this pilot, and have developed a crosswalk to identify appropriate VR services that count towards this measure. For GAO to close this recommendation as implemented, DOL will have to demonstrate that the finalized performance measures have taken into account VR agencies' concerns, including clarity in what is meant by employer services, coverage of the VR agencies' core program activities, and consideration of factors outside of VR agencies' control.

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: The Assistant Secretary for Elementary and Secondary Education should improve the usability of Education's websites to ensure that the states and school districts can more easily find and access federal guidance to address lead in school drinking water, by taking actions such as clarifying which links contain guidance; highlighting new or important guidance; improving their websites' search function; and categorizing guidance. (Recommendation 5)

Agency: Department of Education
Status: Open

Comments: The Department of Education agreed with this recommendation. The agency said it would identify and include an information portal dedicated to enhancing the usability of federal resources related to testing for and addressing lead in school drinking water. Also, Education said it is interested in increasing coordination across all levels of government and it shares the view expressed in our report that improved federal coordination, including with EPA, will better enhance collaboration to encourage testing for lead in school drinking water. In 2019, Education said it planned to complete work on this recommendation by January 1, 2020. We will consider closing this recommendation when these efforts are complete.

Recommendation: The Assistant Secretary for Elementary and Secondary Education should collaborate with EPA to encourage testing for lead in school drinking water. This effort could include disseminating EPA guidance related to lead testing and remediation in schools or sending letters to states to encourage testing in all school districts that have not yet done so. (Recommendation 7)

Agency: Department of Education
Status: Open
Priority recommendation

Comments: The Department of Education agreed with this recommendation. Education stated it has held multiple meetings with the Environmental Protection Agency (EPA) and stated that it plans to hold a virtual meeting with EPA to share information and resources about safe drinking water and raise awareness of the importance of testing for lead. Education also stated it is developing a timeline to conduct additional collaboration activities with EPA. Education officials said they are considering joining an EPA-led Memorandum of Understanding to, among other things, encourage schools to test drinking water for lead. We will consider closing this recommendation when these efforts are complete.

Recommendation: As Education develops the required HBCU Capital Financing Program outreach plan, the Executive Director of the program should include in the plan (1) ways to increase outreach to individual HBCUs so that HBCU officials are informed of the program; (2) steps to coordinate directly with state university systems to specifically address state-level challenges to participation and share potential solutions to increase public HBCU participation; and (3) ways to further leverage the designated bonding authority in its efforts. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: Education identified steps it plans to take to address each of the three components we recommended. First, to increase outreach to individual HBCUs, Education stated it will send letters to presidents and chancellors of eligible HBCUs that are not yet participating, in addition to existing activities. Second, Education stated that it plans to use methods similar to those currently used to reach out to public HBCUs, depending on resources, to coordinate directly with state university systems. Third, Education noted it plans to explore ways to leverage the designated bonding authority to do so. Education also stated that an HBCU's ability to use the program depends on its financial strength, and government resources alone will not ensure financial strength among struggling institutions. We agree; however, it is important to make HBCUs aware of the resources available to them, particularly a federal program that was created to help address HBCUs' capital financing challenges. Education expects to complete these effort by February 28, 2020.

Recommendation: The Executive Director of the HBCU Capital Financing Program should lead an agency effort to analyze various Capital Financing Program loan modifications, including the effects of the loan deferments authorized in the 2018 Consolidated Appropriations Act as well as other potential modifications, to assess the potential benefits to HBCUs participating in the program, the potential cost of these options to the government, and their effect on the program's overall financial stability. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: Education partially agreed with this recommendation, commenting that it disagreed with the recommendation to the extent that it suggests a modification of loan terms. However, our recommendation does not endorse providing loan modifications to colleges but is focused on analyzing the costs and benefits of modifications authorized by law, as well as other potential modifications. Education noted it will continue to analyze loan modifications and develop cost estimates. Our report noted, however, that Education was not able to provide evidence of analysis it conducted on potential loan modifications. We continue to believe that analysis of costs and benefits is needed to determine whether additional loan modifications are necessary or beneficial for the program. The agency anticipates completing its efforts by December 2025.

