Federal Student Aid

ANNUAL REPORT

Fiscal Year 2023
United States Department of Education

Miguel A. Cardona, Ed.D. 

Secretary

Federal Student Aid

Richard Cordray

Chief Operating Officer

Finance Directorate

Mehul Parekh

Chief Financial Officer

November 16, 2023

This publication is in the public domain. Authorization to reproduce it, in whole, or in part, is 

granted. While permission to reprint this publication is not necessary, the citation should be: 

U.S. Department of Education, Federal Student Aid, Federal Student Aid Fiscal Year 2023

Annual Report, Washington, D.C., 2023. 

This publication is available under Performance Reports located on the Federal Student Aid 

website at StudentAid.gov/strategic-planning-reporting. 

To connect to Federal Student Aid through social media, please visit the Federal Student Aid 

website at StudentAid.gov or on X at @FAFSA. 

Federal Student Aid operates on a fiscal year, which begins on October 1 and ends on 

September 30. Information included in the Federal Student Aid Annual Report is based on the 

fiscal year unless otherwise noted.

Federal Student Aid strives to improve and enhance the content quality, report layout, and 

public accessibility of its Annual Report. Suggestions on how this report can be made more 

informative and useful are welcome. The public and other stakeholders are encouraged to 

submit all questions and comments to AFRComments@ed.gov.
Fiscal Year 2023 Annual Report | Federal Student Aid i

Contents

Contents

Introduction (Unaudited)..................................................iii

Letter from the Chief Operating Officer of Federal Student Aid.......................................v

About This Report..............................................................................................................viii

Overview of the Federal Student Aid Annual Report........................................................ix

Management’s Discussion and Analysis (Unaudited) .........1

Overview of Management’s Discussion and Analysis ......................................................3

Fiscal Year 2023 Organizational Highlights........................................................................4

Looking Forward at Federal Student Aid ......................................................................................... 4

Federal Student Aid by the Numbers............................................................................................... 5

Mission and Organizational Structure ................................................................................7

Mission ............................................................................................................................................. 7

Organizational Structure .................................................................................................................. 8

Mission, Vision, and Core Values .................................................................................................. 10

Federal Student Financial Aid Programs ....................................................................................... 13

Performance Management ................................................................................................. 18

Performance Management Processes at Federal Student Aid...................................................... 20

Agency Priority Goals..................................................................................................................... 24

Quality of Performance Data.......................................................................................................... 25

Analysis of Financial Statements......................................................................................26

Introduction .................................................................................................................................... 26

Balance Sheet................................................................................................................................ 26

Statement of Net Cost.................................................................................................................... 37

Statement of Changes in Net Position........................................................................................... 38

Statement of Budgetary Resources ............................................................................................... 39

Financial Management Highlights.................................................................................................. 40

Analysis of Systems, Controls, and Legal Compliance ..................................................41

Annual Performance Report (Unaudited) .........................43

Overview of the Annual Performance Report...................................................................44

Introduction to the Annual Performance Report..............................................................45

Performance Targets by Strategic Goals, Objectives, and Metrics ...............................47

Understanding the Annual Performance Report Section............................................................... 51

Performance Results by Strategic Goals, Objectives, and Indicators...........................52

Strategic Goal 1: Improve Customer Service and Outcomes for Students and Borrowers.......... 52

Strategic Goal 2: Advance Equity and Access to Student Financial Assistance........................... 67

Strategic Goal 3: Strengthen Engagement and Accountability for Educational and Financial 

Institutions ...................................................................................................................................... 77

Strategic Goal 4: Increase Workforce and Workplace Capabilities ............................................... 86

Strategic Goal 5: Boost Operational Efficiency.............................................................................. 95

Fiscal Year 2023 Accomplishments of Federal Student Aid.........................................108
ii Fiscal Year 2023 Annual Report | Federal Student Aid

Contents

Additional Reporting Requirements (Unaudited) ...........119

Overview of Additional Reporting Requirements ..........................................................121

Legislative and Regulatory Recommendations .............................................................122

Annual Bonus Awards......................................................................................................123

Report of the Federal Student Aid Ombudsman............................................................124

Introduction .................................................................................................................................. 124

Overview of All Cases Received in Fiscal Year 2023.................................................................. 124

Activities of the Ombudsman ....................................................................................................... 140

Financial Section (Unaudited)........................................145

Overview of the Financial Section...................................................................................147

Consolidated Balance Sheet............................................................................................148

Notes to the Consolidated Balance Sheet......................................................................149

Independent Auditors’ Report .........................................................................................168

Office of Inspector General Audit Transmittal.............................................................................. 168

Independent Auditors’ Report ...................................................................................................... 170

Other Information (Unaudited)......................................181

Overview of the Other Information Section....................................................................183

Consolidated Statement of Net Cost...............................................................................185

Consolidated Statement of Changes in Net Position ....................................................186

Combined Statement of Budgetary Resources..............................................................187

Notes to the Consolidated Statement of Net Cost, Consolidated Statement of 

Changes in Net Position, and Combined Statement of Budgetary Resources...........188

Summary of the Financial Statement Audit....................................................................216

Management Assurances................................................................................................. 216

Management Challenges..................................................................................................216

Payment Integrity..............................................................................................................216

Appendices (Unaudited) ................................................219

Appendix A: Performance Metrics and Target Changes...............................................221

Appendix B: Data Validation and Verification Matrix ....................................................225

Appendix C: Glossary of Acronyms and Terms ............................................................237

Appendix D: Availability of the FSA Report ...................................................................245
Fiscal Year 2023 Annual Report | Federal Student Aid iii

Introduction

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Introduction (Unaudited)
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Introduction

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Fiscal Year 2023 Annual Report | Federal Student Aid v

Introduction

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Letter from the Chief Operating Officer of Federal 

Student Aid

Dear Federal Student Aid Community: 

Again, I am honored to present the Federal Student Aid 

Fiscal Year (FY) 2023 Annual Report that showcases the 

work of the U.S. Department of Education (Department) 

Office of Federal Student Aid (FSA). At FSA, we enable the 

American dream for millions of students who are pursuing 

education and training beyond high school. This report 

highlights our efforts to enhance customer service, boost 

teamwork, drive efficiency, and advance our workforce 

capability.

The Higher Education Act of 1965 authorizes the 

Department to grant financial assistance that allows broader 

access to higher education. Our mission statement at FSA, 

“Funding America’s Future, One Student at a Time,” 

articulates that goal. FSA makes it possible for all eligible 

students and families to access federal financial aid so they 

can realize the benefits of education and training beyond 

high school, which also greatly strengthens our nation’s 

productive capacity.

During the COVID-19 pandemic, FSA pioneered innovative ways of conducting business that 

have produced efficiencies throughout our enterprise. During FY 2023, FSA maintained high 

productivity by shifting considerable resources and assistance online to serve students, families, 

and schools more effectively. This year, we provided about $114.1 billion in federal grants, 

loans, and work-study funds to more than 9.7 million students at approximately 5,400 

participating postsecondary schools. FSA worked to transform challenges into opportunities, as 

our colleagues around the country operated effectively even in a virtual work posture.

While providing access to higher education is core to our mission, we also track the scope of the 

federal student loan debt portfolio, whose value exceeds $1.6 trillion. This enormous debt load 

burdens millions of Americans, which has stimulated us to find new innovations in managing our 

many programs, products, services, and operations. We know access to higher education 

shapes people’s future paths forward, and our decisions matter significantly to our nation’s 

future. 

During FY 2023, FSA navigated the final months of the prolonged federal student loan payment 

pause to ease the transition of borrowers who are returning to repayment. Prior to the October 

2023 return to repayment date, FSA had worked closely with our student loan servicers to make 

sure borrowers had the information and resources they needed to deal with the challenges of 

returning to repayment on their student loan debt obligations after more than three years of not 

being required to make payments. This was especially important for borrowers who completed

Richard Cordray

Chief Operating Officer
vi Fiscal Year 2023 Annual Report | Federal Student Aid

Introduction

(Unaudited)

their schooling during the payment pause and must now begin to repay their student loans for 

the first time ever.

FSA has also unveiled other measures, such as adding new pages to StudentAid.gov, our 

primary customer website, to help borrowers learn about and access loan payment options. This 

summer, the Department announced the launch of the Saving on A Valuable Education (SAVE) 

income-driven repayment (IDR) plan, which is one of the most affordable student loan 

repayment plans ever offered. The SAVE plan has helped many borrowers reduce their monthly 

payments to as low as $0 and it can prevent loan balances from growing due to unpaid interest. 

The SAVE Plan will greatly benefit low- and middle-income borrowers, community college 

students, and borrowers who work in public service. As of September 2023, more than 4 million 

student loan borrowers had already enrolled in the SAVE plan, with thousands more signing up 

every day. 

Our support for borrowers re-entering repayment includes those who are enrolled in the Fresh 

Start initiative, which is expected to benefit hundreds of thousands of borrowers. This initiative 

enrolls previously defaulted borrowers and reverses the negative effects of their default by 

improving their credit status and providing access to affordable IDR plans.

By the end of FY 2023, FSA had delivered historic levels of targeted student loan debt relief 

benefitting individuals and their families. We especially made progress on our pledge to fix flaws 

in the existing loan forgiveness programs. Through late-September 2023, roughly $127 billion in 

targeted relief had been approved for nearly 3.6 million student loan borrowers. This included 

nearly $42 billion for almost 855,000 borrowers eligible for forgiveness through IDR by fixing 

historical inaccuracies in the count of payments that qualify toward forgiveness. Targeted relief 

efforts also provided nearly $51 billion in loan forgiveness for 715,000 public servants through 

the Public Service Loan Forgiveness (PSLF) program; $11.7 billion for almost 513,000 

borrowers with a total and permanent disability; and $22.5 billion for more than 1.3 million 

borrowers who were cheated by their schools, saw their schools close abruptly, or were covered 

by court settlements.

For the past four years, FSA has focused on improving the federal student aid process through 

the Free Application for Federal Student Aid®, or the FAFSA® form, which students complete to 

apply for federal grants, work-study assistance, and federal student loans. We have now made 

it to the home stretch of this complicated, multi-year project. The vast changes we are making to 

the FAFSA experience are producing a major overhaul of the FAFSA form, processes, and 

systems culminating in the redesigned 2024–25 FAFSA, expected in December 2023.

These substantial changes were required by two laws passed by Congress: the Fostering 

Undergraduate Talent by Unlocking Resources in Education Act (FUTURE Act) in 2019, and the 

FAFSA Simplification Act in 2020. Together they transform how student aid is delivered and 

simplify how students and families engage with the federal student aid programs. Among other 

things, the new FAFSA replaces the Expected Family Contribution with the Student Aid Index, 

revamps the Federal Pell Grant eligibility formula, and allows income information to be obtained 

directly and automatically from the Internal Revenue Service.

FSA continues to improve its customer service with enhanced StudentAid.gov user 

experience, hands-on partner engagement, and modernized organizational capabilities. One 

notable upgrade was made to the Federal Student Aid Estimator, which accurately estimates 

the level of aid for which students and parents are eligible. This tool will prove quite helpful as 
Fiscal Year 2023 Annual Report | Federal Student Aid vii

Introduction

(Unaudited)

the new FAFSA form is delivered in December 2023, by helping families engage in advance 

planning on their financial obligations if they wish to do so.

In the spring of 2023, FSA launched a key update to the PSLF Help Tool to make it much easier 

for public servants to apply for the program. Borrowers can now digitally sign and submit their 

PSLF form, identify employers that need to sign their form and send them requests for esignature, and track the status of their PSLF form in their accounts. As a result, borrowers can 

now complete the entire application process digitally on StudentAid.gov. 

FSA also took a major step in April toward modernizing federal student loan servicing by 

awarding the Next Gen FSA agreements. These contract awards were made through our 

Unified Servicing and Data Solution (USDS) procurement to develop the infrastructure, training, 

and procedures to comply with new requirements and meet the needs of approximately 

37 million borrowers with federally managed student loans. USDS is the long-term loan 

servicing solution designed to deliver high-quality customer experience and help reduce 

delinquency and default.

In FY 2023, FSA continued its drive toward greater school accountability within the federal 

student aid programs. Schools that engage in wrongdoing are being held responsible for their 

abuses by our renewed FSA Enforcement Office, which has reinforced our oversight work and 

helped diminish risks to students and taxpayers. One marker of the revitalized Enforcement 

Office is that it has helped nearly 1.1 million borrowers get approved for $14.8 billion in loan 

forgiveness either through borrower defense to repayment or closed school loan discharges. 

These efforts are giving borrowers relief from their schools' wrongdoing or sudden closure. 

In closing, let me recognize the work undertaken by our FSA colleagues this year to respond to 

several natural disasters—from hurricanes to typhoons, wildfires, floods, and landslides. Our

teams helped organize recovery efforts, reached out to those affected, monitored the aftermath 

of these disasters, and provided the support that schools and students needed to help them 

recover.

As always, however, we know that FSA has much work to do. We invite you to read this report 

to learn more about our plans and actions to help this country move confidently into the future.

Sincerely,

Richard Cordray

Chief Operating Officer

Federal Student Aid

United States Department of Education

November 16, 2023
viii Fiscal Year 2023 Annual Report | Federal Student Aid

Introduction

(Unaudited)

About This Report

FSA, a principal office of the United States (U.S.) Department of Education (Department), is 

required by law to produce an annual report, which details the organization’s fiscal year financial 

and program performance. The Federal Student Aid FY 2023 Annual Report (Annual Report) is 

a comprehensive document that provides an analysis of FSA’s financial and program 

performance results for FY 2023 and exhibits the organization’s effectiveness in accomplishing 

its mission. The Annual Report enables the President of the United States, the U.S. Congress, 

and the public to assess the organization’s performance relative to its mission and to determine 

whether FSA has shown itself to be accountable for the resources entrusted to it. 

This report presents information about FSA’s performance as a Performance-Based 

Organization (PBO), along with its initiatives, accomplishments, and challenges, as required by

the U.S. Office of Management and Budget (OMB) Circular A-11, Preparation, Submission and 

Execution of the Budget, Part 6, Section 260, and Circular A-136, Financial Reporting 

Requirements. The report also satisfies various requirements included in the following federal 

statutes:

• Higher Education Act of 1965, as amended

• Federal Managers’ Financial Integrity Act of 1982

• Chief Financial Officers Act of 1990

• Federal Credit Reform Act of 1990

• Government Performance and Results Act of 1993

• Government Management Reform Act of 1994

• Federal Financial Management Improvement Act of 1996

• Reports Consolidation Act of 2000

• Improper Payments Information Act of 2002, amended

• Government Performance and Results Modernization Act of 2010

• Improper Payments Elimination and Recovery Act of 2010

• Improper Payments Elimination and Recovery Improvement Act of 2012

• Payment Integrity Information Act of 2019

The Department produces the U.S. Department of Education FY 2023 Agency Financial 

Report (AFR), which provides a comprehensive view of the Department’s stewardship of its 

resources and includes a summary of the information contained in this Annual Report. 

The Annual Report is available at StudentAid.gov/strategic-planning-reporting.
Fiscal Year 2023 Annual Report | Federal Student Aid ix

Introduction

(Unaudited)

Overview of the Federal Student Aid Annual Report

The Annual Report is organized into the following sections: 

Management’s Discussion and Analysis

This section provides an overview of the Annual Report and includes 

forward-looking information, the mission and organizational structure, 

highlights of performance management details, financial statement analysis 

with financial management highlights, and a discussion of FSA’s systems, 

controls, and compliance with laws and regulations. 

Annual Performance Report

This section discusses the strategic goals included in the Federal Student 

Aid Five-Year Strategic Plan for Fiscal Years 2023–27 (FY 2023–27

Strategic Plan), its strategic objectives, performance indicator results, and 

fiscal year accomplishments. 

Additional Required Reporting

This section includes the additional reports specifically required by the 

Higher Education Act of 1965, as amended (HEA). 

Financial Reporting Section 

This section includes the Consolidated Balance Sheet, related notes, and 

the report from the independent auditors. 

Other Information 

This section includes the unaudited financial statements and related notes, 

required supplementary information, a summary of the financial statement 

audit, links to the summary of management assurances and FSA’s 

Management Challenges in the Department’s AFR, and Payment Integrity 

Information Act reporting details. 

