Federal Student Aid

Timely Performance Plans and Reports Would Help Guide and Assess Achievement of Default Management Goals Gao ID: GAO-03-348 February 14, 2003

During fiscal year 2002, an estimated 5.8 million people borrowed about $38 billion in federal student loans. Despite a dramatic reduction in annual default rates on those loans since fiscal year 1990 (from 22.4 to 5.9 percent), the total volume of dollars in default doubled to nearly $22 billion by fiscal year 2001 from about $11 billion in fiscal year 1990. During that same period, the total student loans outstanding grew from $54.1 billion to $233.2 billion. The Department of Education's Office of Federal Student Aid (FSA) manages the nation's student financial assistance programs authorized under title IV of the Higher Education Act (HEA). In 1998, Congress amended the HEA and established FSA as a performance-based organization. Among other requirements, the HEA called for FSA to annually develop 5-year plans, issue annual reports, and consult with stakeholders regarding their delivery system. GAO initiated a review to assess FSA's default management efforts and results.

FSA's default management goals were mostly to prevent defaults, increase collections, and verify student eligibility, but the agency lacked a plan to guide its efforts. FSA had 39 default management goals for fiscal years 2000 through 2002. However, the goals changed significantly during this period and FSA did not annually prepare 5-year performance plans as required by the HEA. FSA met or exceeded most goals, but did not prepare timely performance reports. According to our analysis, FSA met or exceeded performance targets for 36 of its 39 default management goals during fiscal years 2000 through 2002. However, FSA did not issue performance reports for fiscal years 2000 and 2001, as required by the HEA. Instead, in December 2002, FSA issued one report for both fiscal years that lists accomplishments, but does not clearly indicate the extent to which goals were or were not met. Suggestions from survey respondents did not indicate the need for additional goals. While about one-third of the 23 school officials who responded to our survey made suggestions about ways that FSA could better assist them, none of the suggestions indicated the need for additional default management goals. FSA assisted all schools by sharing default management information through symposiums and other media, and provided individual assistance to some schools through visits and telephone calls. Most of the responding officials were generally pleased with FSA's assistance. The suggestions that officials made did not indicate a need for additional goals because they either related to existing goals or addressed operational issues.

Recommendations

Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.

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GAO-03-348, Federal Student Aid: Timely Performance Plans and Reports Would Help Guide and Assess Achievement of Default Management Goals This is the accessible text file for GAO report number GAO-03-348 entitled 'Federal Student Aid: Timely Performance Plans and Reports Would Help Guide and Assess Achievement of Default Management Goals' which was released on February 14, 2003. This text file was formatted by the U.S. General Accounting Office (GAO) to be accessible to users with visual impairments, as part of a longer term project to improve GAO products‘ accessibility. Every attempt has been made to maintain the structural and data integrity of the original printed product. Accessibility features, such as text descriptions of tables, consecutively numbered footnotes placed at the end of the file, and the text of agency comment letters, are provided but may not exactly duplicate the presentation or format of the printed version. The portable document format (PDF) file is an exact electronic replica of the printed version. We welcome your feedback. Please E-mail your comments regarding the contents or accessibility features of this document to Webmaster@gao.gov. Report to the Secretary of Education: United States General Accounting Office: GAO: February 2003: Federal Student Aid: Timely Performance Plans and Reports Would Help Guide and Assess Achievement of Default Management Goals: GAO-03-348: GAO Highlights: Highlights of GAO-03-348, a report to the Secretary of Education Why GAO Did This Study: During fiscal year 2002, an estimated 5.8 million people borrowed about $38 billion in federal student loans. Despite a dramatic reduction in annual default rates on those loans since fiscal year 1990 (from 22.4 to 5.9 percent), the total volume of dollars in default doubled to nearly $22 billion by fiscal year 2001 