Recommendation: The Department of Education's Assistant Secretary for Civil Rights should determine the extent to which Title IX coordinators at the K-12 level are aware of and using the tools recommended in OCR's existing guidance and any barriers preventing their use of this guidance, and use this information in OCR's efforts to encourage them to work with athletics administrators on ensuring equal athletic opportunities. (Recommendation 1)

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

Comments: In November 2018, the Office for Civil Rights sent an e-mail to its Regional Directors to inform them of GAO's report, remind them of the importance of coordination between Title IX coordinators and athletics administrators, and encourage them to look for opportunities in their investigations and compliance work to examine the role of Title IX coordinators at the K-12 level. Agency officials also said they sent a letter to Title IX coordinators reminding them of the tools available to them under Title IX. While these are important first steps, as we noted in our report, we continue to believe the systemic approach we recommended is necessary. We are working with Education to obtain updated information, and will close the recommendation if Education demonstrates that any of these steps results in obtaining new information about the extent to which K-12 Title IX coordinators are aware of and using existing Title IX tools, and any barriers they face in doing so, and that they have used this information to inform their work with Title IX coordinators.

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 leadership of the Committee on STEM Education should review performance assessments of federal STEM education programs and then take appropriate steps to enhance effectiveness of the portfolio, such as by sharing promising practices that agencies could use in designing or revising their programs. (Recommendation 1)

Agency: Committee on Science, Technology, Engineering, and Math Education
Status: Open

Comments: The Committee agreed with this action, as recommended by GAO in its March 2018 report, and took some steps toward implementing it. In December 2018, the Committee issued a new 5-year STEM education strategic plan. The Committee's plan states that to enhance the effectiveness of the STEM education portfolio, federal agencies that comprise the Committee are to perform a systematic review of evidence from current programs (e.g., performance assessments). Committee agencies are to also identify promising, evidence-based STEM education programs, practices, and policies in order to learn from and implement them more broadly. The strategic plan commits federal agencies to develop an implementation plan. According to agency officials, the implementation plan will be finalized in the Fall of 2019. GAO will review future efforts of the Committee to determine if they address the recommendation and could lead to improved management of the federal STEM education portfolio.

Recommendation: The leadership of the Committee on STEM Education should improve public awareness of information on programs' performance assessments by documenting program-level information on performance assessments in its federal STEM education inventory. (Recommendation 2)

Agency: Committee on Science, Technology, Engineering, and Math Education
Status: Open

Comments: The Committee agreed with this action, as recommended by GAO in its March 2018 report, and took some steps toward implementing it. In December 2018, the Committee issued a new 5-year STEM education strategic plan. One of the plan's objectives focuses on making program performance and outcomes publically available. To achieve this objective, federal agencies that comprise the Committee are to document and share programs' performance assessment information for both internal strategic planning purposes and to inform public audiences. According to the strategic plan, Committee agencies are to provide content for the inventory of STEM education programs by the end of 2019. GAO will review the results of the Committee's future efforts, including its inventory of programs, to determine if they adequately address the recommendation. The plan acknowledges GAO's finding on the importance of collecting, organizing, and reporting federal performance data to increase public awareness of the impact of federal STEM education programs.

Recommendation: The leadership of the Committee on STEM Education should report required information on the participation rates of women, underrepresented minorities, and persons from rural areas in federal STEM education programs that collect this information. (Recommendation 3)

Agency: Committee on Science, Technology, Engineering, and Math Education
Status: Open

Comments: The Committee agreed with this action, as recommended by GAO in its March 2018 report, and took some steps toward implementing it. In December 2018, the Committee issued a new 5-year STEM education strategic plan. According to the strategic plan, the Committee will develop a common reporting framework that federal agencies with STEM education programs can use to provide the rates of program participation by women, underrepresented minorities, and persons in rural areas. Agencies will begin reporting this information by the end of 2019. According to an official from the Office of Science and Technology Policy, the agency anticipates reporting programs' participation rates in its 2020 annual report to Congress. The plan also states that agencies that conduct valid and reliable tracking of such data are to share their promising practices across agencies so that those strategies can be replicated where and when appropriate. GAO will follow the Committee's progress developing and implementing the reporting framework to determine if it addresses GAO's recommendation. As noted in the strategic plan, tracking and reporting on the participation of underrepresented groups in federal STEM education programs provides agencies with information to gauge their effectiveness at fostering diversity and inclusion.