Appendices

This section includes the discontinued or revised items of the FY 2023–27

Strategic Plan, the data validation and verification of performance 

information, the glossary of acronyms and terms, and the availability of the 

Annual Report. 
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Management’s Discussion and Analysis

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Management’s Discussion and 

Analysis (Unaudited)
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Fiscal Year 2023 Annual Report | Federal Student Aid 3

Management’s Discussion and Analysis

(Unaudited) 

Overview of Management’s Discussion and Analysis

Management’s Discussion and Analysis provides an overview of the Annual Report. It includes 

the following subsections: 

• Fiscal Year 2023 Organizational Highlights: Fiscal Year 2023 Organizational 

Highlights present Looking Forward at Federal Student Aid, which details the most 

important events and challenges that FSA faces and discusses the actions taken and 

progress made by FSA in addressing those challenges. This subsection also includes a 

presentation of Federal Student Aid by the Numbers. 

• Mission and Organizational Structure: Mission and Organizational Structure provides 

the history of FSA; its mission, organizational structure, vision, and core values. The 

section also includes discussion of the federal student aid programs.

• Performance Management: Performance Management presents an overview of FSA’s 

strategic planning and performance management framework. This subsection includes 

an overview of the FY 2023–27 Strategic Plan, a discussion of the agency priority goals 

and the quality of FSA’s performance data. 

• Analysis of Financial Statements: Analysis of Financial Statements provides an 

overview of FSA’s financial data, an analysis of the financial data presented in the 

financial statements, the limitations of financial statements and FSA’s financial 

management highlights. 

• Analysis of Systems, Controls, and Legal Compliance: Analysis of Systems, 

Controls, and Legal Compliance provides FSA’s management assessment in 

conjunction with the Department’s assessment on FSA’s internal controls related to the 

Federal Manager’s Financial Integrity Act of 1982 and its compliance with other laws and 

regulations related to the compliance of financial systems with federal requirements.
4 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Fiscal Year 2023 Organizational Highlights

Looking Forward at Federal Student Aid

In FY 2023, FSA continued to adjust its operations to align with the administrative priorities and 

ascend from the lingering impacts the national COVID-19 emergency pressed on the programs 

authorized by Title IV of the Higher Education Act of 1965, as amended by (Title IV). While 

maneuvering in an ever-changing environment, FSA maintained its focus on supporting 

students, families, and borrowers as they navigate the financial aid process.

FSA implemented customer and stakeholder outreach campaigns that provided repayment 

options and loan forgiveness information to better inform students and borrowers, resulting in 

positive repayment outcomes and reduced defaults. These activities included the always-on 

email campaigns, such as Targeted Early Delinquency Intervention (TEDI), Third-Party Debt 

Relief (TPDR) scam intervention, and borrower risk at time of disbursement, and aim to reduce 

future delinquency and default; supporting policymakers at the Department, OMB and Congress 

with analysis and modeling on options for the repayment process; and generating Direct to 

Discharge (D2D) files for Public Service Loan Forgiveness (PSLF) and Income-Driven 

Repayment (IDR) Account Adjustment, which led to full forgiveness for many borrowers and 

additional months of credit toward forgiveness for many others.

During FY 2023, FSA unveiled new features to support the digital repayment experience on 

StudentAid.gov, including a new IDR application, the new Saving on a Valuable Education 

(SAVE) IDR plan, a new loan consolidation application, an electronic signature (e-signature) 

and submission solution for the PSLF form, and the ability to view the status of an IDR 

application, loan consolidation application, and PSLF form in a customer’s dashboard and My 

Activity.

Additionally, to prevent confusion, FSA added plain-language information which clarifies the 

SAVE Plan repayment option for student loan borrowers, timelines, and processes to prepare 

for returning to repayment, details about the limited PSLF waiver, and an introduction to the 

Fresh Start option for defaulted borrowers.
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 5

Management’s Discussion and Analysis

(Unaudited) 

Federal Student Aid by the Numbers 

Figure 1: FSA Net Outlays1

FY 2019–23

Figure 2: FSA Administrative Budget

FY 2019–23

Figure 3: FSA Student Loan Portfolio2

FY 2019–23

1 The Budgetary account is also known as the Program account; the Non-budgetary credit reform account is also known as the 

Financing account. For more information on these two accounts, please refer to Note 5.

2 The amounts in Figure 3 include both lender-held FFEL loans and School-held Perkins loans.

$57.3 $147.3 $164.2 

$511.2 

$(158.8) $40.1 $(43.0) $(38.7) $(382.4)

$296.6 

2019 2020 2021 2022 2023

Dollars in Billions

Budgetary (Program Account) Non-Budgetary Credit Reform (Financing Account)

$1.7 

$1.8 

$1.9 $1.9 

$2.0 

2019 2020 2021 2022 2023

Dollars in Billions

 

 

 

 

 

 
6 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Figure 4: Total FAFSA® Forms Processed and Total Students Receiving Aid

FY 2019–23

Figure 5: Total Federal Student Aid Delivered

FY 2019–23

Figure 6: FSA Federal Employees3

FY 2019–23

3 Number of employees listed is as of September 30 of each fiscal year.

18.0 17.8 17.6 16.9 17.5

10.4 10.8 10.1 9.8 9.7

2019 2020 2021 2022 2023

in Millions

Total Applications Processed Total Postsecondary Students Receiving Aid

$121.8 

$115.6 

$112.0 $111.6 

$114.1 

2019 2020 2021 2022 2023

Dollars in Billions

1,251

1,462 1,416

1,356 1,406

2019 2020 2021 2022 2023
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 7

Management’s Discussion and Analysis

(Unaudited) 

Mission and Organizational Structure

Mission

FSA, a principal office of the U.S. Department of Education (the Department), seeks to ensure 

that all eligible individuals can benefit from federal financial assistance for education beyond 

high school. As the nation’s largest provider of federal student financial aid, FSA is responsible 

for implementing and managing federal student financial assistance programs authorized under 

the Higher Education Act of 1965, as amended (HEA). Title IV of the HEA specifically authorizes 

the federal student financial assistance programs for which FSA is responsible. These programs 

provide grants, loans, and work-study funds to students attending colleges or career and 

technical schools.

To execute the Title IV programs, FSA is responsible for a range of functions across the student 

aid lifecycle, which include: 

• informing students and families about the availability of the federal student aid programs 

and the process of applying for and receiving aid from those programs, 

• developing the Free Application for Federal Student Aid® (FAFSA®) form and processing 

millions of FAFSA forms each year, 

• accurately disbursing, reconciling, and accounting for billions of dollars of federal student 

aid funds delivered to students annually, 

• managing the outstanding federal student loan portfolio and securing repayment from 

federal student loan borrowers, 

• offering free assistance to students, parents, and borrowers throughout the entire 

financial aid process, 

• informing borrowers about loan forgiveness programs and helping borrowers access the 

forgiveness for which they are eligible, and

• providing oversight and monitoring of all program participants—schools, financial 

entities, and students—to ensure compliance with the laws, regulations, and policies 

governing the federal student aid programs.

This complex, multifaceted mission calls on a range of staff skills, and demands coordination by 

all levels of management. Designated as a Performance-Based Organization (PBO) by 

Congress in 1998, FSA emphasizes tangible results and efficient performance, as well as 

continuous improvement of the processes and systems that support its mission.
8 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Organizational Structure

FSA currently operates under a functional organizational structure that aligns the key business 

areas with its strategic goals, business objectives, and vision. A Chief Operating Officer (COO), 

who is appointed by the Secretary of Education leads FSA, with four Deputy COOs as leaders 

over distinct operational areas. In 2021, the Secretary appointed Richard Cordray as FSA’s

Chief Operating Officer. The figure below illustrates the functional organizations within FSA.

Figure 7: FSA Organizational Chart 
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 9

Management’s Discussion and Analysis

(Unaudited) 

During FY 2023, FSA operated on an annual administrative budget of approximately $2.0 billion.

As of September 30, 2023, FSA was staffed by 1,406 full-time employees and augmented by 

contractors who provide outsourced business operations. The workforce is primarily based in 

FSA’s headquarters located in Washington, DC, with 10 regional offices located throughout the 

country as reflected in the following graphic (See Figure 8). The number of full-time employees 

at each location is shown in parentheses immediately following the location name.

Figure 8: FSA Regional Map
10 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Mission, Vision, and Core Values

FSA’s mission focuses on students. This mission drives the organization’s vision to be a reliable 

provider of federal student aid and services and to be the most trusted source of postsecondary 

education information to students and their families. As part of its vision, FSA strives to assist 

students and families in making better decisions about their postsecondary education funding 

options. The core values reflect a culture of integrity, excellence, and collaboration—key 

components in building a high-performing organization.

Table 1: FSA Mission, Vision, and Core Values

MISSION

Mission Funding America’s Future, One Student at a Time. 

VISION

Vision To be the most trusted and reliable source of student 

financial aid, information, and services in the nation.

CORE VALUES

Integrity Do the right thing regardless of personal interests and hold 

everyone accountable.

Diversity

Develop a team that is reflective of our nation’s diverse 

tapestry of cultures, backgrounds, geographies, and 

experiences.

Customer Service Provide accurate and timely information to customers and 

support to colleagues, customers, and partners. 

Excellence 

Strive to deliver effective programs, products, and services 

by adapting to change and continuously improving 

business practices and processes. 

Respect Treat individuals with dignity and gratitude by 

acknowledging their contributions, ideas, and talents.

Collaboration Coordinate cohesively with colleagues, customers, and 

partners to produce enterprise-focused solutions.

As discussed in detail in the Performance Management subsection and Annual Performance 

Report section, FSA has translated this vision into a set of clearly defined strategic goals and 

objectives, with related measurable performance indicators. The realization of these goals will 

enable the organization to accomplish its mission successfully.
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 11

Management’s Discussion and Analysis

(Unaudited) 

Significant Legislation that Directs the FSA Mission

Several legislative acts guide FSA’s mission. The HEA established FSA as a PBO to administer 

the Title IV programs. The following table, while not all-inclusive, identifies legislation that has 

significantly influenced FSA’s mission.

Table 2: Overview of Legislative Authority

Legislation Purpose

Higher Education Act of 1965, as amended Created the federal student financial assistance 

programs known as Title IV programs.

Student Loan Reform Act of 1993 Authorized a multi-year phased implementation of the 

William D. Ford Federal Direct Loan Program. 

Higher Education Reconciliation Act of 2005 Allowed graduate and professional students to use the 

Parent Loan for Undergraduate Studies Loan 

Program. 

College Cost Reduction and Access Act of 2007 Authorized the Teacher Education Assistance for 

College and Higher Education Grant Program, created 

the Public Service Loan Forgiveness Program, and 

established Income Based Repayment plans.

Ensuring Continued Access to Student Loans Act of 

2008

Provided the Department with the authority to 

implement programs to ensure eligible students and 

parents were not denied access to federal student 

loans during the credit market disruptions of 2008.

SAFRA Act of 2009 Provided that, beginning July 1, 2010, no new loans 

would be originated under the Federal Family 

Education Loan Program.

Bipartisan Student Loan Certainty Act of 2013 Established that federal student loan interest rates will 

be tied to financial markets and that each loan will 

have a fixed interest rate for the life of the loan.

Consolidated Appropriations Act, 2014 Transferred all Health Education Assistance Loan 

Program loans as of July 1, 2014, from the U.S. 

Department of Health and Human Services to the 

Department.

Fostering Undergraduate Talent by Unlocking 

Resources for Education Act, 2019

Reauthorized mandatory funding programs for 

historically black colleges and universities and other 

minority-serving institutions.

Coronavirus Response and Relief Supplemental 

Appropriations Act, 2021 

Established the Free Application for Federal Student 

Aid (FAFSA) simplification and expanded Federal Pell 

Grant Program eligibility. 

FSA Stakeholders

The community of stakeholders in the student aid delivery system includes students, parents, 

lenders, guaranty agencies (GAs), postsecondary institutions, and contracted servicers, as well 

as taxpayers and other federal entities such as Congress and OMB.

FSA’s responsibilities include coordinating and monitoring the activity of the large number of 

federal, state, nonprofit, and private entities involved in delivering federal student aid within the 

statutory framework established by Congress and regulatory framework established by the 
12 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Department. The following table displays the role of FSA and the participants in the FSA 

system.

Table 3: Role of FSA and Participants in the FSA System 

Participants Participants’ Role FSA’s Engagement with Participants

Students • Receive aid to finance postsecondary 

education and repay loans following 

completion or exit from school. 

• Explaining federal student aid 

opportunities and requirements, 

• Providing products, services, and tools to 

help students pay for postsecondary 

education, 

• Identifying students who are eligible for 

aid, and

• Protecting students and borrowers from 

unfair, deceptive, or fraudulent practices 

in the student aid marketplace.

Guaranty Agencies • Insure Federal Family Education 

Loan Program loans and service their 

defaulted loan portfolios. 

• Monitoring compliance, 

• Assisting them in meeting regulatory 

requirements, 

• Providing technical assistance, and 

• Paying default claims.

Loan Holders • Hold and service outstanding Federal 

Family Education Loan Program

loans to students.

• Monitoring compliance, 

• Assisting them in meeting requirements, 

• Providing interest subsidies and Special 

Allowance Payments, and 

• Educating them regarding policy.

FSA-Contracted Loan 

Servicers

• Service William D. Ford Federal 

Direct Loan Program portfolio and 

portions of Federal Family Education 

Loan Program portfolio, 

• Provide systems and services to 

support FSA’s core operations (e.g., 

applications, disbursements), and

• Recover funds from defaulted loans.

• Entering contractual agreements, 

• Setting performance standards, and

• Overseeing operations.

Postsecondary 

Institutions

• Determine students’ aid packages 

and disburse funds.

• Determining eligibility and disbursing aid, 

• Monitoring compliance and regulatory 

requirements, and

• Providing technical assistance.

Congress • Sets statutory requirements for 

student loan programs as well as a 

myriad of borrower benefits and 

budget appropriations. 

• Providing data and information for 

decision-making and

• Providing updates on operational 

performance.

The President, the 

Department, and 

others in the Executive 

Branch

• Set regulatory standards and 

establish policy for the distribution of 

aid and collection of loan payments. 

• Providing data that informs policy 

decisions, 

• Providing recommendations for 

implementation of new policies, and

• Sharing information regarding high-risk 

compliance concerns. 
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 13

Management’s Discussion and Analysis

(Unaudited) 

Federal Student Financial Aid Programs 

Each year, FSA delivers billions of dollars in financial aid to students through the Title IV

programs of the HEA. These programs collectively represent the nation’s largest source of 

federal financial aid for postsecondary education students. This aid covers expenses such as 

tuition and fees, room and board, books and supplies, and transportation. Federal financial aid 

is mainly distributed to students through: 

• Loans: Student aid funds that are borrowed to help pay for eligible education programs 

and must be repaid with interest, 

• Grants: Student aid funds that do not have to be repaid, unless other conditions apply, 

and

• Work-Study: Part-time employment program that allows students enrolled in college to 

earn money to help pay for school.

To obtain federal financial aid, prospective aid recipients must complete the FAFSA form. In 

FY 2023, FSA processed more than 17.5 million FAFSA forms, resulting in the delivery of 

approximately $114.1 billion in Title IV aid to more than 9.7 million postsecondary students and 

their families. These students attended more than 5,400 active institutions of postsecondary 

education that participate in federal student aid programs, and which are accredited by agencies

recognized by the Secretary. 

The following table presents a comparison of the amounts of Title IV aid disbursed to students 

by program in FY 2023 and FY 2022. A summary discussion of each Title IV program is 

presented in the paragraphs after the table.
14 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Table 4: Summary of Federal Aid Disbursed to Students by Program4

(Dollars in Millions) 

Programs

2023 Aid 

Disbursed to 

Students

2022 Aid 

Disbursed 

to Students

Difference Percentage 

Change

Federal Loan Program

William D. Ford Federal Direct Loan Program $ 83,295.3 $ 83,450.6 $ (155.3)

 

(0.2)%

Federal Grant Programs

Federal Pell Grant Program $ 28,689.2 $ 26,129.5 $ 2,559.7 9.8% 

Federal Supplemental Educational Opportunity 

Grant Program 893.8 866.5 27.3 3.2% 

The Teacher Education Assistance for College and 

Higher Education Grant Program 82.1 57.4 24.7 43.0% 

Iraq and Afghanistan Service Grant Program 0.6 0.5 0.1 20% 

Subtotal Grant Programs $ 29,665.7 $ 27,053.9 $ 2,611.8 9.7% 

Federal Work-Study Program

Federal Work-Study Program $ 1,150.2 $ 1,106.2 $ 44.0 4.0% 

Grand Total $ 114,111.2 $ 111,610.7 $ 2,500.5 2.2% 

Federal Loan Programs

In fulfilling its program responsibilities, FSA directly manages or oversees a loan portfolio of 

more than $1.6 trillion, representing approximately 219.9 million student loans to more than 

45.5 million borrowers. These loans were made primarily through the first two federal student 

loan programs described below.