from about $11 billion in fiscal year 1990. During that same period, the total student loans outstanding grew from $54.1 billion to $233.2 billion. The Department of Education‘s Office of Federal Student Aid (FSA) manages the nation‘s student financial assistance programs authorized under title IV of the Higher Education Act (HEA). In 1998, Congress amended the HEA and established FSA as a performance-based organization. Among other requirements, the HEA called for FSA to annually develop 5-year plans, issue annual reports, and consult with stakeholders regarding their delivery system. GAO initiated a review to assess FSA‘s default management efforts and results. What GAO Found: FSA‘s default management goals were mostly to prevent defaults, increase collections, and verify student eligibility, but the agency lacked a plan to guide its efforts. FSA had 39 default management goals for fiscal years 2000 through 2002. However, the goals changed significantly during this period and FSA did not annually prepare 5- year performance plans as required by the HEA. FSA met or exceeded most goals, but did not prepare timely performance reports. According to our analysis, FSA met or exceeded performance targets for 36 of its 39 default management goals during fiscal years 2000 through 2002. However, FSA did not issue performance reports for fiscal years 2000 and 2001, as required by the HEA. Instead, in December 2002, FSA issued one report for both fiscal years that lists accomplishments, but does not clearly indicate the extent to which goals were or were not met. Suggestions from survey respondents did not indicate the need for additional goals. While about one-third of the 23 school officials who responded to our survey made suggestions about ways that FSA could better assist them, none of the suggestions indicated the need for additional default management goals. FSA assisted all schools by sharing default management information through symposiums and other media, and provided individual assistance to some schools through visits and telephone calls. Most of the responding officials were generally pleased with FSA‘s assistance. The suggestions that officials made did not indicate a need for additional goals because they either related to existing goals or addressed operational issues. Highlights Figure: [See PDF for image] [End of figure] What GAO Recommends: The Secretary of Education and FSA‘s Chief Operating Officer should (1) produce a 5-year performance plan annually as required by the HEA and (2) prepare and issue reports to the Congress on FSA‘s performance that are timely and clearly identify whether performance goals were met. www.gao.gov/cgi-bin/getrpt?GAO-03-348. To view the full report, including the scope and methodology, click on the link above. For more information, contact Cornelia M. Ashby at (202) 512-8403 or ashbyc@gao.gov. Contents: Letter: Results in Brief: Background: FSA‘s Default Management Goals Were Mostly to Prevent Defaults, Increase Collections, and Verify Student Eligibility, but the Agency Lacked a Plan to Guide its Efforts: FSA Met or Exceeded Most Goals, but Did Not Prepare Timely Performance Reports: Surveyed School Officials‘ Suggestions Did Not Indicate the Need for Additional Goals: Conclusions: Recommendations to the Secretary of Education: Agency Comments and Our Evaluation: Appendix I: Scope and Methodology: Appendix II: FSA‘s Default Management Goals for Fiscal Years 2000-2002: Appendix III: FSA‘s Default Management Goals and Outcomes for Fiscal Years 2000-2002: Appendix IV: Comments from the Office of Federal Student Aid: Appendix V: GAO Contacts and Staff Acknowledgments: GAO Contacts: Staff Acknowledgments: Tables: Table 1: Total Student Loan Portfolio and Amounts in Default by Type of Loan for Fiscal Years 1990--2001 (nominal dollars in billions): Table 2: Summary of Postsecondary Schools That Participated in Our Survey: Figures: Figure 1: Fiscal Years 1990-2000 National Cohort Default Rates: Abbreviations: COO: Chief Operating Officer: CDRcohort default rate: FFEL: Federal Family Education Loan Program: FSA: Office of Federal Student Aid: HEA: Higher Education Act: HHS: Department of Health and Human Services: IFAP: Information for Financial Aid Professionals: IRS: Internal Revenue Service: NSLDS: National Student Loan Data System: PBO: performance-based organization: VFA: Voluntary Flexible Agreement: This is a work of the U.S. Government and is not subject to copyright protection in the United States. It may be reproduced and distributed in its entirety without further permission from GAO. It may contain copyrighted graphics, images or other materials. Permission from the copyright holder may be necessary should you wish to