Recommendation: The Director of the Office of Science and Technology Policy should report the outcomes of programs' performance assessments completed in the previous year in its annual report. (Recommendation 4)

Agency: Executive Office of the President: Office of Science and Technology Policy
Status: Open

Comments: The Office of Science and Technology Policy agreed with this action, as recommended by GAO in its March 2018 report, and took some steps toward implementing it. In December 2018, the Committee issued a new 5-year STEM education strategic plan. The strategic plan states that the Office of Science and Technology Policy will include in its annual reports descriptions of the outcomes of any program assessments conducted on federal STEM education programs in the previous year. According to an Office of Science and Technology Policy official, this information will be included in annual reports starting in 2020. GAO will review these annual reports to determine if they address the recommendation. As noted in the strategic plan, collecting and reporting federal performance data supports efficient and effective use of public funding, increases public awareness of federal program outcomes, and promotes the use of high-quality performance assessment and evaluation methods.

Recommendation: The Secretary of Homeland Security, in collaboration with other agencies, through the planned interagency working group or another mechanism, should identify further opportunities to more effectively publicize resources to reach additional colleges. (Recommendation 2)

Agency: Department of Homeland Security
Status: Open

Comments: In early 2020, the federal government created the schoolsafety.gov clearinghouse website to compile and publicize emergency preparedness resources from across multiple agencies including the Departments of Education, Homeland Security, and Justice. The website houses key emergency preparedness resources we identified during our work as well as newer information that was not part of our review, such as guidance related to the Coronavirus Pandemic. DHS issued a press release when the website was launched, but does not prominently publicize it on it website, including on its webpages that are specifically focused on colleges and universities. We will monitor the agency's efforts to publicize these resources and consider closing it at that time.

Recommendation: The Attorney General, in collaboration with other agencies through the planned interagency working group or another mechanism, should identify further opportunities to more effectively publicize resources to reach additional colleges. (Recommendation 3)

Agency: Department of Justice
Status: Open

Comments: In early 2020, the federal government created the schoolsafety.gov clearinghouse website to compile and publicize emergency preparedness resources from across multiple agencies including the Departments of Education, Homeland Security, and Justice. The website houses key emergency preparedness resources we identified during our work as well as newer information that was not part of our review, such as guidance related to the Coronavirus Pandemic. DOJ issued a press release when the website was launched, but does not prominently publicize it on it website, including on its webpages that are specifically focused on colleges and universities. We will monitor the agency's efforts to publicize these resources and consider closing it at that time.

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: Congress should consider requiring that states notify parents/guardians of changes in students' federal special education rights when a student with a disability is moved from public to private school by their parent.

Agency: Congress
Status: Open

Comments: As of August 2019, Congress has not considered this matter.

Recommendation: The Assistant Secretary for Special Education and Rehabilitative Services should review information provided by states related to changes in federal special education rights when a parent places a student with a disability in a private school and work with states to correct inaccurate information.

Agency: Department of Education: Office of Special Education and Rehabilitative Services
Status: Open
Priority recommendation

Comments: Education generally agreed with this recommendation. However, the agency believes it is necessary to review the full documents containing information provided by states, so that it can determine the context in which the information was presented. We will coordinate with Education as appropriate to facilitate such a review. As of March 2020, the agency worked with relevant states to improve the information provided, and reviewed states' revised information to parents about federal rights of children with disabilities who are placed by parents in private schools. Education stated that this effort did not identify any inaccurate or inconsistent information. However, some states appear not to have modified language that Education previously identified as inaccurate. Education did not explain why it has determined that this information is now accurate. To fully address this recommendation, Education should either provide this explanation or have these states correct any inaccurate information.

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 ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to develop a comprehensive long-term capital asset plan to inform its allocation of school facility funds. Such a plan should include a prioritized list of school repair and maintenance projects with the greatest need for funding.

Agency: Department of the Interior
Status: Open

Comments: Interior agreed with this recommendation. In August 2017, Indian Affairs reported that its Office of Facilities, Property, and Safety Management was undergoing a reorganization to establish a work group focused on asset management and will continue to work with the Office of Management and Budget to develop a capital asset management plan. In October 2018, Indian Affairs provided a prioritized list of deferred maintenance projects for 2018 and documentation of its processes for prioritizing school deferred maintenance requirements and allocating one type of construction funding. They also provided a memorandum on facilities management communication and organizational roles and responsibilities and sample agendas and minutes from meetings regarding construction. Indian affairs did not provide a long term capital asset plan. We will continue to monitor Indian Affairs' efforts to implement this recommendation and await documentation on the actions it is taking to develop a capital asset plan. We will continue to monitor Indian Affairs' efforts to implement this recommendation and await documentation on the actions it is taking to develop a capital asset plan.