The William D. Ford Federal Direct Loan (Direct Loan) Program lends funds directly to 

students and parents through participating schools. Created in 1993, this program is funded 

primarily by borrowings from the U.S. Department of the Treasury (Treasury), as well as an 

appropriation for subsidy costs. Four different types of Direct Loans are available for borrowers: 

• Direct Subsidized Loans: Federal loans based on financial need made to 

undergraduate students for which the federal government generally does not charge 

interest while the borrower is in school, in grace, or in deferment status. If the interest is 

not paid during the grace period, the interest is added to the loan’s principal balance.

• Direct Unsubsidized Loans: Federal loans made to undergraduate students and 

graduate students for which the borrower is fully responsible for paying the interest 

4 Aid disbursed to students as cited in the table above, and in the following sections concerning the Federal Loan Programs, the 

Federal Grant Programs, and the Federal Work-Study Program in the Management’s Discussion and Analysis are fiscal year 

amounts derived from amounts from FSA’s and the Department’s financial systems. The number of awards or recipients reported in 

the Management’s Discussion and Analysis is derived from a variety of sources including FSA’s Common Origination and 

Disbursement System and data used to support the President’s Budget. Recipient counts are based on award year.
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 15

Management’s Discussion and Analysis

(Unaudited) 

regardless of the loan status. Interest on unsubsidized loans accrues from the date of 

disbursement and continues throughout the life of the loan.

• Direct Parent Loans for Undergraduate Students (PLUS) Loans: Federal loans 

made to graduate or professional students and parents of dependent undergraduate 

students for which the borrower is fully responsible for paying the interest regardless of 

the loan status.

• Direct Consolidation Loans: Federal loans that allow the borrower to combine multiple 

existing federal student loans into one new loan. The borrower will only have to make 

one monthly payment on the consolidation loan, and the repayment term of the loan may 

be longer than the terms of the original loans, which may result in a lower monthly 

payment. 

As of September 30, 2023, FSA’s portfolio of Direct Loans included $1,030.9 billion in credit 

program receivables, net. In FY 2023, the Department made $83.3 billion5 in net loans to 

6.8 million recipients.

Under the Federal Family Education Loan (FFEL) Program, students and parents obtained 

federal loans through private lenders. Guaranty Agencies (GAs) insure lenders against borrower 

default; the federal government, in turn, reinsures the GAs. Federal subsidies ensure private 

lenders earn a certain yield on the loans they hold. 

The passage of the SAFRA Act, which was included in the Health Care and Education 

Reconciliation Act of 2010 (HCERA) (Pub. L. 111-152), ended the origination of new FFEL 

Program loans as of July 1, 2010. Nevertheless, FSA, lenders, and GAs continue to service and 

collect outstanding FFEL Program loans. FSA, FFEL lenders, and GAs held a FFEL Program 

loan portfolio of approximately $99.7 billion as of September 30, 2023. Of this portfolio, 

$39.3 billion represented FSA’s credit program receivables, net, comprised of $27.5 billion in 

loans acquired under the Ensuring Continued Access to Student Loans Act of 2008 (ECASLA)

authorization and $11.8 billion acquired under the "traditional" (Non-ECASLA) guaranteed loan 

program. In FY 2023, FSA made gross payments of approximately $1.7 billion to lenders for 

interest and special allowance subsidies and $5.2 billion to GAs for reinsurance claims and fees 

paid for account maintenance, default aversion, and collection activities.

ECASLA authorized the Department to implement several programs to ensure credit market 

disruptions did not deny eligible students and parents the access to federal student loans for the 

2008–09 and 2009–10 academic years. The authority for two ECASLA Programs, the Loan 

Purchase Commitment Program, and the Loan Participation Interest Purchase Program, expired 

after September 30, 2010. The third ECASLA Program, the Asset-Backed Commercial Paper

Conduit (ABCP Conduit) Program, ended in January 2014. 

The Federal Perkins Loan Program was one of three campus-based student aid programs.

These federal loans were made by schools to undergraduate and graduate students who 

demonstrate financial need. Historically, participating schools received a certain amount of 

funds each year from FSA for distribution under this program, which supplemented funds in a 

school’s revolving fund, from which new disbursements were made. These funds enabled 

eligible institutions to offer low-interest loans to students based on financial need. Once the full 

amount of the school’s funds had been awarded to students, no additional loans were to be 

5 Excludes consolidation loans of $37.8 billion.
16 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

made under this program for the year. The Federal Perkins Loan Program Extension Act of 

2015 eliminated the authorization for schools to make new Federal Perkins loan disbursements 

as of September 30, 2017, and ended all Perkins loan disbursements by June 30, 2018. 

The Health Education Assistance Loan (HEAL) Program was transferred to the Department 

from the U.S. Department of Health and Human Services in FY 2014 under the Consolidated 

Appropriations Act, 2014 (Pub. L. 113-76). This program enabled graduate students in schools 

of medicine, osteopathy, dentistry, veterinary medicine, optometry, podiatry, public health, 

pharmacy, chiropractic, or programs in health administration and clinical psychology to obtain 

federally insured loans through participating lenders. Since September 30, 1998, no new loans 

have been originated through this program; however, borrowers are still obligated to repay any 

outstanding loans obtained through the program.

The Department assumed responsibility for the program and the authority to administer, service, 

collect, and enforce the loans. Credit program receivables, net of allowance for subsidy, were 

approximately $388.1 million for FY 2023. 

Federal Grant Programs

In fulfilling its responsibility for administering Title IV aid, FSA oversaw the disbursement of 

approximately $29.7 billion in grants to approximately 6.0 million recipients. The following 

provides a summary for each grant program, including aid disbursed in FY 2023. 

The Federal Pell Grant (Federal Pell Grant) Program helps ensure financial access to 

postsecondary education by providing grant aid to low-income and middle-income 

undergraduate students. Considered the foundation of a student’s financial aid package, 

Federal Pell Grants vary according to the financial circumstances of students and their families. 

In FY 2023, the Department disbursed approximately $28.7 billion in Federal Pell Grants 

averaging approximately $4,782 to approximately 6.0 million students. The maximum Federal 

Pell Grant award was $6,895 in the 2022–23 award year and increased to $7,395 in the 2023–

24 award year. 

The Federal Supplemental Educational Opportunity Grant Program is one of three campusbased programs through which the Department provides funds directly to eligible institutions. 

Funds provided through this program enable eligible institutions to offer grants to students 

based on need. Federal grants distributed under this program are administered directly by the 

financial aid office at each participating school. Each participating school receives a certain 

amount of Federal Supplemental Educational Opportunity Grant funds each year from FSA.

Once the full amount of the school’s grant funds has been awarded to students, no additional

awards can be made under this program for the year. This form of aid does not require 

repayment. In FY 2023, approximately $893.8 million were disbursed through approximately 

1.7 million campus-based awards.

The Teacher Education Assistance for College and Higher Education (TEACH) Grant

Program provides individual awards up to $4,000 per year to students agreeing to teach 

mathematics, science, or other specialized subjects in a high-poverty school for at least four 

years within eight years of their graduation. This grant program began in the 2008–09 school 

year, starting July 1, 2008. For any award year 2022–23 or 2023–24 TEACH Grant first 

disbursed on or after October 1, 2022, and before October 1, 2023, the maximum award is 

$3,772. For any award year 2023–24 TEACH Grant first disbursed on or after October 1, 2023, 
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 17

Management’s Discussion and Analysis

(Unaudited) 

and before October 1, 2024, the maximum award is $3,772. If students fail to fulfill the service 

requirements specific to the program, their TEACH Grants convert to Direct Unsubsidized 

Loans, with interest accruing from the time of the award. During FY 2023, there were

approximately 2,879 involuntary conversions and 9,250 voluntary conversions from TEACH 

grant status to direct unsubsidized loans. Those grantees who are involuntarily converted to 

loan status have the right to appeal an involuntary conversion. During FY 2023, there were 

approximately 187 reinstatements from loan status back to grant status. In FY 2023, the 

Department disbursed more than 22,000 grants totaling $82.1 million under the TEACH Grant 

Program. 

The Iraq and Afghanistan Service Grant Program, which became effective July 1, 2010, 

provides non-need-based grants to students whose parent or guardian was a member of the 

Armed Forces and died in Iraq or Afghanistan because of military service after

September 11, 2001. These grants are awarded to students who are not eligible for a Federal 

Pell Grant based on financial need, but meet the remaining Federal Pell Grant eligibility 

requirements, and:

• Have a parent or guardian who was a member of the U.S. Armed Forces and died as a 

result of military service in Iraq or Afghanistan after the 9/11 events, and

• Were under 24 years old or enrolled in college at least part-time at the time of the parent 

or guardian’s death.

For any award year 2022–23 Iraq and Afghanistan Service Grant first disbursed on or after 

October 1, 2022, and before October 1, 2023, the maximum award is approximately $6,501. For

any award year 2023–24 Iraq and Afghanistan Service Grant first disbursed on or after 

October 1, 2023, and before October 1, 2024, the maximum award is up to $6,973.49. The 

Department disbursed approximately $0.6 million to support fewer than 100 awards in FY 2023. 

Federal Work-Study Program

The Federal Work-Study Program is one of three campus-based programs through which the 

Department provides funds directly to eligible institutions. Funds provided through this program 

enable eligible institutions to offer part-time employment to undergraduate, graduate, and 

professional students based on financial need, allowing them to earn money to help pay 

education expenses. The program is available to full-time or part-time students and encourages 

community service work. The work is often related to the student’s course of study. In FY 2023, 

approximately $1.2 billion were disbursed through approximately 660,000 campus-based 

awards. 
18 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Performance Management

The Performance Management section of the Annual Report provides a general overview of the 

performance management processes at FSA. The foundation of performance management 

within FSA is the five-year strategic plan. The key strategic drivers relevant to the strategic 

planning process within FSA are listed below.

Table 5: Key Strategic Drivers Relevant to FSA Strategic Planning

Key Strategic Driver Relevance to FSA’s Strategic Planning Process 

The Higher Education Act of 1965 legislation

and Department regulations 

Prescribes Title IV program and PBO requirements (i.e., 

improve service, reduce costs, improve and integrate support 

systems, develop delivery and information systems, and 

enhance staff development and talent). 

Student and borrower needs Students and borrowers are key customers of FSA services 

and products. 

Key external and internal factors that influence 

FSA’s operations.

Indicate student aid environment within which FSA must 

operate. Listed below are key factors that may affect the 

student aid operational environment.

• Legislative mandates that guide FSA’s operational 

priorities. 

• Priorities set by the Department and FSA leadership.

• Input collected through FSA’s multiple customer 

feedback channels.

• GAO/OIG recommendations to improve operational 

efficiencies. 

The Department’s Five-Year Strategic Plan Require FSA’s support of the Department’s strategic goals 

related to postsecondary education.

Office of Inspector General’s (OIG)

Management and Performance Challenges 

Require the Department and FSA senior management’s 

consideration for establishing priorities. OIG’s Management 

Challenges for FY 2023 include:

• Implementing Pandemic Relief Laws, 

• Oversight and Monitoring,

• Data Quality and Reporting,

• Improper Payments, and

• Information Technology Security. 

OIG and Government Accountability Office 

(GAO) audits 

Require FSA senior management’s consideration for 

establishing priorities to address findings and 

recommendations. 

Federal financial management laws and 

regulations 

Prescribe financial management requirements. 

Federal performance reporting legislation and 

requirements 

Prescribe performance and reporting requirements. 

Federal budget deficits Require FSA to look for opportunities to reduce operating 

costs through improved efficiency. 
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 19

Management’s Discussion and Analysis

(Unaudited) 

The key strategic drivers inform the strategic planning process, aligning FSA with the PBO 

requirements outlined in the HEA while ensuring future consistency and accountability. The key 

strategic drivers influence the development and implementation of FSA’s strategic plan, as well 

as the development and tracking of performance indicators. The Performance Management 

section discusses the following:

• FSA’s performance management processes,

• FSA’s FY 2023–27 strategic goals,

• FSA’s alignment to the Department of Education Strategic Plan for Fiscal Year 2022–26

(FY 2022–26 Strategic Plan), and

• FSA’s efforts to validate the quality of performance data reported.

Figure 9 provides a summary of the strategic plan elements that are fundamental to the 

development and execution of the five-year strategic plan. 

Figure 9: Strategic Process Building Blocks

 
20 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Performance Management Processes at Federal Student Aid

During FY 2023, FSA used a multifaceted performance management framework to establish 

goals and communicate, measure, and report performance, including the following elements:

• FSA FY 2023–27 Strategic Plan

• Weekly Organization Briefings

• Executive Management Monthly Report

• FSA Bi-Weekly Report

• Annual Performance Report

• Department’s Quarterly and Annual Performance Reviews

• Agency Priority Goals (APGs)

FSA FY 2023‒27 Strategic Plan

The FY 2023–27 Strategic Plan outlines goals, objectives, and performance indicators that 

provide a roadmap for how FSA will successfully operate, respond to change, and execute its 

mission moving forward. These strategic goals collectively provide the framework for continuous 

improvement at FSA; guide the organization in managing its programs more effectively; and 

offer clear strategic direction to all of FSA’s internal and external constituencies. To provide the 

best framework to effectively achieve these outcomes, the five-year strategic goals must be:

• Appropriate to the mission of the organization,

• Realistic and measurable,

• Achievable in the time frame established,

• Challenging in their performance targets, and

• Understandable to the layperson with language that is unambiguous and terminology

that is sufficiently defined.

Each strategic goal encompasses objectives and identifies performance indicators to measure 

FSA’s level of success in meeting the strategic goal. For each performance indicator, FSA 

identifies a target level of performance for each fiscal year. FSA sets the target level of 

performance at a challenging, but realistic level that is achievable within the timeframe. Meeting 

or exceeding the target indicates that FSA succeeded in attaining the established performance 

indicator, while falling short of the target indicates that FSA did not attain the performance 

indicator.
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 21

Management’s Discussion and Analysis

(Unaudited) 

The FY 2023–27 Strategic Plan outlines strategic goals and objectives that are used to track 

and evaluate FSA’s progress toward meeting its mission. The following table provides an 

abbreviated view of the current strategic framework.

Table 6: Strategic Goals and Strategic Objectives for FY 2023‒27

Strategic Goal 1 Strategic Objectives

Improve Customer Service and Outcomes 

for Students and Borrowers

1.1: Simplify the student loan repayment process to reduce future 

delinquency and default rates and improve accessibility of loan 

forgiveness programs.

1.2: Enhance the quality of contact center and loan servicing 

operations, leveraging data to assess progress toward customer 

service and product delivery standards.

1.3: Engage with stakeholders to improve delivery of student aid.

1.4: Address complaints and inquiries regarding financial aid 

products and services.

Strategic Goal 2 Strategic Objectives

Advance Equity and Access to Student 

Financial Assistance 

2.1: Enable financial education and empowerment by helping 

students and families understand the benefits and 

responsibilities of financing post-secondary education.

2.2: Simplify the Free Application for Federal Student Aid 

(FAFSA)

®process.

2.3: Provide accurate, seamless, easy, and customized interactions 

throughout the student aid lifecycle.

Strategic Goal 3 Strategic Objectives

Strengthen Engagement and 

Accountability for Educational and 

Financial Institutions

3.1: Utilize a comprehensive suite of monitoring tools to oversee 

participating partners.

3.2: Build enforcement capabilities, in coordination with federal and 

state partners, to protect students, families, and taxpayers from 

deceptive, fraudulent, or harmful practices in the student aid 

marketplace. 

3.3: Provide inclusive and effective partner outreach, training, and 

technical assistance.

Strategic Goal 4 Strategic Objectives

Increase Workforce and Workplace 

Capabilities

4.1: Promote workplace diversity, equity, inclusion, and accessibility.

4.2: Attract, develop, and retain an agile workforce that can quickly 

respond to a changing environment and emerging priorities. 