reproduce copyrighted materials separately from GAO‘s product. February 14, 2003: The Honorable Roderick Paige Secretary of Education: Dear Mr. Secretary: During fiscal year 2002, an estimated 5.8 million people borrowed about $38 billion in federal student loans to help meet their educational needs. This is more than triple the $11.7 billion borrowed in fiscal year 1990. Despite a dramatic reduction in annual default rates on those loans since fiscal year 1990 (from 22.4 to 5.9 percent), the total volume of dollars in default had grown to nearly $22 billion by fiscal year 2001 from about $11 billion in fiscal year 1990. During the same period, the total student loans outstanding grew from $54.1 billion to $233.2 billion. The Department of Education‘s Office of Federal Student Aid (FSA) is responsible for managing and administering the nation‘s student financial assistance programs authorized under title IV of the Higher Education Act (HEA) of 1965, as amended. In 1998, the Congress amended HEA to establish FSA as a performance-based organization (PBO) in order to address longstanding management weaknesses.[Footnote 1] Among other requirements, HEA called for FSA to annually develop 5-year plans that establish measurable goals and to issue annual reports on the extent to which the goals were met. The intent of this law was to provide among other things, a greater level of accountability for FSA‘s administration of programs. Additionally, HEA requires FSA to seek the opinions and suggestions of postsecondary institutions and other stakeholders, such as lenders and borrowers, regarding their delivery system. Because of the large volume of dollars at-risk, we undertook this study to determine (1) what FSA‘s default management goals were for fiscal years 2000 through 2002, (2) whether FSA had achieved its stated performance goals, and (3) whether school officials from schools with large potential losses from defaults--schools with high default rates or a high volume of dollars in default--had suggestions that indicated the need for additional default management goals. To achieve our objectives, we reviewed HEA to identify FSA‘s roles and responsibilities, interviewed FSA officials responsible for overseeing and administering student aid programs, and obtained and analyzed available data and reports on FSA‘s performance goals and accomplishments for fiscal years 2000--2002. In addition, we interviewed FSA officials regarding assistance provided to schools, particularly, schools with high default rates and those with a high volume of dollars in default. We attempted to contact officials at 31 schools with high default rates or a high volume of dollars in default to ask them their views of the assistance provided by FSA and to obtain their suggestions on ways that FSA could better assist them. Officials from 23 of the 31 schools agreed to participate in our survey. We conducted our work between September 2002 and January 2003 in accordance with generally accepted government auditing standards. See appendix I for additional information about our scope and methodology. Results in Brief: For fiscal years 2000 through 2002, FSA identified 39 default management goals designed primarily to prevent defaults, increase collections, or verify student eligibility. The default management goals included increasing students‘ awareness of their repayment obligations, verifying family income by matching student records with Internal Revenue Service (IRS) tax records, and locating defaulted borrowers through a national new hires database. However, the goals changed significantly between fiscal years 2000 and 2002 and were not tied to an overall plan. Specifically, although 5 of the 39 goals were continued for each of the 3 fiscal years and 6 others were continued for 2 years, 28 were single-year goals. Moreover, a majority of these single-year goals, 15 of the 28, were implemented in fiscal year 2002. FSA‘s documents did not explain the basis for establishing, continuing, or ending goals from year to year nor did FSA prepare 5-year performance plans as required by HEA. On the basis of our analysis of FSA‘s internal documents, we determined that 36 of its 39 default management goals were met or exceeded during the 3-year period. FSA met its goal to recover more previously defaulted dollars than it lost through new defaults; it recovered $4.87 billion compared to $2.7 billion lost through new defaults. Also, FSA met its target to support the administration‘s efforts to improve its data matching capabilities with the IRS by proposing changes to legislation that would authorize expanded use of tax data. The 3 unmet goals were to (1) provide the Congress with a report by the end of fiscal year 