Recommendation: To ensure accountability for BIE school facility funds, the Secretary of the Interior should direct the Assistant Secretary--Indian Affairs to improve oversight and technical assistance to tribal organizations to enhance tribal capacity to manage major construction projects.

Agency: Department of the Interior
Status: Open

Comments: Interior agreed with this recommendation. In August 2017, Indian Affairs reported that its Division of Facilities Management and Construction will develop a project tracking and monitoring process for all projects above a certain monetary threshold. Additionally, Indian Affairs reported that this office will work with BIA and BIE officials to identify common challenges that tribes face in managing projects and provide appropriate technical assistance. In September 2018, Indian Affairs provided documentation of templates it had created for regional Indian Affairs officials to use in communicating with tribes and agendas for training presentations. Neither of these documents show any direct technical assistance to tribes or address oversight. We will continue to monitor Indian Affairs' efforts to implement this recommendation and await documentation on the actions it is taking to improve oversight and technical assistance to tribal organizations.

Recommendation: The Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to assign responsibility to a specific office or official to develop and implement a plan to assess employees' safety training needs and monitor employees' compliance with Indian Affairs' safety training requirements.

Agency: Department of the Interior
Status: Open

Comments: Interior agreed with this recommendation. In early August 2017, Indian Affairs reported that BIA regional leadership, in collaboration with Indian Affairs' safety office, will develop and publish a safety training plan for all Indian Affairs employees with responsibilities for safety inspections. Additionally, Indian Affairs reported that BIA and BIE will develop and implement a policy to ensure that first-line supervisors monitor and report on whether employees have completed the training requirements. Indian Affairs reported a target date of January 31, 2020 for implementing this recommendation. In May 2018, Indian Affairs reported that it had completed a draft training plan and noted that it had been submitted to management for review. We requested copies of the training plan but as of August 2018, we had not been provided any. In April 2019, Indian Affairs provided documentation that it had developed and implemented a plan to assess all employees' safety training needs. In addition, agency officials reported that Interior's new training management system allows supervisors to track employees' completion of required safety training courses. However, the agency did not provide documentation that senior managers are overseeing employees' compliance with Indian Affairs' safety training requirements. In May 2020, Indian Affairs officials told us that they had developed a process to generate reports on personnel safety training compliance and would provide documentation demonstrating that such reports are shared with management to address training noncompliance. We will continue to monitor the agency's actions in this area.

Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to coordinate with the Federal Highway Administration and tribal stakeholders and reexamine the need for road-description and condition data currently collected in the NTTFI and eliminate fields that do not serve an identified purpose.

Agency: Department of the Interior
Status: Open

Comments: In June 2019, Interior reported that the Bureau of Indian Affairs' (BIA) and Federal Highway Administration's (FHWA) efforts to coordinate with tribes and the Tribal Transportation Program Coordinating Committee (TTPCC) to address this recommendation were progressing. Established by federal regulations, TTPCC is the committee comprised of 24 tribal representatives that provides input and makes recommendations to the BIA and FHWA. According to Interior, TTPCC has identified data elements--14 of 54 data fields--to be considered for removal from NTTFI, and BIA and FHWA have held discussions with tribes concerning a draft plan to remove these identified data elements from NTTFI. Interior reported that tribal groups have posed no objections to the plan and that they anticipate the plan being implemented later in the year. We will continue to monitor actions to address this recommendation.

Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to for fields determined to have continued relevance for management and program oversight take steps to improve the quality of these data by clarifying guidance in the NTTFI coding guide that tribes use to collect data and by providing additional guidance on steps needed to ensure that data are consistently reported.

Agency: Department of the Interior
Status: Open

Comments: In June 2019, Interior reported that a group of tribal users organized by the Bureau of Indian Affairs (BIA) and the Federal Highway Administration (FHWA) to review the NTTFI and the coding guide was progressing in its efforts to recommend updates to the coding guide. According to Interior, the group has made recommendations to the Tribal Transportation Program Coordinating Committee (TTPCC) on which data elements to remove from the NTTFI and for clarifying guidance in the coding guide, relevant to the data elements proposed to remain in the NTTFI. Interior anticipates that updates to the coding guide based on the group's recommendations will be completed in 2019. We will continue to monitor actions to address this recommendation.

Recommendation: To help ensure that NTTFI is able to provide quality information to support management and program oversight efforts, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to establish a process to monitor data to facilitate timely and targeted corrections to missing or erroneous data.