4.3: Foster an organizational culture that promotes a productive, 

connected, and engaged workforce, particularly in a hybrid 

workplace environment.

Strategic Goal 5 Strategic Objectives

Boost Operational Efficiency

5.1: Strengthen enterprise-wide data analytics and information 

management to foster a customer-centric, data-driven, 

performance-based organization.

5.2: Continuously improve systems, structures, and operations to 

enhance organizational efficiency and performance.

5.3: Enhance procurement planning, management, and execution.

5.4: Improve cybersecurity detection, prevention, and protection 

ensuring data confidentiality, integrity, and availability.
22 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Weekly Organization Briefings

The Organization Briefings in FY 2023 have continued to enhance the strategic alignment within 

FSA in operations, products, and accountability in achieving results. These sessions provide 

awareness of and engagement in FSA’s priority projects and initiatives, with topics aligned with 

the strategic plan. Discussions in the briefings enabled attendees to make strategic connections 

between the work that is performed throughout FSA and its impact on its stakeholders, and 

these briefings contributed to the development of the FY 2023 Annual Report. 

To further advance FSA’s strategic framework, the Organization Briefings established various 

themes that illustrated the efforts of specific business areas in advancing the goals and 

objectives of the FY 2023-27 Strategic Plan. The Organization Briefings supported greater 

transparency and accountability in managing FSA’s strategies to achieve its goals and 

objectives while strengthening partnerships across FSA, the Department, and with external 

stakeholders.

Executive Management Monthly Report

Throughout FY 2023, FSA measured and analyzed performance based upon performance 

indicators results outlined in the FY 2023–27 Strategic Plan, as well as various internal 

indicators used for operational management. The analysis of programmatic and operational 

performance continued to be a transparent process within the organization, executed through 

monthly performance reports shared with the FSA leadership and management team. Detailed 

analyses of specified performance indicators were developed, and project leads directly briefed 

FSA leadership and management team via performance dashboards each month.

FSA Bi-Weekly Report

Throughout FY 2023, the FSA reports on priority initiatives on a regular basis to support 

engagements between FSA and the Office of the Under Secretary. This reporting mechanism is 

leveraged as an opportunity for FSA to elevate critical issues and obtain support for key 

initiatives.

Annual Performance Report

To report progress on meeting the strategic goals, FSA prepares and publishes an Annual 

Performance Report, which is included in the Annual Report. In addition to the Annual 

Performance Report, the Annual Report includes FSA management’s discussion and analysis of 

its financial and performance results, its financial statements and notes, and the report of the 

independent auditors. 
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 23

Management’s Discussion and Analysis

(Unaudited) 

The Department Quarterly and Annual Performance Reviews

The Department conducts quarterly meetings, known as Strategic Plan Progress Reviews 

(SPPRs), with principal offices on progress towards achieving agency priorities. The SPPR is a 

quarterly discussion-based review led by the Deputy Secretary, Department Performance 

Improvement Officer, and agency leaders. The SPPRs provide a mechanism for agency leaders 

to review the organization’s performance and bring together the people, resources, and analysis 

needed to drive progress on agency priorities, both mission-focused and management goals. 

Best practices for an effective SPPR include key elements: narratives, visuals, and data. The 

SPPR quarterly cycle includes a meeting on the key projects and initiatives, an internal review 

with the Department, an external strategic review with OMB, and a year in review.

In the Department’s new plan, FSA tracks the performance indicators that support the following 

Department’s strategic goal: 

• Goal 4: Increase postsecondary value by focusing on equity-conscious strategies to 

address access to high-quality institutions, affordability, completion, post-enrollment 

success, and support for inclusive institutions. 

Specifically, FSA is responsible for the following strategic objective under Goal 4:

• Strategic Objective 4.2: Improve the administration of student aid programs to help 

eligible students receive aid; support borrowers in successfully repaying their loans, 

claiming loan forgiveness benefits, and mitigating student loan default; and hold 

contractors accountable.
24 Fiscal Year 2023 Annual Report | Federal Student Aid

Management’s Discussion and Analysis

(Unaudited) 

Agency Priority Goals 

Agency Priority Goals (APGs) are a performance accountability structure of the Government 

Performance and Results Modernization Act of 2010 (GPRA Modernization Act) (Pub. L. 111-

352) that provide agencies a mechanism to focus on leadership priorities, set outcomes, and 

measure results, bringing focus to mission areas where agencies need to drive significant 

progress and change. APG statements are outcome-oriented, ambitious, and measurable with 

specific targets that reflect a near-term result or achievement that agency leadership wants to 

accomplish within approximately 24 months. In collaboration with OMB, the Department 

established three APGs for FY 2024 through FY 2025 that align with the Department’s 

FY 2022–26 Strategic Plan. FSA’s quarterly progress reports are published on

Performance.gov. 

FY 2023 closes out the FY 2022–23 APG. In collaboration with the Department, FSA succeeded 

in accomplishing the goal, “to provide effective customer service for borrowers to simplify the 

student loan repayment process and improve loan servicer quality and accuracy to levels at or 

above 95 percent.” 

FSA implemented performance benchmarks as part of student loan servicer agreements to 

improve loan servicer quality, accuracy, and timeliness. FSA was able to realize performance 

standards and expanded hours of operation for loan servicer call centers to improve the 

borrower experience and increase borrowers’ access to customer service representatives. 

Lastly, in FY 2023, the new contact center customer feedback surveys continued to inform 

improvements to systems, tools, and the customer experience.

FSA’s FY 2024–25 APG Goal Statement:

By September 30, 2025, the Department will launch the complete IDR capabilities and establish 

indicators that will monitor and track borrowers’ ability to select student loan repayment plans 

that contribute to a reduced risk of delinquency.
(Unaudited)

Fiscal Year 2023 Annual Report | Federal Student Aid 25

Management’s Discussion and Analysis

(Unaudited) 

Quality of Performance Data

Ensuring the integrity of the data required to determine performance results is a critical step in 

reporting performance. For this step, FSA developed and implemented a Validation and 

Verification Matrix, which serves as a tool to authenticate the completeness and reliability of the 

underlying data gathered and used to calculate each performance indicator for the reporting 

period, including the performance results reported in this Annual Report. For each performance 

indicator, the matrix documents the following: the data source, availability, security procedures, 

and known limitations; whether data are subject to FSA’s OMB Circular A- 123 Internal Control 

Review process; and procedures for accessing the data, calculating the performance indicator, 

and validating and verifying the data gathered.

For a discussion of data validation and verification for each performance indicator, please see 

the Data Validation and Verification subsection, located in the Appendices section. 
26 Fiscal Year 2023 Annual Report | Federal Student Aid

Annual Performance Report

(Unaudited)

Analysis of Financial Statements

Introduction

This section assists readers in understanding FSA’s financial position as reflected in the

Balance Sheet and related notes located in the Financial Section of this report and FSA’s net 

cost, budgetary resources, and changes in net position as reflected in the unaudited statements 

and related notes in the Other Information Section of this report. The financial analysis section 

explains major changes in assets, liabilities, costs, and budgetary resources. It also includes 

comparisons of the current year to the four prior years and discusses the relevance of 

significant balances, amounts, and trends reflected in the financial statements and notes.

FSA’s financial statements are prepared in accordance with generally accepted accounting 

principles, which include established federal accounting standards and reporting requirements. 

In FY 2023, FSA’s consolidated balance sheet was subject to an annual independent audit. FSA 

received a disclaimer of opinion on the consolidated balance sheet as of September 30, 2023. 

FSA has oversight responsibilities for more than $1.6 trillion in federal student loans, of which it 

directly owns and manages approximately $1.4 trillion. The remaining balance represents nondefaulted FFEL Guaranteed loans held by lenders and Federal Perkins loans held by schools. 

FSA reports its portfolio of federal student loans on its Balance Sheet under Loans Receivable, 

Net (see Note 5). Loans Receivable, Net is the gross amount of loans and interest receivable 

less an allowance for the present value of amounts not expected to be recovered (Allowance for 

Subsidy). Subsidy Expense is a factor included in the Allowance for Subsidy and represents an 

estimate in present value terms of the cost to the government of Direct Loans and loan 

guarantees. Subsidy Expense is recorded in the year a loan is disbursed and updated annually 

through a re-estimation process. It includes default costs (net of recoveries), contractual 

payments paid to third party private collection agencies, and net borrowing costs, less any 

origination or other fees collected. If the net cost to the government is greater than zero, then 

the subsidy expense is said to be positive. However, the subsidy expense may also be zero 

(break-even), or it may be negative if the estimated cost of providing loans to borrowers is less 

than the value of collections received as interest and fees. As of September 30, 2023, FSA 

reported $1,072.5 billion in Loans Receivable, Net after deducting an Allowance for Subsidy of 

approximately $449.9 billion. Loans Receivable, Net increased 25% from the prior year, which 

was primarily due to a decrease in the Allowance for Subsidy. The $224.7 billion decrease in the 

FY 2023 Allowance for Subsidy was due to the Supreme Court’s ruling against the 

Administration’s one time student debt relief plan.

Balance Sheet

The Balance Sheet presents the recorded value of assets and liabilities retained or managed by 

FSA as of a specific point in time. Assets represent resources available to pay liabilities or

satisfy future service needs. Liabilities are amounts FSA owes, the probable and measurable 

future outflows of resources arising from past transactions or events. The difference between 

assets and liabilities represents FSA’s net position.
Fiscal Year 2023 Annual Report | Federal Student Aid 27

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(Unaudited)

The Condensed Balance Sheets presented below provide a summary of significant balances in 

FSA’s Balance Sheets over a five-year period, beginning with FY 2019. The table also shows 

the percentage change between the prior and current fiscal years as of September 30, 2022

and 2023, respectively. The FY 2022 data appearing in the tables and figures throughout this 

section were not audited. Figures and tables presented in this section include rounding 

adjustments to ensure that component line items sum to the corresponding total. As a result, 

there may be small discrepancies between the amounts shown in a particular figure or table 

when compared to similar items discussed in the text or presented in other areas of the Annual 

Report. 

Table 7: Financial Highlights

Condensed Balance Sheets

(Dollars in Billions)

FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited)

FY 2023

(Unaudited) Difference Percentage 

Change6

Assets

Fund Balance with Treasury $ 62.6 $ 70.3 $ 79.2 $ 118.6 $ 106.87 $ (11.73) (9.9) %

Credit Program Receivables, Net 1,202.1

 

1,169.6 1,164.8 858.3 1,072.55 214.25 25%

Remaining Assets 2.2 2.2 2.2 0.9 .84 (.06) (6.7)%

Total Assets $ 1,266.9 $1,242.1 $ 1,246.1 $ 977.8 $ 1,180.26 $ 202.46 20.7%

Liabilities

Debt $ 1,287.5 $1,249.8 $ 1,221.1 $ 905.0 $ 1,188.50 $ 283.50 31.3%

Subsidy due to Treasury General 

Fund 10.3 3.3 1.5 27.0 1.63 (25.37) (94.0)%

Remaining Liabilities 14.0

 

8.4 15.9 18.1 19.34 1.24 6.9%

Total Liabilities $ 1,311.8 $1,261.4 $ 1,238.5 $ 950.1 $ 1,209.47 $ 259.37 27.3%

Net Position

Unexpended Appropriations $ 31.4 $ 35.0 $ 36.3 $ 37.3 $ 38.01 $ .71 1.9%

Cumulative Results of Operations (76.3) (54.4) (28.7) (9.5) (67.22) 57.72 607.6%

Net Position $ (44.9) $ (19.4) $ 7.6 $ 27.7 $ (29.21) $ (56.91) (205.5)%

Total Liabilities & Net Position $ 1,266.9 $1,242.1 $ 1,246.1 $ 977.8 $ 1,180.26 $ 202.46 20.7%

The condensed Balance Sheet shows that FSA had total assets of $1,180.26 billion as of 

September 30, 2023, an increase of $202.46 billion, or 20.7%, over the prior fiscal year. The 

increase resulted primarily from an increase in Credit Program Receivables, Net of $214.25 

billion, combined with a decrease in Fund Balance with Treasury ($11.73 billion). Fund Balance 

with Treasury and Credit Program Receivables, Net accounted for approximately 99.9% of Total 

Assets as of September 30, 2023, as illustrated in the Composition of Assets chart (Figure 10). 

The Comparison of Assets chart (Figure 11) presents changes in these two principal Balance 

Sheet line items over the past five fiscal years.

6 The percentage change is calculated as the difference between FY 2022 and FY 2023, divided by the FY 2022 amount. In some 

instances, where the current-year amount has an opposite sign to the prior-year amount, the percentage change may be negative 

even though the annual change is positive (and vice versa). Similarly, if the current-year negative amount has a larger negative 

value than the prior-year negative amount, the difference will be negative, but the percentage change will be positive.
28 Fiscal Year 2023 Annual Report | Federal Student Aid

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(Unaudited)

Figure 10: Composition of Assets7

Figure 11: Comparison of Assets

(Dollars in Billions)

Credit Program Receivables, Net. FSA’s Credit Program Receivables, Net balance of 

$1,072.5 billion as of September 30, 2023, represents FSA’s most important asset category and 

accounted for approximately 90.9% of Total Assets. FSA reports the total amount under the 

three major program categories of Direct Loan, FFEL, and Other, as illustrated in Figure 12 

below and discussed more fully in the following sections.

7 Line items presented in the Figures and Tables throughout this section may include rounding adjustments to reconcile to the total 

amount being reported. 

FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited)

FY 2023

(Unaudited)

Credit Program Receivables, Net 94.9% 94.2% 93.5% 87.8% 90.9%

Fund Balance with Treasury 4.9% 5.7% 6.3% 12.1% 9.0%

Remaining Assets 0.2% 0.2% 0.2% 0.1% 0.1%

0%

20%

40%

60%

80%

100%

Composition of 

FSA Assets

FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited)

FY 2023

(Unaudited)

Credit Program Receivables,

Net $1,202.1 $1,169.6 $1,164.8 $858.3 $1,072.5

Fund Balance with Treasury $62.6 $70.3 $79.2 $118.6 $106.9

Remaining Assets $2.2 $2.1 $2.1 $0.9 $0.8

Total Assets $1,266.9 $1,242.1 $1,246.1 $977.8 $1,180.2

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400
Fiscal Year 2023 Annual Report | Federal Student Aid 29

Annual Performance Report

(Unaudited)

Figure 12: Total Loan Portfolio

Net of Allowance for Subsidy

(Dollars in Billions)

Figure 12 shows that over the five-year period from FY 2019–23, FSA’s portfolio of Credit 

Program Receivables, Net decreased by $129.6 billion. The Direct Loan program accounted for 

most of this change and decreased by $92.8 billion. Also included in the $129.6 billion decrease 

was a $37.5 billion reduction in the FFEL portfolio.

The changes in the Direct Loan and FFEL portfolios are principally related to the impact of the 

SAFRA Act which, as of June 30, 2010, eliminated all new loan originations under the FFEL 

Program in favor of direct lending. Loan consolidation has also played a role. Another 

contributing factor is the FY 2023 decrease in the allowance for subsidy of $224.7 billion and in 

FY 2022, an increase of $352.7 billion. Additional information on the allowance for subsidy is 

included in Note 5. 

Direct Loan Credit Program Receivables, Net. Direct Loan Credit Program receivables 

continued to be the largest component of FSA’s credit program receivable portfolio in FY 2023. 

As of September 30, 2023, the $1,030.9 billion Direct Loan portfolio ending balance accounted

for 96.1% of FSA's total Credit Program Receivables, Net. The FY 2023 Direct Loan ending 

balance total includes $1,419.6 billion in principal, interest, and fees, with an allowance for 

subsidy of $388.7 billion. The FY 2023 $8.8 billion decrease in Direct Loan Receivables (before 

subsidy cost) was mainly driven by the decrease in the outstanding amount owed by borrowers. 

 

 

 

 

 

 

 

 

 

 
30 Fiscal Year 2023 Annual Report | Federal Student Aid

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(Unaudited)

Figure 13: Components of Direct Loan Receivables, Net8

(Dollars in Billions)

The growth in principal outstanding has accounted for virtually all growth of the Direct Loan 

portfolio over the past five years in dollar terms, as seen in Figure 13. The figure shows the 

number of recipients corresponding to the outstanding loan portfolio at each fiscal year end. 

Recipients are students who benefit from the federal student loans. In most cases, a recipient is 

the borrower; however, for Parent PLUS loans, the parent is the borrower, and the student is the 

recipient. Figure 13 also shows that Direct Loan recipients grew from 35.1 million to 38.1 million 

over the five-year period.