2002 explaining the impact of voluntary flexible agreements (VFAs);[Footnote 2] (2) implement a multiyear program during the 3-year period to reduce default rates over the life of the loan; and (3) prepare an analysis in fiscal year 2002 to identify improvements that could be made to the National Student Loan Data System (NSLDS)--a national database containing information on federal student loans and grants. Although FSA achieved nearly all of its default management goals, it did not provide to the Congress timely reports on its performance as required by HEA for fiscal years 2000 and 2001. In December 2002, FSA issued a single performance report for both fiscal years 2000 and 2001. The information in the report was not timely nor did it indicate whether or not the agency met established performance goals. As a result, the Congress does not know whether FSA achieved its goals for those years. While 7 of the 23 officials from schools with high default rates or a high volume of dollars in default who participated in our survey made suggestions about ways that FSA could better assist them, none of these suggestions indicated the need for additional default management goals. FSA provided similar assistance to all schools, irrespective of their default rates or dollars in default, primarily by sharing default management best practices at its National Default Prevention Day symposiums and hosting conferences to disseminate default management information. FSA also provided individual assistance to some schools through on-site visits and telephone calls to address specific default management concerns such as preparing default management plans. Although 16 of the 23 officials said that they were generally pleased with one or more services provided by FSA, nearly a third suggested ways that FSA could better assist schools. Their suggestions included improving the usefulness and access to loan information in NSLDS, holding default management training sessions in locations near them, and making it easier to identify and contact the right FSA program officials to address concerns. These suggestions did not indicate the need for additional default management goals because they either related to existing goals or addressed operational issues. To assure the public that FSA has developed long-term goals that set the direction for its default management program, we are recommending that the Secretary of Education and FSA‘s Chief Operating Officer (COO) prepare and make available a 5-year performance plan annually, as required by HEA. In addition, to provide essential information to the Congress about FSA‘s progress toward achieving its goals, we are recommending that the Secretary of Education and FSA‘s COO prepare and issue performance reports to the Congress that are timely and clearly indicate whether established goals and performance targets were met. FSA provided written comments on a draft of this report. In commenting on the draft, FSA generally agreed with our findings and said it would take actions to address our recommendations. FSA‘s written comments appear in appendix IV. Background: Title IV of HEA authorized several student aid programs including the Federal Family Education Loan (FFEL) and the William D. Ford Direct Loan (Direct Loan) programs, the Federal Pell Grant program, and campus-based aid programs.[Footnote 3] The FFEL and Direct Loan programs are the largest source of aid for students. The FFEL program[Footnote 4] provides loans to eligible students and parents through participating private lenders that receive a federal guarantee of repayment if the borrower defaults. Under the Direct Loan program, eligible students and parents borrow funds directly from the federal government through participating schools. As of October 2002, about 6,400 schools participated in one or more of the title IV student aid programs. To be eligible to participate in the FFEL and Direct Loan programs, schools must manage their loan portfolios to keep the default rate for their loans below established limits. The national student loan default rate, also known as the national cohort default rate (CDR), is defined as the percentage of borrowers who enter repayment status in a certain fiscal year and default before the end of the next fiscal year on Federal Stafford Loans and, under certain circumstances, Federal SLS loans, and Direct Stafford Loans. For example, the fiscal year 2000 CDR of 5.9 percent represents the percentage of borrowers whose first loan repayments came due between October 1, 1999, and September 30, 2000, and who, as of September 30, 2001, had defaulted. The national CDR is an aggregate of all postsecondary institutional default rates. The CDR for schools with 30 or more borrowers in repayment is calculated based on the percentage of borrowers entering repayment on loans in a fiscal year and defaulting during that fiscal year or the following fiscal year.