Agency: Department of the Interior
Status: Open

Comments: Interior told us that, along with the Bureau of Indian Affairs (BIA) and Federal Highway Administration (FHWA), it has held several meetings with tribal users to identify missing or erroneous data in the NTTFI. For example, the meeting participants identified that data which were formerly but are no longer used in formulas to allocate federal funding to tribes are likely outdated and not useful. Further, recognizing that approximately 70 percent of NTTFI data reflects inventory and condition information of roads owned by non-BIA and non-tribal entities, such as state and local governments, the meeting participants determined that opportunities exist to work with these external entities to monitor data obtained from them to ensure that it is current and accurate for use and display in the NTTFI. As of June 2019, Interior said that, in anticipation of changes to the NTTFI format, its main actions to address this recommendation will be to coordinate with these external entities to monitor the data they provide to NTTFI to ensure it conforms to NTTFI's new format. We will continue to monitor actions to address this recommendation.

Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a means to document when the level of service for each road section was last evaluated.

Agency: Department of the Interior
Status: Open

Comments: In June 2019 Interior reported that BIA had developed a data reporting process that incorporates use of a "time-stamp" to indicate when the level of service for a road section is evaluated. Interior said that it anticipates providing guidance on this process to BIA staff, tribes, and others that perform level of service road maintenance assessments so that they can implement the process in 2020. We will continue to monitor efforts to implement this recommendation.

Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop and maintain documentation supporting the unit costs of maintenance used to estimate maintenance needs.

Agency: Department of the Interior
Status: Open

Comments: In June 2019 Interior reported that the Bureau of Indian Affairs (BIA) had surveyed tribes to determine their capabilities for managing data related to road maintenance costs. Interior further reported that BIA was investigating the use of computer software for tracking road maintenance costs and developing estimates of maintenance needs. Interior said that it expects to complete actions to implement this recommendation in 2020. We will continue to monitor actions to address this recommendation.

Recommendation: To improve the DMR, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a process for more complete and accurate reporting occurring under existing authority of Road Maintenance Program funds expended for performed maintenance on BIA roads.

Agency: Department of the Interior
Status: Open

Comments: In its official comments on our report, Interior said that that it cannot reasonably accomplish this recommendation because, in reference to the tribes which have agreements with the Bureau of Indian Affairs (BIA) to maintain BIA roads in their area, it conflicts with the intent of federal law and the minimum-reporting requirements when a tribal entity takes over the day-to-day actions and tasks of a program. However, following our report's issuance, Interior told us that its actions to address other recommendations will assist the tribes in developing data on Road Maintenance Program (RMP) funds expended for performed maintenance on BIA roads. In addition, Interior said that tribes have expressed interest in gathering this data. Further, in June 2019, Interior reported that the Tribal-Interior Budget Council had approved a plan for a pilot project in the BIA Great Plains Region to gather data relevant to addressing this recommendation. Even though tribal reporting of this data is voluntary, we continue to believe that by coordinating with affected tribes on developing a process for their self-reporting of RMP funds expended for maintenance, and by implementing such a process for tribes that BIA serves directly, Interior could improve the reporting of maintenance performed on BIA roads and be better positioned to provide Congress with more accurate and complete information on RMP funding decisions. We will continue to monitor actions to address this recommendation.

Recommendation: To best align resources allocation decisions to needs, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to review the formula to fund transportation at BIE schools and determine, with BIA and tribal stakeholders, what adjustments, such as distinguishing between gravel and paved roads, are needed to better reflect transportation costs for schools.

Agency: Department of the Interior
Status: Open

Comments: At the time of our report, Interior said that it concurred with this recommendation; however, it subsequently changed its position. Interior noted that its tribal and school partners have not requested changes to this formula and that it was therefore not compelled to undertake the rigorous consultation and negotiated rulemaking actions that would be needed to change the formula. As of June 2019, Interior has not acted to address this recommendation.

Recommendation: To implement the goals and policy priorities of the 2020 Federal Youth Transition Plan, the Federal Partners in Transition (FPT) workgroup--the Secretaries of HHS, Education, Department of Labor, and the Commissioner of the Social Security Administration--should develop a long-term implementation plan that includes milestones and specific agency roles and assignments.