Table 8 illustrates that from FY 2019 to FY 2023, outstanding principal increased from 103.7% 

to 129.6% of the net receivable balance, and accrued interest increased from 7.4% to 8.1% of 

the net receivable balance. 

Table 8: Components of Direct Loan Credit Program Receivables, Net by Percentage

Direct Loan Component FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited)

FY 2023

(Unaudited)

Principal 103.7% 111.3% 117.0% 164.3% 129.6%

Accrued Interest 7.4% 8.4% 7.8% 10.6% 8.1%

Allowance for Subsidy (11.1)% (19.7)% (24.8)% (74.9)% (37.7)%

Net Receivable 100.0% 100.0% 100.0% 100.0% 100.0%

The following is a summary of the COVID-19 emergency relief measures. On March 20, 2020, 

FSA began providing the following temporary relief on Department-owned federal student loans: 

suspension of loan payments, stopped collections on defaulted loans, and a 0% interest rate. 

On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES 

Act) became law. The CARES Act provided for the above relief measures through 

September 30, 2020. On August 8, 2020, the COVID-19 emergency relief measures were 

extended through December 31, 2020. On December 4, 2020, the COVID-19 emergency relief 

measures were extended through January 31, 2021. On January 20, 2021, the COVID-19 

8 Recipient numbers come from the FSA Data Center or NSLDS® database. For more details, refer to Footnote 11. 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
Fiscal Year 2023 Annual Report | Federal Student Aid 31

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(Unaudited)

emergency relief measures were extended through September 30, 2021. On March 29, 2021, 

more relief measures were added for borrowers in the Total and Permanent Disability (TPD) 

discharge process. On March 30, 2021, the COVID-19 emergency relief measures were 

expanded to federal student loans made through the FFEL Program that were in default. On 

August 6, 2021, the COVID-19 emergency relief measures were extended until 

January 31, 2022. On December 22, 2021, the COVID-19 emergency relief measures were 

extended through May 1, 2022. On April 6, 2022, the COVID-19 emergency relief measures 

were extended through August 31, 2022. On August 24, 2022, the COVID-19 emergency relief 

measures were extended through December 31, 2022, and again on November 22, 2022, 

pending the Supreme Court’s decision on whether the Department would be permitted to 

implement the one-time student loan debt relief program. On June 7, 2023, The Department 

notified borrowers that student loan interest would resume on September 1, 2023, and 

payments would resume in October 2023.

However, repayment of Federal PLUS Loans to parents begins within 60 days of full 

disbursement unless parents request a deferment from their loan servicer to delay the start of 

repayment until the end of the six-month grace period after the student graduates or drops 

below half-time enrollment. Direct PLUS Loans for graduate or professional students enter 

repayment six months after the borrower graduates or drops below half-time enrollment. Once 

the student borrower graduates, leaves school, or drops below half-time enrollment, they are 

frequently entitled to a “Grace” period. During this period, repayment is not required to begin on 

the loan. Not all federal student loans have a grace period and for most loans, interest will 

accrue during the grace period. At the end of the grace period, the borrower will enter 

“Repayment” status and regular monthly payments will be required according to an agreed upon 

payment schedule.

Figure 149 reflects FSA’s portfolio of Direct Loans in two main categories based on repayment 

status. For the purpose of this discussion, loans are classified as “In Repayment” if, under the 

terms of the promissory note, the loan is current, delinquent, defaulted, in non-defaulted 

bankruptcy, or in a disability status.10 Alternatively, loans are classified as “Not in Repayment” if 

the borrower is “In School”, “In Grace”, or has been granted a deferment or a forbearance. The 

loan status “Deferment” includes loans for which payments have been postponed due to certain 

circumstances, such as returning to school, military service, or economic hardship. Similarly, 

“Forbearance” includes loans for which payments have been temporarily suspended or reduced 

because of certain types of financial hardships. Figure 14 reports the portfolio balance as the 

sum of principal and interest balances (i.e., the gross amount) owed by the borrower and 

excludes any subsidy cost or allowance that would adjust the outstanding balance to its net 

present value.

9 FY 2019 data are taken directly from the NSLDS database. 

10 The In Repayment/Not in Repayment classifications used for this discussion are slightly different from the definitions under 

34 CFR §§ 685.207, 685.204, and 685.205 which specify that a borrower first enters repayment before receiving a deferment or 

forbearance. Under 34 CFR § 685.205(a), borrowers in forbearance may still make payments on their loans. In addition, under 

34 CFR Part 668 Subpart N, borrowers in a deferment or forbearance are considered to be in repayment for purposes of calculating 

the cohort default rate for institutions.
32 Fiscal Year 2023 Annual Report | Federal Student Aid

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(Unaudited)

Figure 14: Direct Loan Portfolio by Repayment Status

Principal and Interest Only (Dollars in Billions)

The temporary relief discussed above and beginning on March 20, 2020, resulted in significant 

and atypical shifts in the “In Repayment” and “Not in Repayment” classifications11. The 

September 30, 2023 balance of loans in repayment of $1,106.8 billion contrasts sharply with the 

$129.3 billion in repayment as of September 30, 2022. The significant increase in this segment 

from FY 2022 reflects the impact of the COVID-19 emergency measures and payment pause, 

which placed most borrowers into administrative forbearance until September FY 2023. 

In Figure 15, the Direct Loan portfolio of “In Repayment” principal and interest has been 

subdivided into three categories, “Current”, “Delinquent”, and “Default/Bankruptcy/Other”. If the 

borrower continues to make timely payments such that no more than 30 days elapse after the 

due date without payment, then the loan is classified as “Current.” If more than 30 days elapse, 

then the loan will be reclassified as “Delinquent.” Under Title IV, if more than 270 days pass 

without payment being received to satisfy the oldest payment due, Direct Student Loans are 

technically considered “In Default”.12 The status continues to be tracked through the life of the 

loan until the loan is paid in full or otherwise closed out.

11 See footnote 10.

12 FSA’s policy is to not transfer such loans to the defaulted debt servicer until more than 360 days pass without payment being 

received, to ensure parity of Direct Loan borrower treatment with that of FFEL borrowers.

 

 

 

 

 

 

 

 

 

 

 
Fiscal Year 2023 Annual Report | Federal Student Aid 33

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(Unaudited)

Figure 15: Direct Loan Portfolio Segment in Repayment by Status13

Principal and Interest Only

(Dollars in Billions) 

The portfolio of Direct Loan principal and interest receivables “Not in Repayment” is reflected in 

Figure 1614 which subdivides this segment into two categories, “In School, Grace Period, and 

Education Deferments” and “Forbearance/Noneducation Deferments”. The “In School, Grace 

Period, and Education Deferments” declined from $259.5 billion in FY 2022 to $255.4 billion in 

FY 2023. The “Forbearance and Noneducation Deferments” segment decreased from 

$1,039.7 billion in FY 2022 to $57.4 billion in FY 2023.

Figure 16: Direct Loan Portfolio Segment not in Repayment by Status

Principal and Interest Only

(Dollars in Billions)

13 See footnote 10. 

14 Ibid. 

FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited)

FY 2023

(Unaudited)

In School, Grace Period, and

Education Deferments $294.8 $282.8 $271.9 $259.5 $255.4

Forbearance and Noneducation

Deferments $133.2 $887.5 $967.8 $1,039.7 $57.4

Total $428.0 $1,170.3 $1,239.7 $1,299.2 $312.8

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

 

 

 

 

 

 

 

 
34 Fiscal Year 2023 Annual Report | Federal Student Aid

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(Unaudited)

FSA FFEL Credit Program Receivables, Net. FSA’s portfolio of FFEL loans includes debt 

acquired under the Conduit, Loan Participation Purchase, and Loan Purchase Commitment 

Programs established through the FY 2008 ECASLA law and referred to collectively as the 

FFEL ECASLA Loan Programs. It also includes debt acquired under the “traditional” (NonECASLA) loan programs, known collectively as the “FFEL Guaranteed” portfolio segment. 

Figure 17 illustrates that the FFEL ECASLA portfolio segment remains the major component of 

the total FFEL portfolio of net credit program receivables. This segment decreased from 

$53.7 billion in FY 2019 to $27.5 billion as of September 30, 2023, primarily as a result of 

collections of principal and the impact of borrowers consolidating loans under the Direct Loan 

Program.

Figure 17: Total FFEL Loan Portfolio15

(Dollars in Billions) 

15 FFEL Guaranteed refers to the FFEL Guaranteed (Non-ECASLA) Program; FFEL ECASLA refers to FFEL ECASLA Acquired 

Loan Program

FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited)

FY 2023

(Unaudited)

 FFEL ECASLA $53.7 $46.3 $42.1 $29.9 $27.5

 FFEL Guaranteed $23.1 $21.1 $16.1 $9.9 $11.8

Total FFEL Portfolio $76.8 $67.4 $58.2 $39.8 $39.3

$0

$10

$20

$30

$40

$50

$60

$70

$80

$90
Fiscal Year 2023 Annual Report | Federal Student Aid 35

Annual Performance Report

(Unaudited)

FFEL receivables are further broken down into principal, accrued interest, and subsidy 

components as shown below in Figure 1816. 

Figure 18: Components of FFEL Receivables, Net

(Dollars in Billions) 

Other Credit Program Receivables, Net. As shown in Figure 19 below, TEACH Grants, 

Perkins Loans, and HEAL Loans make up the third segment of Credit Programs Receivables, 

Net that FSA reports on its balance sheet.

Figure 19: Other Credit Program Receivables Loan Portfolio

(Dollars in Millions)

16 Recipients in Millions for FY 2019 are based on data published by the FSA Data Center, at StudentAid.gov/portfolio. FY 2019

data are taken directly from the NSLDS database.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
36 Fiscal Year 2023 Annual Report | Federal Student Aid

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The Other Credit Program Receivables, Net, balance of $2.3 billion in FY 2023 accounted for 

0.22% of FSA’s total Credit Program Receivables, Net of $1,072.5 billion. 

Composition of FSA Liabilities. FSA’s liabilities represent probable and measurable future 

outflows of resources arising from past transactions or events. As of September 30, 2023, FSA 

had total liabilities of $1,209.5 billion as compared to $950.1 billion as of September 30, 2022. 

Debt. FSA’s debt associated with loans is the primary component of its liabilities. FSA’s debt 

balance of approximately $1,188.5 billion as of September 30, 2023, is $283.5 billion greater 

than the FY 2022 amount. As shown in Figure 20, the Direct Loan Program, with a balance of 

approximately $1,127.0 billion comprises 94.8% of total debt. 

Figure 20: Comparison of Debt

(Dollars in Billions)

FSA borrows funds from Treasury to support the disbursement of new loans, and for the 

payment of credit program outlays and related costs. FSA then makes repayments after 

considering its cash position and liability for future cash outflows, as mandated by the Federal 

Credit Reform Act of 1990 (FCRA). The net impact of these activities on the outstanding debt 

portfolio are illustrated for the Direct Loan and FFEL Programs in Figures 21 and 22 

respectively.

Direct Loan net financing activity (Figure 21) accounted for the $289.5 billion increase in FSA’s 

outstanding debt. 

 

 

 

 

 

 

 

 

 

 
Fiscal Year 2023 Annual Report | Federal Student Aid 37

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(Unaudited)

Figure 21: Direct Loan Program Net Financing Activity

(Dollars in Billions)

FFEL program net financing activity (Figure 22) accounted for the $6.1 billion decrease in FSA’s 

outstanding debt.

Figure 22: FFEL Loan Program Net Financing Activity

(Dollars in Billions) 

Statement of Net Cost

The Statement of Net Cost is the federal financial statement that presents the net cost of 

operations for FSA programs. FSA’s net cost is the gross cost incurred during its operations 

less any exchange revenues earned from its activities. Gross cost is composed of the cost of 

credit programs, grant programs, and operating costs. Exchange revenues are primarily interest 

earned on credit program loans.

The Statement of Net Cost presented below provides a condensed summary of the significant 

balances in FSA’s Statements of Net Cost over a five-year period, beginning with FY 2019. The 

table also shows the percentage change between the prior and current fiscal years as of 

September 30, 2022 and 2023, respectively.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 
38 Fiscal Year 2023 Annual Report | Federal Student Aid

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(Unaudited)

Table 9: Statements of Net Cost

(Summarized)

(Dollars in Billions)

FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited) 

FY 2023

(Unaudited) Difference Percentage Change17

Gross Cost $144.9

 

$171.2 $177.4 $503.0 $(34.7) $(537.7) (106.9)%

Less: Earned Revenue (36.8) (39.4) (39.7) (65.1) (40.8) 24.3 (37.3)%

Net Cost of Operations $108.1 $131.8 $137.7 $437.9 $(75.5) $(513.4) (117.2)%

As shown in Figure 23, FSA’s gross costs significantly decreased from $144.9 billion in FY 2019 

to ($34.7) billion in FY 2023, primarily as the result of subsidy-related transactions. FSA’s 

earned revenues (mainly interest and fee accruals net of subsidy amortization) increased from 

($36.8) billion in FY 2019 to ($40.8) billion in FY 2023. As a result, net cost of operations 

decreased from $108.1 billion in FY 2019 to ($75.5) billion in FY 2023. 

Figure 23: Composition of Net Cost

(Dollars in Billions)

Statement of Changes in Net Position

The Statement of Changes in Net Position presents the amounts that caused the net position 

section of the Balance Sheet to change from the beginning to the end of the reporting period 

and is affected by changes in its two components, cumulative results of operations and 

unexpended appropriations.

FSA’s net position as of September 30, 2023, was ($29.2) billion, a decrease of $56.9 billion 

from the September 30, 2022 net position of $27.7 billion. Cumulative Results of Operations 

decrease by ($57.7) billion from ($9.5) billion in FY 2022 to ($67.2) billion in FY 2023. In 

addition, unexpended appropriations increased by $0.71 billion from $37.3 billion in FY 2022 to 

$38.0 in FY 2023. 

17 Refer to Footnote 6.

FY 2019 FY 2020 FY 2021 FY 2022

(Unaudited)

FY 2023

(Unaudited)

Gross Costs $144.9 $171.2 $177.4 $503.0 $(34.7)

Earned Revenue $(36.8) $(39.4) $(39.7) $(65.1) $(40.8)

Net Costs $108.1 $131.8 $137.7 $437.9 $(75.5)

 $(200)

 $(100)

 $-

 $100

 $200

 $300

 $400

 $500

 $600
Fiscal Year 2023 Annual Report | Federal Student Aid 39

Annual Performance Report

(Unaudited)

Statement of Budgetary Resources

The Statement of Budgetary Resources compares the budgetary resources provided with the 

status or execution of those resources. The statement details the composition of the resources 

and net outlays. Appropriations are available to cover the subsidy cost of each loan program 

and administrative expenses. Subsidy expense represents the difference between the net 

present value of expected future cash flows and the face value of each loan portfolio. 

Appropriation authority is available as needed on a permanent basis to finance costs resulting 

from loans guaranteed in the years before FY 1992. The Federal Pell Grant Program receives 

appropriations to cover actual grant disbursements. 

The statement shows that as of September 30, 2023, FSA had $787.4 billion in total budgetary 

resources as compared with $824.4 billion in budgetary resources as of September 30, 2022.

Overall budgetary resources decreased by $37.6 billion. 

Limitations of Financial Statements

The principal financial statements are prepared to report the financial position, financial 

condition, and results of operations, pursuant to the requirements of 31 U.S.C. § 3515(b). The 

statements are prepared from records of Federal entities in accordance with Federal generally 

accepted accounting principles (GAAP) and the formats prescribed by OMB. Reports used to 

monitor and control budgetary resources are prepared from the same records. Users of the 

statements are advised that the statements are for a component of the U.S. Government.
40 Fiscal Year 2023 Annual Report | Federal Student Aid

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(Unaudited)

Financial Management Highlights

Financial Impact of the Coronavirus Disease 2019 

In response to the COVID-19 emergency, Congress enacted the CARES Act on

March 27, 2020. As part of the CARES Act, FSA received $40.0 million to support efforts related 

to loan forbearance, default collection wage garnishment assistance for student loan borrowers, 

servicing system modifications, systems support of COVID-19 telework, and hiring of temporary 

employees. The Coronavirus Response and Relief Supplemental Appropriations Act, 2021, 

which was part of the Consolidated Appropriations Act, 2021, was signed into law December 

2020, and provided additional relief funding in the amount of $30.0 million. Funding from the 

CARES Act and Coronavirus Response and Relief Supplemental Appropriations Act, 2021, 

expired September 30, 2021, and September 30, 2022 respectively. 