[Footnote 5] FSA issues draft CDRs and supporting data to schools in January or February of each year for review. A school may challenge the draft default rate information if it identifies inaccuracies in data. In addition, a school with CDRs of 25 percent or more for 3 consecutive years can appeal the draft rate if it can show that the number of students who obtained loans did not exceed approximately 3.8 percent of the total number of students at the school, while schools with CDRs over 40 percent in 1 year can appeal the draft rate if it can show that the number of students who obtained loans did not exceed approximately 6 percent of the total number of students at the school. FSA makes revisions as needed, and releases the final CDR to the schools and the public no later than September 30 of each year. Unless a school has 30 or fewer borrowers who entered repayment for the 3 most recent fiscal years, it could lose its eligibility to participate in some title IV student aid programs if its final CDR exceeds established thresholds. For example, under HEA, if schools have CDRs of 25 percent or more for 3 consecutive years, they face loss of eligibility to participate in the FFEL and Direct Loan programs.[Footnote 6] A regulation imposes the same restriction on eligibility if schools have CDRs exceeding 40 percent in a given year. Additionally, schools that are ineligible to receive FFEL and Direct Loans due to CDRs of 25 percent or more for 3 consecutive years are also generally prohibited by statute from receiving Pell Grants. These schools are subject to suspension from title IV programs for the remainder of the fiscal year in which FSA notifies them of termination and the following 2 fiscal years. However, schools have appeal rights and retain program eligibility while their appeals are pending. Schools may apply to be reinstated to participate in title IV loan and/or Federal Pell Grant programs after the later of the expiration of their suspension or 18 months after the effective date of their termination. Over the last decade, approximately 1,200 schools have been subject to suspension due to default rates above the 25 percent threshold for fiscal years 1998 through 2000.[Footnote 7] From fiscal year 1990 to fiscal year 1999, the national student loan default rate declined from 22.4 percent to 5.6 percent. In fiscal year 2000, the rate climbed slightly to 5.9 percent. Figure 1 shows the trend in national cohort default rates from fiscal years 1990 through 2000. Figure 1: Fiscal Years 1990-2000 National Cohort Default Rates: [See PDF for image] [End of figure] Despite the overall progress made in reducing the national default rate, the cumulative student loan funds in default had doubled to almost $22 billion by fiscal year 2001 from their fiscal year 1990 level of nearly $11 billion. During this same time period, the total student loan portfolio grew by more than 400 percent from $54.1 billion to $233.2 billion and the defaults, as a percent of the total loan portfolio, declined from 20.1 percent to 9.4 percent. Table 1 shows the outstanding portfolio and defaulted loan balances for FFEL and Direct Loans as well as the total defaulted loans as a percentage of the total outstanding loan portfolio for fiscal years 1990 through 2001. Table 1: Total Student Loan Portfolio and Amounts in Default by Type of Loan for Fiscal Years 1990--2001 (nominal dollars in billions): Fiscal Year: 1990; FFEL Outstanding Portfolio: $ 54.1; FFEL Defaults[ A]: $ 10.9; Direct Loan Outstanding Portfolio: --; Direct Loan Defaults[ A]: --; Total Outstanding Portfolio: $54.1; Total Outstanding Portfolio: $10.9; Total Defaults: 20.1. Fiscal Year: 1991; FFEL Outstanding Portfolio: 57.5; FFEL Defaults[ A]: 12.5; Direct Loan Outstanding Portfolio: --; Direct Loan Defaults[ A]: --; Total Outstanding Portfolio: 57.5; Total Outstanding Portfolio: 12.5; Total Defaults: 21.7. Fiscal Year: 1992; FFEL Outstanding Portfolio: 62.0; FFEL Defaults[ A]: 13.6; Direct Loan Outstanding Portfolio: --; Direct Loan Defaults[ A]: --; Total Outstanding Portfolio: 62.0; Total Outstanding Portfolio: 13.6; Total Defaults: 21.9. Fiscal Year: 1993; FFEL Outstanding Portfolio: 69.0; FFEL Defaults[ A]: 12.1; Direct Loan Outstanding Portfolio: --; Direct Loan Defaults[ A]: --; Total Outstanding Portfolio: 69.0; Total Outstanding Portfolio: 12.1; Total Defaults: 17.5. Fiscal Year: 1994; FFEL Outstanding Portfolio: 80.0; FFEL Defaults[ A]: 12.5; Direct Loan Outstanding Portfolio:

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