Agency: Department of Education
Status: Open

Comments: In June 2020, the Department of Labor (DOL) reported additional efforts by member federal agencies of the Federal Partners in Transition (FPT) to collaborate to make progress towards meeting the policy priorities outlined in the 2020 Federal Youth Transition Plan. In addition, DOL has reported that it has formalized and assigned certain FPT roles and responsibilities, is currently evaluating the 2020 plan priorities, is developing a charter to further define FPT milestones and federal agency roles and responsibilities, and will update the Office of Disability Employment Policy (ODEP) website to highlight FPT milestones and timelines. We are encouraged by this additional progress and anticipate we will close the recommendation once DOL provides the approved charter and updates the ODEP website as specified.

Recommendation: To implement the goals and policy priorities of the 2020 Federal Youth Transition Plan, the Federal Partners in Transition (FPT) workgroup--the Secretaries of HHS, Education, Department of Labor, and the Commissioner of the Social Security Administration--should develop a long-term implementation plan that includes milestones and specific agency roles and assignments.

Agency: Department of Health and Human Services
Status: Open

Comments: In July 2020, the HHS reported additional efforts by member federal agencies of the Federal Partners in Transition (FPT) to collaborate to make progress towards meeting the policy priorities outlined in the 2020 Federal Youth Transition Plan. In addition, HHS has reported that it has formalized and assigned certain FPT roles and responsibilities, is currently evaluating the 2020 plan priorities, is developing a charter to further define FPT milestones and federal agency roles and responsibilities, and the Office of Disability Employment Policy (ODEP) website will be updated to highlight FPT milestones and timelines. We are encouraged by this additional progress and anticipate we will close the recommendation once approved charter is provided and updates to the ODEP website are made as specified.

Recommendation: To implement the goals and policy priorities of the 2020 Federal Youth Transition Plan, the Federal Partners in Transition (FPT) workgroup--the Secretaries of HHS, Education, Department of Labor, and the Commissioner of the Social Security Administration--should develop a long-term implementation plan that includes milestones and specific agency roles and assignments.

Agency: Social Security Administration
Status: Open

Comments: In November 2019, SSA again reported that it meets on a monthly basis in both the Federal Partners in Transition (FPT) steering and general meetings, and that these meetings have created a working, structured, collaborative effort to address the audit recommendation and meet the policy priorities outlined in the FPT 2020 plan. SSA noted that the voluntary, ad-hoc nature of the FPT precludes definitive role assignments and implementation plans. We continue to maintain that being a voluntary initiative does not preclude the FPT from establishing long-term milestones and clarifying roles and responsibilities. Further, a long-term plan can be changed, and need not be definitive. Without a long-term implementation plan that includes milestones and specific agency roles and assignments, it is less likely that the priorities outlined in the 2020 Plan will be achieved.

Recommendation: To implement the goals and policy priorities of the 2020 Federal Youth Transition Plan, the Federal Partners in Transition (FPT) workgroup--the Secretaries of HHS, Education, Department of Labor, and the Commissioner of the Social Security Administration--should develop a long-term implementation plan that includes milestones and specific agency roles and assignments.

Agency: Department of Labor
Status: Open

Comments: In June 2020, the Department of Labor (DOL) reported additional efforts by member federal agencies of the Federal Partners in Transition (FPT) to collaborate to make progress towards meeting the policy priorities outlined in the 2020 Federal Youth Transition Plan. In addition, DOL has reported that it has formalized and assigned certain FPT roles and responsibilities, is currently evaluating the 2020 plan priorities, is developing a charter to further define FPT milestones and federal agency roles and responsibilities, and will update the Office of Disability Employment Policy (ODEP) website to highlight FPT milestones and timelines. We are encouraged by this additional progress and anticipate we will close the recommendation once DOL provides the approved charter and updates the ODEP website as specified.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to expand its performance measures for the 21st Century program to address all program objectives. Specifically, Education should establish performance measures related to key behavioral, including student attendance and disciplinary incidents, and socio-emotional outcomes.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with our recommendations; rather, it generally noted that it will keep our recommendations in mind as it continues to implement changes in the program as a result of ESSA. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to conduct federal-level data checks on the accuracy of 21st Century program data submitted by states. Such checks could test for logical relationships between fields. Education should also publicly disclose and address any data limitations it identifies, as appropriate.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but stated that it was taking some actions to enhance program data. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to provide written, non-regulatory guidance to states on developing and conducting high-quality 21st Century state evaluations to help address the difficulties states face in measuring program performance and effectiveness.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but identified steps it plans to take to implement it. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

Recommendation: The Secretary of Education should direct the Office of Academic Improvement to use the information it collects from its monitoring visits and ongoing interactions with states to share effective practices across states for sustaining their 21st Century programs once program funding ends. This information could be shared using existing mechanisms such as Education's meetings with 21st Century state coordinators.