The American Rescue Plan Act of 2021, which was signed into law in March 2021, provided 

$91.1 million in relief funding. During FY 2023, FSA obligated $23 million prior to the Fiscal 

Responsibility Act of 2023, which permanently rescinded unobligated balances.

The CARES Act provided emergency relief measures in the Direct Loan program that included 

suspending loan payments, halting collections on defaulted loans, and setting interest rates to 

0% through September 30, 2020. In response, FSA stopped all federal wage garnishments and 

collection actions for borrowers with federally held loans in default. Emergency relief measures 

were repeatedly extended and expanded subsequent to the CARES Act. On August 24, 2022, 

the COVID-19 relief measures were extended until the Department was permitted to implement 

the debt relief program or the litigation was resolved. In June 2023, the U.S. Supreme Court did 

not rule in favor of the debt relief program. As a result, interest on student loans started in 

September 2023 and payments will begin in October 2023.
Fiscal Year 2023 Annual Report | Federal Student Aid 41

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(Unaudited)

Analysis of Systems, Controls, and Legal 

Compliance

FSA adheres to the Government Accountability Office (GAO) published guidance on internal 

control and recognizes that internal control is an integral part of managing an organization. 

Internal control includes the plans, methods, and procedures used to meet the organization’s 

missions, goals, and objectives. In carrying out these components of internal control, FSA 

supports an environment for performance-based management. Internal control also serves as 

the first line of defense in safeguarding assets and preventing and detecting errors and fraud. 

Internal control helps government program managers achieve desired results through effective 

stewardship of public resources.

Internal controls should provide reasonable assurance that the objectives of the agency are 

being achieved in the following categories:

• Effective and efficient operations

• Reliability of reporting for internal and external use

• Compliance with applicable laws and regulations18

FSA is responsible for establishing and maintaining effective internal control over reporting and 

the financial management systems that meet the objectives of the Federal Managers’ Financial 

Integrity Act of 1982 and annually assessing the effectiveness and efficiency of its internal 

controls over operations and compliance with applicable laws and regulations in accordance 

with OMB Circular A-123, Management’s Responsibility for Enterprise Risk Management and 

Internal Control (OMB Circular A-123). FSA continues to coordinate with the Department and 

internally to execute these requirements.

Information on the Department’s assessment of internal control, inclusive of FSA, is available in 

the Analysis of Systems, Controls and Legal Compliance section of the Department’s AFR.

In addition, FSA, working with the Department, conducted its current year assessment of the 

effectiveness of internal control in accordance with the requirements of OMB Circular A-123, 

Appendix A, Management of Reporting and Data Integrity Risk (OMB Circular A-123, Appendix 

A). OMB Circular A-123, Appendix A provides requirements to agencies for conducting 

management’s assessment of internal control over reporting. The scope of FSA’s assessment 

focuses on new processes and processes with high-risk profiles that are tested every year. 

Processes with lower-risk profiles are reviewed and tested on a 4-year cycle. In FY 2023, FSA 

continued to rely on audits of external service providers conducted by independent public 

accountants in accordance with Statement on Standards for Attestation Engagements Number 

18, Reporting on Controls at a Service Organization. 

FSA’s participation in the Department's implementation of the requirements of OMB Circular 

A-123, including Appendix A, enables it to continue to build upon its internal control framework. 

This framework will be used in continuing efforts to monitor and improve internal control. Please

18 Government Accountability Office Standards for Internal Control in the Federal Government, GAO-14-704G, 

September 10, 2014, p.5.
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refer to the Analysis of Systems, Controls and Legal Compliance section of the 

Department’s AFR for additional information related to management’s assurances and 

disclosures.

Please also refer to the Analysis of Systems, Controls and Legal Compliance section of the

Department’s AFR for information related to the Department's compliance with the Federal 

Financial Management Improvement Act of 1996. 

FSA’s financial management systems strategy is formulated and managed as part of the 

Department’s strategy. For details on FSA’s financial management systems strategy, please 

refer to the Financial Management Systems Strategy narrative found in the Management’s 

Discussion and Analysis section of the Department’s AFR. 
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Overview of the Annual Performance Report

The Annual Performance Report section of the FY 2023 Annual Report provides detailed 

performance information on FSA’s progress in achieving the goals and objectives described in 

the FY 2023–27 Strategic Plan. The subsections of the Annual Performance Report are listed 

below:

• Introduction to the Annual Performance Report: The Introduction to the Annual 

Performance Report provides an overview of the Annual Performance Report and 

includes a high-level summary of the FY 2023–27 Strategic Plan. 

• Performance Results by Strategic Goal: This subsection details the results of each 

overall strategic goal by strategic objective and performance indicator. Each strategic 

objective provides an overview and a performance analysis, which includes noteworthy 

progress and focused improvement. Each performance indicator includes a table that 

presents five years of data results, where available, as well as its current target and 

results. The performance indicator section also includes a discussion of the indicator 

definition and performance period. 

• Understanding the Performance Results 

• Fiscal Year 2023 Accomplishments of Federal Student Aid: This subsection 

describes additional accomplishments that were not measured by the performance 

indicators included in the strategic plan but were the result of initiatives that FSA 

undertook to support the implementation of the strategic plan or legislative changes.
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Introduction to the Annual Performance Report

The FSA strategic plan guides FSA toward achieving its vision, “To be the most trusted and 

reliable source of student financial aid, information, and services in the nation.” The strategic 

plan outlines FSA’s strategic goals, objectives, and performance indicators. The FY 2023 

Annual Report introduces the new FY 2023–27 Strategic Plan. This plan was developed to align 

with and support the Department’s overall strategic goals and objectives, as defined in the 

Department’s FY 2022–26 Strategic Plan. 

The FSA FY 2023 Annual Report describes the accomplishments, challenges, and future plans 

to successfully achieve the goals set forth in the five-year strategic plan.

The FY 2023–27 strategic goals are: 

• Strategic Goal 1: Improve Customer Service and Outcomes for Students and 

Borrowers 

• Strategic Goal 2: Advance Equity and Access to Student Financial Assistance

• Strategic Goal 3: Strengthen Engagement and Accountability for Educational and 

Financial Institutions

• Strategic Goal 4: Increase Workforce and Workplace Capabilities

• Strategic Goal 5: Boost Operational Efficiency

FSA transitioned to the FY 2020–24 Strategic Plan to the current strategic plan. This plan 

enabled the organization to continue to focus on its vision to create a more student-focused, 

agile, and transparent organization. The plan, FY 2023–27 Strategic Plan, ensures that FSA will 

continue to improve upon its mission while increasing accountability in all areas of 

organizational performance.

The enactment of FY 2023–27 Strategic Plan closes out the FY 2020–24 Strategic Plan and 

realigns the organization priorities to the Department’s strategic current plan. In doing so, FSA 

continues to focus on its vision to create a more student-focused, agile, and transparent 

organization. The FY 2023–27 Strategic Plan ensures that FSA will continue to achieve its 

mission while increasing accountability in all areas of organizational performance. FSA will 

measure performance through a new set of performance indicators, listed in Tables 11-15, 

which align with the current strategic framework. Appendix A lists the indicators that were 

discontinued as a part of the old FY 2020–24 Strategic Plan. 

FSA is required, by the PBO-enabling legislation, to report annually on its level of performance 

and the associated results. This section, the Annual Performance Report (APR), satisfies this 

annual reporting requirement. For additional performance-related information—including a more 

complete discussion of FSA’s mission, organization, and performance management—refer to 

the Management’s Discussion and Analysis section. To read more about FSA’s strategic 

plans refer to StudentAid.gov/strategic-planning-and-reporting. 
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The performance indicators in the table below were continued from the FY 2020-24 Strategic 

Plan. See Appendix A for a listing of all the performance indicators that were discontinued.

Table 10: FY 2020–24 and FY 2023–27 Strategic Plans Performance Indicator Crosswalk

Performance Indicator Crosswalk

FY 2020-24 Plan Performance Metrics FY 2023-27 Plan Performance Indicators

1.1 Improve Federal Employee Viewpoint Survey 

score: Employee Engagement Index. FSA’s scores 

will improve the first year and continue to increase 

1-2% annually.

4.3.A Federal Employee Viewpoint Survey: Employee 

Engagement Index

2.2.G Customer Satisfaction Survey(s) for StudentAid.gov 

site and associated tools. 2.3.A StudentAid.gov Digital Satisfaction

2.4.B Percentage of borrowers using auto-debit. 1.1.B Percentage of borrowers using auto-debit.

2.4.C Percentage of users who start and complete the 

Public Service Loan Forgiveness (PSLF) Help Tool 

by generating a PSLF form.

1.1.C Percentage of borrowers submitting 

applications through the PSLF Help Tool.

3.1.A FSA will annually conduct an Institutional Review 

for its participating partners including schools, thirdparty servicers, and financial institutions.

3.1.A Review for participating partners that have 

been provisionally certified.

3.2.A FSA will measure institutional participation rates in 

Title IV training and specialized technical 

assistance programs.

3.3.A. Institutional participation rates in Title IV

training and specialized technical assistance 

programs. 
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Performance Targets by Strategic Goals, 

Objectives, and Metrics 

In FY 2023, FSA had 32 performance indicators. Of these, 14 indicators were met or exceeded, 

1 indicator performed below the target, 16 indicators were baselined or did not have an 

established target and 1 indicator was not available before the publication of this Annual Report. 

The following tables present the performance indicators and their respective targets under the 

applicable FY 2023–27 Strategic Objective. To read more about performance measurement and 

target changes in FY 2023, refer to the Appendices section.

Table 11: Strategic Goal 1: Improve Customer Service and Outcomes for Students and 

Borrowers

Strategic Objective 1.1: Simplify the student loan repayment process to reduce future delinquency and 

default rates and improve accessibility of loan forgiveness programs.

Performance Indicators FY 2023 Target

1.1.A Number of borrowers that received loan forgiveness. Baseline

1.1.B Percentage of borrowers using auto-debit. Baseline

1.1.C Percentage of borrowers submitting applications through the PSLF Help 

Tool. Maintain or increase

Strategic Objective 1.2 Enhance the quality of contact center and loan servicing operations, leveraging 

data to assess progress toward customer service and product delivery 

standards.

Performance Indicator FY 2023 Target

1.2.A Percentage of contractor interactions reviewed that received a passing 

score. 

Baseline

Strategic Objective 1.3 Engage with stakeholders to improve delivery of student aid. 

Performance Indicator FY 2023 Target

1.3.A Surveys to third-party stakeholders. Implement survey

Strategic Objective 1.4 Address complaints and inquiries regarding financial aid products and services. 

Performance Indicators FY 2023 Target

1.4.A Timeliness of case handling. Baseline

1.4.B Accuracy of business process operations. Baseline

1.4.C Accuracy of first-level complaint response. Baseline
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Table 12: Strategic Goal 2: Advance Equity and Access to Student Financial Assistance

Strategic Objective 2.1: Enable financial education and empowerment by helping students and families 

understand the benefits and responsibilities of financing post-secondary 

education.

Performance Indicator FY 2023 Target

2.1.A Overall borrower satisfaction score for online counseling. Baseline

Strategic Objective 2.2: Simplify the Free Application for Federal Student Aid (FAFSA®) process.

Performance Indicator FY 2023 Target

2.2.A Customer satisfaction survey score associated with completing the Free 

Application for Federal Student Aid®. 78

Strategic Objective 2.3: Provide accurate, seamless, easy, and customized interactions throughout the 

student aid lifecycle.

Performance Indicators FY 2023 Target

2.3.A StudentAid.gov Digital Satisfaction. Maintain or increase

2.3.B StudentAid.gov Post-transaction Satisfaction. Baseline

2.3.C Contract Center Satisfaction. Baseline

2.3.D Email Campaign Helpfulness. Baseline

Table 13: Strategic Goal 3: Strengthen Engagement and Accountability for Educational 

and Financial Institutions

Strategic Objective 3.1: Utilize a comprehensive suite of monitoring tools to oversee participating 

partners. 

Performance Indicator FY 2023 Target

3.1.A Review for participating partners that have been provisionally certified. 40%

Strategic Objective 3.2: Build enforcement capabilities, in coordination with federal and state partners to 

protect students, families, and taxpayers from deceptive, fraudulent, or harmful 

practices in the student aid marketplace.

Performance Indicator FY 2023 Target

3.2.A Build and implement an FSA Enforcement Strategy that incorporates a 

risk model for identifying schools that pose risk to students and taxpayers. Develop strategic plan

Strategic Objective 3.3: Provide inclusive and effective partner outreach, training, and technical 

assistance.

Performance Indicator FY 2023 Target

3.3.A Institutional participation rates in Title IV training and specialized technical 

assistance programs. 75-80%
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Table 14: Strategic Goal 4: Increase Workforce and Workplace Capabilities

Strategic Objective 4.1: Promote workplace diversity, equity, inclusion, and accessibility.

Performance Indicators FY 2023 Target

4.1.A Federal Employee Viewpoint Survey Diversity and Inclusion Index: New 

Inclusion Quotient Index. Baseline 

4.1.B Percentage of qualified new hires and backfills coming from identified 

underrepresented workforce populations. Baseline

4.1.C Percentage of underrepresented populations included in organizational 

talent acquisition, promotion, and development/training activities. Baseline

4.1.D Percentage of employees participating in formal diversity, equity, 

inclusion, and accessibility efforts.

10-15% of total employee 

count

Strategic Objective 4.2: Attract, develop, and retain an agile workforce that can quickly respond to a 

changing environment and emerging priorities.

Performance Indicator FY 2023 Target

4.2.A Federal Employee Viewpoint Survey: Intrinsic Work Experience. Baseline 

Strategic Objective 4.3: Foster an organizational culture that promotes a productive, connected, and 

engaged workforce, particularly in a hybrid workplace environment.

Performance Indicators FY 2023 Target

4.3.A Federal Employee Viewpoint Survey: Employee Engagement Index. Maintain or improve by 1%

4.3.B Federal Employee Viewpoint Survey: Leader Lead. Maintain or improve by 1%

4.3.C Federal Employee Viewpoint Survey: Supervisors. Maintain or improve by 1%
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Table 15: Strategic Goal 5: Boost Operational Efficiency

Strategic Objective 5.1: Strengthen enterprise-wide data analytics and information management to foster 

a customer-centric, data-driven, performance-based organization.

Performance Indicators FY 2023 Target

5.1.A The Sum of Annual Data Maturity Assessment (DMA) for DMA 

Processing Areas. 56

5.1.B Successful maintenance and use of statistical models in Title IV

operations.

8 total number of new and 

existing modeling initiatives

5.1.C Implement new Statistical Modeling Initiatives. 2 total number new initiatives

Strategic Objective 5.2: Continuously improve systems, structures, and operations to enhance 

organizational efficiency and performance.

Performance Indicator FY 2023 Target

5.2.A Operational Performance. 

Investment portfolio aligned 

to key organizational drivers 

and current FY enacted 

appropriation. Investment 

portfolio achieves 75% of 

planned milestones. 

Organization/program risks 

are documented (Y/N)

Strategic Objective 5.3: Enhance procurement planning, management, and execution.

Performance Indicators FY 2023 Target

5.3.A Time-duration estimates for procurement-related tasks for use in Program 

Schedules.

Identify requisite tasks and 

durations for other 

procurement methods based 

upon law, regulation, policy, 

and historic performance

5.3.B Plan, develop and implement a new investment management process 

aligning acquisitions, budget, and human capital with program planning. Planning

Strategic Objective 5.4: Improve cybersecurity detection, prevention, and protection ensuring data 

confidentiality, integrity, and availability.

Performance Indicator FY 2023 Target

5.4.A Cybersecurity Maturity-Level (OIG Maturity Levels) 60% at Level 3 or higher
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Understanding the Annual Performance Report Section

The Annual Performance Report (APR) highlights FSA’s efforts to deliver greater impact 

through innovation, increasing effectiveness and efficiency, and delivering better customer 

service along with the Department.19

How to read the Annual Performance Report. This section of the Annual Report is organized 

by FSA’s five strategic goals. Each subsection provides an overview of the goal, the associated 

objectives, and performance indicators that support the strategic goal. Each section is 

structured in the following order:

• Strategic Goal Spotlight

• Strategic Objective Overview

• Performance Summary and Analysis

• Performance Indicator(s) 

• Key Successes and Opportunities

The detail provided for each performance indicator is as follows:

• Indicator Definition: Provides a brief explanation of the indicator and explains the 

factors used to measure the indicator. 

• Period of Performance: Indicates the time period of the data reference.

• Table: Identifies the performance indicator associated with the strategic goal and 

provides the historical actual results for the four previous fiscal years (if available); the 

target and actual result for the current fiscal year; and an indicator as to whether FSA 

met the performance indicator for each fiscal year reported. The following table is the 

legend for the performance indicator result.

Table 16: Performance Result Indicator Legend

Performance Result Indicator

Performance result met or exceeded the target. Met

Performance result did not meet the target. Not met

Performance result is baselined. Baseline data will provide a historical point of reference to 

inform program planning such as target setting. Baseline

Performance indicator is a new or revised indicator and prior year results are not available. –

Performance result is not applicable. N/A

Note: The reported performance indicator results are as of the end of the fiscal year (September 30), unless 

otherwise noted. Data as of the end of the fiscal year may not be available in some instances, such as when the 

required data are obtained from external sources including state and private nonprofit guaranty agencies; lenders and 

loan servicers; and grant and loan recipients. 

19 OMB Circular 11_Part 6
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Performance Results by Strategic Goals, Objectives, 

and Indicators

Strategic Goal 1: Improve Customer Service and Outcomes for 

Students and Borrowers

Goal Leader: Deputy Chief Operating Officer, Office of Student Experience and Aid 

Delivery

Table 17: Goal Objectives

Strategic Objective No. Strategic Objective

Strategic Objective 1.1

Simplify the student loan repayment process to reduce future 

delinquency and default rates and improve accessibility of loan 

forgiveness programs.

Strategic Objective 1.2

Enhance the quality of contact center and loan servicing operations, 

leveraging data to assess progress toward customer service and 

product delivery standards.

Strategic Objective 1.3 Engage with stakeholders to improve delivery of student aid.

Strategic Objective 1.4 Address complaints and inquiries regarding financial aid products and 

services.

Goal Spotlight

FSA continues to implement various enhancements that will provide an improved customer 

experience for students and borrowers, resulting in positive repayment outcomes and reduced 

defaults.

Signature and Submission 

The PSLF Help Tool, available on StudentAid.gov, helps borrowers determine whether they 

are eligible for PSLF, apply for forgiveness, and certify employment. Previously, a borrower 

would need to use the PSLF Help Tool to determine their eligibility; print and sign the PSLF 

Form & Temporary Expanded PSLF (TEPSLF) Certification & Application Form; have one or 

more employers sign the paper form; and submit the completed form by mail, fax, or by 

uploading their form to the PSLF servicer portal if their loans were already assigned to 

MOHELA. In April 2023, as part of the 6.2 Digital and Customer Care (DCC) Release, 

borrowers can, for the first time, fully complete the PSLF application process digitally with the 

help of the new digital signature and submission components of the PSLF Help Tool. The 

redesigned tool allows borrowers to: 

• sign and submit the PSLF Form digitally on StudentAid.gov, 

• identify employers that need to sign their PSLF Form and send requests for e-signature 

via DocuSign, 

• track the status of their PSLF Form in their account’s Status Center, and 
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• digitally sign and submit PSLF forms for processing and updates to a borrower’s 

progress with the PSLF program. 

PSLF Help Tool 

FSA updated the PSLF Help Tool to increase transparency for borrowers and streamline the 

employer review process for the PSLF Servicer when an employer’s eligibility changed over 

time. With the introduction of the new 'Split' employer eligibility status in the PSLF Help Tool, the 

Digital Platform will now display 'Undetermined' eligibility statuses for users whose period of 

employment overlaps with an undetermined period. This new view will allow borrowers to more 

clearly see which periods of their employment are inapplicable towards their PSLF qualification.

PSLF Regulatory Implementation

On November 1, 2022, the Department published final new regulations governing PSLF in the 

Direct Loan program. These regulatory changes included updates to the application process, 

definitions for full-time employment, qualifying employers, and qualifying monthly payments. On 

July 1, 2023, these new regulations for PSLF became effective and FSA’s implementation 

efforts included updating processes, procedures, systems, and information for borrowers on 

these changes.
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Strategic Objectives and Performance Indicators 

Strategic Objective 1.1

Simplify the student loan repayment process to reduce future delinquency 

and default rates and improve accessibility of loan forgiveness programs.

Strategic Objective Leader: Deputy Chief Operating Officer, Office of Student 

Experience and Aid Delivery

Overview

FSA implemented customer and stakeholder outreach campaigns that provided repayment 

options and loan forgiveness information to better inform students and borrowers, resulting in 

positive repayment outcomes and reduced defaults. The campaigns included:

• The always-on email campaigns, such as TEDI, TPDR scam intervention, and borrower 

risk at time of disbursement aim to reduce future delinquency and default.

• Produced D2D files for PSLF and Account Adjustment, leading to full forgiveness for 

many borrowers and additional months of credit toward forgiveness for many others.

• Regularly supported policymakers at the Department, OMB, and Congress with analysis 

and modeling on options for the repayment process.

• Multiple email and short message service (SMS) outreach campaigns focusing on PSLF, 

return to repayment, Fresh Start, auto-debit, Supreme Court decision, and IDR plans, 

including the SAVE plan.

Performance Summary and Analysis

There are three performance indicators for this strategic objective. Two performance indicators 

completed a baseline assessment in FY 2023, which will be used to set targets for future years. 

One performance indicator met its FY 2023 target.
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Performance Indicators 

Performance Indicator 1.1.A: Number of borrowers that received loan forgiveness.

Indicator Definition: This performance indicator measures the number of total borrowers who 

receive loan forgiveness through the PSLF, Borrower Defense, TPD, and IDR Programs. 

Account Adjustment D2D forgiveness will impact the July 2023–June 2024 results for this 

Indicator.

Period of Performance: July 2022 through June 2023.

Table 18: Performance Indicator 1.1.A 

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 1.32 

million

Performance Result N/A N/A N/A N/A Baseline

Performance Indicator 1.1.B: Percentage of borrowers using auto-debit. 

Indicator Definition: This performance indicator measures the percentage of borrowers 

actively enrolled in auto-debit repayments. The numerator is the number of borrowers who are 

in a repayment status that the Title IV Additional Servicers (TIVAS) and Not-For-Profits (NFPs) 

report with the auto-debit bill type. The denominator is the total number of borrowers in the 

repayment plan universe: statuses of repayment, deferment, and forbearance. Bill type is 

reported with repayment plan, repayment term, and similar elements. Restricting to only 

repayment/delinquency status would be self-selecting, as borrowers using auto-debit are more 

likely to pay on-time. In any case, Return to Repayment will greatly reduce the numbers of 

borrowers in forbearance and will facilitate increases in auto-debit usage in coming years.

Period of Performance: Point in time, June 30 annually.

Table 19: Performance Indicator 1.1.B

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A 24.8% N/A N/A Baseline 20.9%

Performance Result N/A Baseline N/A N/A Baseline

Note: This indicator was paused during FY 2021–22 due to the COVID-19 pandemic. It was restarted and 

baseline in FY 2023.
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Performance Indicator 1.1.C: Percentage of borrowers generating applications through the 

PSLF Help Tool.

Indicator Definition: This performance indicator measures the percentage of borrowers who 

start a PSLF form and save a completed PSLF form. The numerator is the number of 

authenticated users that initiate a PSLF form via the PSLF Help Tool. The denominator is the

total number of authenticated users that generate a completed PSLF Form via the Help Tool.

Period of Performance: October 2022 through September 2023.

Table 20: Performance Indicator 1.1.C

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A 34.5% 56.7% Maintain or 

increase 60.5%

Performance Result N/A N/A Baseline Met Met

Key Successes and Opportunities

The limited PSLF waiver opportunity was introduced in FY 2022 on October 6, 2021, and ended 

on October 31, 2022. Beginning November 1, 2022, the “normal” program requirements 

resumed for PSLF and TEPSLF. In FY 2023, FSA implemented wind down efforts for the limited 

PSLF waiver with procedures, processes, updates to borrower communications, and reporting. 

While the limited PSLF waiver ended on October 31, 2022, borrowers are still receiving updates 

to their PSLF payment counts and forgiveness as PSLF forms are processed. As of mid-July 

2023, more than 662,000 borrowers have been identified for $45.6 billion in forgiveness under 

the limited PSLF waiver. 

With the introduction of PSLF e-signature and submission during FY 2023, FSA expects to see 

a continued increase in users who access the PSLF Help Tool and concluding the process by 

generating a completed PSLF form. The introduction of the e-signature and submission process 

has been the key driver in the increase for FY 2023. 

Note that the limited PSLF waiver period (October 6, 2021 – October 31, 2022) caused a 

significant increase in the traditional Help Tool initiation volume.
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Strategic Objective 1.2

Enhance the quality of contact center and loan servicing operations, 

leveraging data to assess progress toward customer service and product 

delivery standards. 

Strategic Objective Leader: Deputy Chief Operating Officer, Office of Student 

Experience and Aid Delivery

Overview

FSA faced significant changes to the Direct Loan portfolio when contracted partners exited the 

program. These contract partners were responsible for servicing federal student loans by 

providing contact center operations, back-office processing (e.g., collecting payments and 

processing applications), and other administrative support associated with maintaining a federal 

student loan. In addition, there were several high-risk, high-profile regulations, and policy 

changes introduced, such as the FAFSA modernization, simplification, and IRS Financial 

Transaction data sharing initiative, IDR forgiveness policy, Fresh Start, and Return to 

Repayment for more than 40 million borrowers. As a result, FSA was responsible for 

overseeing, tracking, and remediating millions of federal student loans for each of these events. 

Oversight groups within FSA, with finite resources, were responsive to these events and 

implemented oversight methodologies to review borrower and loan status and servicers’ 

process and outcomes to ensure regulations and requirements were being met and followed.

FSA preciously set a framework for oversight which put a stronger focus on key performance 

indicators and contractual service level agreement metrics aimed at delivering more effective 

outcomes for students and greater value to taxpayers. This framework was the foundation for 

the shifts in oversight throughout the organization. 

Performance Summary and Analysis

There is one performance indicator for this strategic objective. This performance indicator 

completed a baseline assessment in FY 2023, which will be used to set targets for future years. 

In FY 2023, FSA’s Vendor Oversight Group (VOG) conducted several thousand customer 

interaction quality monitoring for four Direct Loan servicing call centers. Due to staffing 

shortages and a substantial increase of call volume related to the Debt Relief program, Fresh 

Start, return to repayment, and the new SAVE Plan, the effective sample size for interaction 

quality monitoring was not reached.  These customer interaction quality monitoring reviews are 

labor-intensive.  These reviews require staff to listen and score borrower calls, review borrower 

accounts in loan servicer systems, thoroughly annotate the call, and conduct any follow-up 

actions that are needed to ensure the customer service representative properly handled the 

call.  All customer interaction quality monitoring reviews conducted are final and all 

recommendations and/or corrective actions are being tracked and monitored.
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Performance Indicator

Performance Indicator 1.2.A Percentage of contractor interactions reviewed that received a 

passing score. 

Indicator Definition: The indicator measures the percentage of contractor interactions that 

were reviewed and received a passing score (95%) as defined in their Service Level 

Agreements.

Period of Performance: October 2022 through September 2023.

Table 21: Performance Indicator 1.2.A

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 98.1% 

Performance Result N/A N/A N/A N/A Baseline

Key Successes and Opportunities

In late FY 2021, several loan servicers informed FSA that they would not continue their student 

loan servicing past their current contracts. This meant that a significant portion of the Direct 

Loan portfolio would transfer to new servicers. The VOG was responsible for providing oversight 

for this process and focused on loan transfer reviews in FY 2022 and FY 2023.

In FY 2023, VOG finalized remediation plans for millions of student loans that were transferred 

(automated and manual) and closed out the transfers in September 2023. The oversight reviews 

were finalized in FY 2023 and, more than 500 transfer related issues were identified,

remediated, and closed. VOG notified servicers of the final status through final reports.

In preparation of borrowers returning to repayment status, VOG conducted more than 900 

secret shopper calls. Secret shopper calls involve VOG staff calling servicing call centers to ask

representatives questions related to program changes, such as IDR plans and the new SAVE 

program, direct discharge on IDR and PSLF, along with other topics germane to return to 

repayment. VOG shared the results of the secret shopper calls with the FSA internal stake 

holders as well as the servicers.

In addition to all the oversight activities that VOG performed in FY 2023, VOG also prepared 

oversight activities for Return to Repayment in the fourth quarter of FY 2023. The team 

documented borrower and collaborative external partners concerns including IDR questions 

regarding payment calculations, due dates, and borrower defense status.

Targeted monitoring reviews of Servicing Level Agreements (SLAs) were implemented in 

FY 2022 and effectuated in FY 2023. The SLAs are contractual required performance criteria 

agreed upon by FSA vendors. These performance measures are intended to motivate vendors 

to provide high levels of service for FSA’s customers. They also facilitate FSA in holding 

vendors accountable when performance falls short of expectations.

Escalated servicer issues where the item(s) are to be reported in VOG’s Analytics, Compliance, 

Evaluation and Remediation System (ACERS), or as CAP referrals. ACERS items are also 
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topics of discussion in touchpoints with vendors. Outstanding ACERS issues are reviewed 

regularly by the Vendor Management team and with the servicers and VOG as needed. There 

are multiple meeting forums where ACERS and CAPS are reviewed and discussed.
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Strategic Objective 1.3 

Engage with stakeholders to improve delivery of student aid. 

Strategic Objective Leader: Ombudsman, Office of the Ombudsman

Overview

FSA’s authorizing statute mandates consultation with stakeholders regarding their degree of 

satisfaction with the federal student aid delivery system, including aid disbursement, school 

satisfaction, and loan repayment. It also requires that FSA solicit stakeholder suggestions to 

improve federal aid delivery. The Ombudsman Office’s Stakeholder Engagement Group helps to 

satisfy this obligation by regularly meeting with a variety of stakeholders in the form of listening 

sessions, briefings, and webinars. The group solicits feedback on the stakeholder experience by 

surveying meeting participants about key metrics. 

• During FY 2023, the Stakeholder Engagement Group held more than 100 meetings with 

stakeholders, including state attorneys general, state student loan ombudsmen, legal aid 

organizations, research organizations, consumer advocacy groups that represent 

students and borrowers, civil rights groups, trade associations, and more.

• Following each listening session, the Stakeholder Engagement Group invited 

participants to complete a survey that collected feedback on FSA’s delivery of student 

financial aid, as well as on its strengths, areas for improvement, responsiveness, and 

accessibility. During FY 2023, FSA received 23 responses to the survey. In assessing 

FSA’s responsiveness to feedback, listening and valuing input, and accessibility, 

respondents rated the agency 8 out of 10. 

• In late FY 2023, the Stakeholder Engagement Group updated the survey to better 

capture actionable feedback from stakeholders that identify areas in need of 

improvement. In FY 2024, the group will launch the new survey and explore methods to 

increase the response rate.

Performance Summary and Analysis

There is one performance indicator for this strategic objective. The performance indicator was 

baselined this performance year, which will be used to set targets for future years. Additionally, 

as the Stakeholder Engagement Group expands its efforts in outreach and financial literacy, it 

will implement new, targeted measurements to evaluate the effectiveness of those efforts.
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Performance Indicator

Performance Indicator 1.3.A Surveys to third-party stakeholders.

Indicator Definition: This performance indicator measures the satisfaction of stakeholders in 

FSA’s solicitation of their opinions, priorities, and view of the delivery of Title IV aid.

Period of Performance: October 2022 through September 2023.

Table 22: Performance Indicator 1.3.A

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Implement 

Survey

Survey 

Implemented

Performance Result N/A N/A N/A N/A Met

Note: The revised survey was completed in September 2023 and will be launched in FY 2024.

Key Successes and Opportunities

• The Stakeholder Engagement Group developed a new stakeholder engagement tracking 

system, which will be implemented in FY 2024 and will increase transparency on the 

number and type of engagements and stakeholder responses. The system will also 

centralize the data used to complete the annual performance report. 