Agency: Department of Education
Status: Open

Comments: Education neither agreed nor disagreed with this recommendation, but identified steps it plans to take to implement it. We will monitor the agency's progress and consider closing it when the agency provides documentation that these efforts are complete.

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: 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 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 ensure that all BIE schools are positioned to address safety and health problems with their facilities and provide student environments that are free from hazards, the Secretary of the Interior should direct the Assistant Secretary-Indian Affairs to develop a plan to build schools' capacity to promptly address safety and health problems with facilities. Such a plan could prioritize assistance to schools to improve the expertise of facility staff to maintain and repair school buildings.

Agency: Department of the Interior
Status: Open
Priority recommendation

Comments: Interior agreed with this recommendation. In June 2018, Indian Affairs provided us with documentation on its efforts to build schools' capacity to address safety and health problems with facilities. In particular, the agency updated its Service Level Agreement between BIA and BIE, which details their roles and responsibilities for inspecting and providing technical assistance to BIE schools, among other areas. However, Indian Affairs' documents provided little information on how it planned to support BIE school personnel in fixing safety hazards in their facilities. In our 2016 report, we found that school personnel often lack the necessary technical expertise, time, and resources to address safety hazards in school buildings. Further, the agency did not include information on whether it has staffed regional offices with specialists to assist schools with safety and facility issues. In February 2020, agency officials said that they had not taken further actions to implement the recommendation and indicated that no office or official was currently responsible for coordinating efforts to implement the recommendation.

Recommendation: In order to ensure complete, analyzable records regarding research grant award decisions are available for management and analysis, the Secretary of Energy should direct DOE's grant-making agencies to implement additional data collection efforts, which should include: (1) Retaining complete records of pre-proposal, proposal, and award data, including a record of proposal disposition, in linked electronic files to facilitate aggregate, statistical analysis of the grant-making process, including the calculation of success rates. (2) Collecting demographic, education, and career information from applicants, on a voluntary basis, that is not available to proposal reviewers but is used for analysis of success rates.

Agency: Department of Energy
Status: Open

Comments: DOE generally agreed with this recommendation. DOE's Office of Science began collecting investigator demographics during the second quarter of fiscal year 2015 and already retained complete records that enabled the calculation of success rates. According to DOE officials, since September 2017, the other three grant-making components included in our audit have been taking various actions to implement the recommendation. These three components, the Office of Nuclear Energy (NE), the Advanced Research Projects Agency-Energy (ARPA-E), and the Office of Energy Efficiency and Renewable Energy (EERE), all complete steps to ensure that they retain complete grant life cycle information for each individual award, including complete records of pre-proposal, proposal, and award data in linked electronic files, thus fulfilling the first part of our recommendation. In 2019, EERE coordinated the development of a Federal Register Notice (FRN) regarding data collection jointly with NE and ARPA-E. The FRN drafted by EERE was finalized and published on February 11, 2020 (Vol. 85, Issue 28, Pages 7759-7760 [FR DOC# 2020-02674]). Under the proposed information collection request, an interface will be implemented in DOE grant application systems to allow external users to voluntarily provide a minimal amount of demographic information to comply with this recommendation, pursuant to review by the Office of Management and Budget. On June 30th, DOE officials shared with GAO the draft FRN for the 30-day notice and request for public comment prior to implementation.

Recommendation: To comply with Title IX enforcement requirements, the Secretary of the Department of Defense, which funds STEM research at universities, should direct the Director of the Office of Diversity Management and Equal Opportunity to ensure that Title IX compliance reviews of DOD's grantees are periodically conducted.

Agency: Department of Defense
Status: Open

Comments: DOD agreed with this recommendation and noted it is in the process of revising current DOD guidance which will address its Title IX enforcement requirements. In September 2017, a DOD official stated that the agency is in the process of formulating instructions related to both Title IX and Title VI that they believe will address the recommendation regarding Title IX enforcement. In a memorandum issued in December 2017, a DOD official described the agency's corrective action plan (CAP), including drafting an updated rule for the Code of Federal Regulations and the development and issuance of internal DOD policy documents regarding Title IX enforcement requirements. Both of these activities were expected to be completed by June 2019. DOD reported in March 2020 that it is continuing to revise current DOD guidance to address its Title IX enforcement requirements. The Director of DOD's Office of Diversity, Equity, and Inclusion (ODEI) stated in a letter to GAO that the revised Titile IX policy is in the early stages of DOD's policy process. ODEI expressed its commitment to developing the revised policy and ensuring Title IX compliance reviews are conducted as per the revised policy and GAO's recommendation. In September of 2020, DoD sent an update indicating that they will issue a policy memorandum, specifically outlining the requirement for DoD Components who provide financial assistance to educational programs or activities conduct periodic compliance reviews. This is expected to be complete by December 31, 2020.

Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should address overpayments resulting from enrollment changes by identifying and implementing a cost-effective way to allow Post-9/11 GI Bill beneficiaries to verify their enrollment status each month, and require monthly reporting.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA officials reported in August 2020 that the agency was in the latter stages of developing a pilot program to verify beneficiaries' attendance using text messaging. This pilot, scheduled for release in November 2020, will initially be limited to beneficiaries receiving the Rogers STEM Scholarship to extend their Post-9/11 GI Bill benefits, but would eventually be expanded to all Post-9/11 GI Bill beneficiaries if it is successful. VA expects to complete these efforts by December 2021.

Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should improve efforts to notify veterans and schools about overpayment debts by identifying and implementing other methods of notifying veterans and schools about debts to supplement the agency's mailed notices (e.g., email, eBenefits).

Agency: Department of Veterans Affairs
Status: Open

Comments: VA officials reported in August 2020 that the agency has taken action to move away from a reliance on mailed letters, including the eventual use of email notifications for debt letters and other GI Bill correspondence. The agency plans to implement these changes December by 2020.

Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should revise policy for calculating overpayments to increase collections by prorating tuition overpayments when veterans reduce their enrollment during the term based on the actual date of the enrollment change rather than paying additional benefits through the end of the month during which the reduction occurred.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA officials reported in August 2020 that the agency is revising its tuition overpayment regulations to address the recommendation in GAO's 2015 report. VA officials said that these revisions are part of its broader regulatory proposal that has experienced delays due to 2017 legislative changes and other legal developments. They expect these proposed regulations to be published by December 2020.

Recommendation: To improve the administration of the Post-9/11 GI Bill, reduce the occurrence of overpayments, and increase debt collections, the Secretary of Veterans Affairs should ensure it is recovering the full amount of tuition and fee payments if a school does not charge a veteran for any tuition or fees after dropping a class or withdrawing from school. For example, VA could adjust its overpayment calculation to account for these situations or provide schools with guidance on how to account for school refund policies when reporting enrollment and tuition changes.

Agency: Department of Veterans Affairs
Status: Open

Comments: VA officials reported in August 2020 that the agency plans to amend its procedures to account for school refund policies when calculating veterans' overpayment debts, as we recommended. VA plans to incorporate this change in its information technology (IT) upgrades by December 2021. Earlier plans to implement this recommendation were put on hold so the department could prioritize other IT updates that it said are necessary to implement certain legislative changes to the GI Bill program.

Recommendation: To help districts address key challenges in meeting MOE and mitigate unintended consequences that may affect services for students with disabilities, while preserving the safeguard for funding for students with disabilities, Congress should consider options for a more flexible MOE requirement. This could include adopting a less stringent MOE requirement to align with the MOE requirements in other education programs or adding to or modifying exceptions. For example, current exceptions could be changed to allow one-time increases in spending without changing a district's MOE baseline in order to encourage pilot innovations or to allow certain spending decreases (e.g., state caps on teacher benefits), as long as a district can demonstrate the decrease does not negatively affect services.

Agency: Congress
Status: Open

Comments: As of February 2020, Congress has not taken legislative action on this issue.

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 improve agencies' guidance development, review, evaluation, and dissemination processes for non-significant guidance, we recommend that the Secretaries of USDA, HHS, DOL, and Education should improve the usability of selected component websites to ensure that the public can easily find, access, and comment on online guidance. These improvements could be informed by the web and customer satisfaction metrics that components have collected on their websites. Some examples of changes that could facilitate public access to online guidance include (1) improving website usability by clarifying which links contain guidance; (2) highlighting new or important guidance; and (3) ensuring that posted guidance is current.

Agency: Department of Health and Human Services
Status: Open

Comments: In comments printed in the April 2015 final report, HHS concurred with the recommendation and stated that it would review current links to guidance documents and explore ways to enhance their visibility and usability. As of June 2020, GAO is working with HHS officials to obtain additional updates and documentation regarding the department's implementation of this recommendation.

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.