• During FY 2023, the Stakeholder Engagement Group expanded its engagement with 

underserved communities, including military families, communities of color, and persons 

with disabilities. In FY 2024, the group will work to expand its reach to ensure additional 

constituencies have their voice heard, including persons living in rural communities and 

LGBTQ+ students and borrowers. 

• The survey of stakeholders is an inherently limited metric because it only collects 

opinions from those stakeholders who have an existing relationship with FSA through 

the Stakeholder Engagement Group. As such, survey results may provide an inflated 

view of FSA’s delivery efforts (e.g., the survey only asks about accessibility to those who 

have access). In FY 2024, the Stakeholder Engagement Group intends to partner with 

FSA’s Organizational Health and Impact team to robustly evaluate which populations are 

not well-represented through existing channels. The teams will explore opportunities to 

build out those relationships with the goal of identifying disconnects between Title IV

program policy and its delivery.
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Strategic Objective 1.4 

Address complaints and inquiries regarding financial aid products and 

services. 

Strategic Objective Leader: Ombudsman, Office of the Ombudsman

Overview

The Student Loan Ombudsman is an independent, statutory role, established in part to resolve 

complaints from student and borrowers. As such, the Ombudsman Office manages FSA’s 

complaint system and directly handles escalated complaints from students and borrowers. The 

FSA Ombudsman works with a range of Title IV stakeholders, including loan servicers, 

Business Process Operations (BPO) vendors, other FSA business units, consumer advocates, 

and most importantly, student loan borrowers, to both resolve individual complaints and ensure 

FSA is reducing barriers that may impede student and borrower success. 

In general, complaints received through the FSA complaint system are first routed to the entity 

against which the complaint is filed for an initial review and response. If the student or borrower 

is unsatisfied with that response, he or she may escalate the complaint to the Ombudsman 

Office for further review. 

To achieve FSA strategic goal 1.4 and fulfill the Ombudsman’s statutory obligations, the 

Ombudsman Office performed four functions in FY 2023: 

• Dispute resolution – the investigation and resolution of individual, escalated complaints; 

• Complaint research and analysis – the evaluation of complaint trends to inform 

identification of systemic breakdowns, organizational priorities, and recommendations for 

improvements; 

• Complaint quality management – the oversight of the FSA complaint system and 

associated vendors to ensure a positive customer experience; and 

• Stakeholder engagement – the promotion of FSA’s resources, including the availability 

of the Ombudsman, within communities as a trusted resource for students and 

borrowers, and soliciting feedback about ways to improve the Title IV aid experience.

The Ombudsman Office is integrated with the broader FSA NextGen strategy to enhance the 

complaint management system and process. Beginning in October 2021, FSA made significant 

improvements to the visibility of its complaint tool, which resulted in a substantial increase in 

complaint submissions. That same year, as part of FSA’s effort to modernize how it engages 

with aid recipients, it transitioned to a BPO vendor model. This transition included modifications 

to the intake, routing, and resolution of complaints. As a result of these changes, FSA 

developed specific performance metrics to assess the timeliness, quality, and accuracy of 

complaint handling operations beginning in FY 2023.
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Performance Summary and Analysis

There are three performance indicators for this strategic objective. During FY 2023, these three 

indicators established baseline assessments which will be used to set targets for future years.

Performance Indicators

Performance Indicator 1.4.A Timeliness of case handling.

Indicator Definition: This performance indicator measures the number of cases that were 

closed in a timely manner.

Period of Performance: October 2022 through September 2023.

Table 23: Performance Indicator 1.4.A

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 78%

Performance Result N/A N/A N/A N/A Baseline

Note: FSA’s goal is to close 95% of cases within 60 calendar days. In FY 2023, FSA closed 115,335 

cases. Of those cases, 78% (90,327) met the 60-day case closure timeliness requirement. Of the 22% 

(25,008) that did not meet timeliness requirements, 54% (13,599) were processed by MOHELA. The high 

number of cases not meeting the requirement may be attributed, in part, to a backlog of complaints 

related to the limited PSLF waiver Program which ended in October 2022. Additionally, borrowers faced 

delays in receiving timely responses to their complaints following servicing transfers, particularly where 

receiving-servicers delayed loading account data onto their systems. FSA understands the importance of 

timely case closure and the Ombudsman monitors case timeliness regularly through both the Quality 

Management Program and regular reviews of Ombudsman staff casework.

Performance Indicator 1.4.B Accuracy of business process operations.

Indicator Definition: This performance indicator measures the accuracy with which Business 

Process Operations (BPO) populate the data fields and route the cases within Salesforce.

Period of Performance: October 2022 through September 2023.

Table 24: Performance Indicator 1.4.B 

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 58%

Performance Result N/A N/A N/A N/A Baseline

Note: Due to resource constraints, specifically staffing shortages, the Ombudsman Office was unable to 

operationally stand up its internal quality management (QM) program until August 2023. The program is 

designed to establish, monitor, and evaluate the quality of vendor engagement and services across the 

complaint lifecycle. FSA’s quality management program was able to fully perform one accuracy review of 

BPO vendors in FY 2023. To complete the review, FSA selected a sample of BPO cases and evaluated 

vendor performance in categorizing and triaging incoming cases. Because a case category and 

subcategory can change during the casework process, FSA limited sample selection to only cases 

categorized and worked by BPO vendors. The QM Group then selected a random sample of 1% of
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annual cases only worked by BPOs (747 cases) to review for accuracy. The QM Group also completed a 

10% secondary quality review of the sample to ensure staff accurately evaluated the BPO vendor.

The QM Group determined that the BPO accuracy rate was 58%, meaning BPOs miscategorized cases 

approximately 42% of the time, which leads to significant issues in data quality and delayed responses to 

borrowers. During the review, FSA determined that several gaps to accurately measure and evaluate the 

quality of BPO and vendor performance exist. Specifically, the categories have not been updated to align 

with the current FSA operational environment, which is designed around task-based contracting. 

Combined with the overly cumbersome interface of the complaint system, the task-based pricing model 

prioritizes volume and speed over accuracy, which may result in BPO agents opting for the easiest-toselect category rather than the most accurate category.

Performance Indicator 1.4.C Accuracy of first-level complaint response.

Indicator Definition: This performance indicator measures the quality and accuracy of the 

complaint responses provided by FSA vendors.

Period of Performance: October 2022 through September 2023.

Table 25: Performance Indicator 1.4.C

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 32.1%

Performance Result N/A N/A N/A N/A Baseline

Note: As stated above, FSA did not implement the Ombudsman QM program until August 2023. FSA’s 

quality management program completed one accuracy review of BPO vendors in FY 2023. To complete 

the review, FSA selected a sample of closed BPO and Direct Loan Servicer cases and evaluated vendor 

performance using a pre-established scorecard. During the review, FSA determined the scorecard does 

not meet the operational needs and performance expectations of the Ombudsman and will be revamped 

in early FY 2024. Going forward, FSA will continue to review for vendor accuracy and will develop 

additional monitoring and evaluation tools and an accountability framework that reflects the updated 

scorecard.

The QM Group sampled 154 BPO and 251 Direct Loan servicer closed cases during the month of 

September to review for quality. The QM Group determined that 63.6% of the BPO cases sampled did not 

meet the passing score of 85%, and 70.5% of servicer cases did not meet the passing score of 85%. 

Further, the QM group identified that in the main quality category, “Issue Resolution,” was far below the 

target quality metrics. 

A quality assurance score of 85% is based on the industry standard for quality assurance in customer 

satisfaction for call center monitoring and is utilized to gauge and lower the probability of customers 

reentering the FSA complaint system due to poor experience with issue resolution. Our current QA 

scoring evaluates services provided based on defined customer experience and case review compliance 

metrics. While the small sample size described above limits FSA’s ability to infer trends or make holistic 

assessments about vendor performance, the findings did provide enough data to determine that prior 

quality monitoring efforts lacked the necessary rigor to establish appropriate interventions to the improve 

customer service experience.
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Key Successes and Opportunities

In April 2023, FSA completed a systematic review of customer complaints processed by BPO 

vendors and determined that further improvements and enhancements to the complaint system 

were necessary to effectively respond to customer complaints and meet performance indicators. 

As a result, FSA initiated a multi-phase improvement effort which includes modernizing the 

complaint system operational flow, insourcing significant portions of complaint handling from 

BPO vendors to FSA, and establishing a quality management program to ensure accountability 

where vendors engage with customer complaints. FSA believes these improvements will 

resolve a long-standing organizational risk of outsourcing escalated complaint handling to 

vendors, improve customer response quality, decrease the number of reopened complaints, and 

reduce the annual operating costs associated with BPO vendors.

FSA is investing in modernizing its complaint case management and processing system, called 

the Feedback and Dispute Management System (FDMS). FSA has a longstanding goal of 

establishing a single point of entry for its customers. Therefore, to the greatest extent possible, 

the technical aspects of operations are housed in FSA’s DCC system. FDMS is an independent 

“line of business” within the DCC platform. The first phase of the FDMS modernization effort is 

scheduled to be implemented in March 2024 and will include the automatic routing of complaint 

cases based on customer category selections. User-testing shows that automatic routing will 

improve case routing accuracy, while simultaneously reducing BPO operational costs. 

Additional improvements to case categorization, case layout, and internal workflows are 

planned for FY 2024, however remain contingent upon resource availability. 

In addition to insourcing complaint processing, FSA has transitioned key complaint handling 

functions from BPOs to FSA staff. Since 2015, the Ombudsman Office has outsourced 

complaint research and resolution to vendors. FSA has identified this outsourcing as a risk to 

the agency, particularly in the BPO environment where vendors are often the same entities 

against which a customer is complaining. In June 2023, FSA began insourcing specific case 

types – escalations, disputes, and control mail – from BPO vendors to FSA staff. FSA believes 

insourcing complaint work will significantly increase the accuracy and quality of responses and 

improve the borrower experience. As of July 2023, all new escalated complaints were assigned 

to FSA staff and BPO vendors were only processing previously assigned cases. A second 

phase of case type insourcing will begin in FY 2024. 

To support the monitoring and oversight of Strategic Objective 1.4, the Ombudsman instituted a 

Quality Management (QM) program in FY 2023 to promote and improve response quality and 

reduce the number of complaint escalations. The QM Group has identified multiple challenges 

with the current scorecard and oversight process and will make improvements in FY 2024. 

The QM Group’s challenges with the existing quality and accuracy analysis include:

• Preliminary analysis of the September sample revealed that the existing scorecard 

weights metrics in a manner that does not promote quality customer service. For 

example, a vendor could appropriately access the complaint system, but fail to 

substantively respond to the customer, and still receive a passing score. As a result, the 

vendor would be deemed to have satisfied the SLA, but FSA would not have achieved 

its customer service goals. 
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• An 85% quality score metric is not required within current SLAs but should be 

maintained to align with industry best practices and to ensure quality issue resolution 

and lower the probability of a customer reentering the FSA complaint system. Without 

increased performance standards for complaint handling, vendors will not prioritize 

investing in complaint resolution. 

• Current analysis is based on a small sample size, and not significant to show trends or 

make assumptions about future vendor output. The analysis was significant enough, 

however, to reveal gaps with FSA’s current scoring mechanism. 

The QM Group will review an average of 500 case categorizations monthly and provide 

feedback and additional training to BPO vendors based on results. The sample will be 

monitored and adjusted when necessary to ensure a representative sample of the case 

population is consistently reviewed. Operationally, FSA will conduct monthly meetings with 

vendors to review issues, discuss opportunities for improvement, provide instruction to address 

frequent pain point areas, and develop additional guidance documents to correct case 

categorization issues. Additionally, as mentioned above, the Ombudsman Office is working to 

streamline the complaint system interface to improve vendors’ ability to timely and accurately 

address complaints.
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Strategic Goal 2: Advance Equity and Access to Student 

Financial Assistance

Goal Leader: Deputy Chief Operating Officer, Office of Student Experience and Aid 

Delivery 

Table 26: Goal Objectives

Strategic Objective No. Strategic Objective

Strategic Objective 2.1

Enable financial education and empowerment by helping students 

and families understand the benefits and responsibilities of financing 

post-secondary education.

Strategic Objective 2.2 Simplify the Free Application for Federal Student Aid (FAFSA®) 

process. 

Strategic Objective 2.3 Provide accurate, seamless, easy, and customized interactions 

throughout the student aid lifecycle. 

Goal Spotlight

Digital and Customer Care is a key initiative to drive performance towards achieving the 

strategic goal. Four significant releases in FY2023 expanded and improved the features and 

capabilities of StudentAid.gov. In addition to these planned releases, StudentAid.gov is often 

asked to respond quickly to changing or new priorities. FSA used a highly integrated, 

collaborative approach to lead and manage changes and new priorities with the vision of 

meeting customer and business needs. These efforts have led to a better user experience, 

continued strong customer satisfaction scores, growth/increase in customer use of 

StudentAid.gov features (tools, forms/applications, content), and advancement of a single, 

digital “door” for customer engagement with FSA. Significant improvements to the Digital 

Platform include:

• Released the 2023-24 FAFSA form with FAFSA Simplification updates.

• Released the Student Loan Debt Relief Application in support of the Administration’s 

student debt relief plan. While the Supreme Court issued a decision blocking the 

Department from moving forward with this plan, the application demonstrated FSA’s 

ability to rapidly deliver a customer-focused and effective form. 

• Updated the PSLF Help Tool to provide borrowers with e-signature and submission 

functionality. 

• Released new IDR application that integrates with IRS’ Federal Tax information 

capability and supports borrower enrollment in the new SAVE IDR plan.

• Updated Borrower Defense, PSLF, and TEPLSF forms based on regulatory changes.

• Provided borrowers with the ability to view the status of their IDR application, loan 

consolidation application, and PSLF form in their Dashboard and My Activity. 

In addition to the updates to the Digital Platform, FSA implemented several key communications 

within the Marketing Communications Platform (MCP). These communications enabled the 
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organization to provide important information to its customers, such as filling out their FAFSA 

forms and planning for returning to student loan payments. 
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Strategic Objectives and Performance Indicators 

Strategic Objective 2.1 

Enable financial education and empowerment by helping students and 

families understand the benefits and responsibilities of financing postsecondary education. 

Strategic Objective Leader: Deputy Chief Operating Officer, Office of Student Experience and 

Aid Delivery 

Overview

StudentAid.gov is FSA's primary customer-facing website that provides critical information and 

tools for students, families, and borrowers as they prepare and plan for college, apply for and 

receive federal student aid, and repay student loans. For this reason, StudentAid.gov plays a 

critical role in supporting the Department’s and FSA’s strategic goals and priorities. FSA 

supported multiple releases in FY 2023 that expanded and improved the features and 

capabilities of StudentAid.gov. 

Performance Summary and Analysis

There is one performance indicator for this strategic objective. Overall borrower satisfaction 

score for online counseling measure baselined its annual indicator target.

Performance Indicator 

Performance Indicator 2.1.A: Overall borrower satisfaction score for online counseling.

Indicator Definition: This performance indicator will measure borrower comprehension and 

satisfaction with the different online counseling (i.e., Annual Student Loan Acknowledgement, 

Entrance Counseling, Exit Counseling, Teacher Education Assistance for College and Higher 

education (TEACH), and Parent Loan for Undergraduate Students (PLUS) Credit Counseling).

Period of Performance: October 2022 through September 2023.

Table 27: Performance Indicator 2.1.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 90

Performance Result N/A N/A N/A N/A Baseline
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Key Successes and Opportunities

FSA paid close attention to user feedback in reviews pertaining to the various online counseling 

tools found on StudentAid.gov and their functionality (Annual Student Loan Acknowledgment, 

Entrance Counseling, Exit Counseling, TEACH, and Parent Loan for Undergraduate Students 

(PLUS) Credit Counseling). Based on the feedback FSA received, FSA continues to improve 

these counseling tools by enhancing the user experience and clearly communicating the 

information presented to borrowers. FSA's commitment to producing high-quality tools is evident 

by the positive feedback and exceptional scores received from valued users, as reflected in this 

year's annual report.
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Strategic Objective 2.2 

Simplify the Free Application for Federal Student Aid (FAFSA®) process.

Strategic Objective Leader: Deputy Chief Operating Officer, Office of Student Experience and 

Aid Delivery 

Overview

Getting students, parents, and counselors around the country focused on increasing 

completions of the FAFSA form for the 2023–24 academic year remains a top priority for FSA. 

Whether a student is attending a traditional four-year college or university, enrolling in a 

community college, or opting for a trade or vocational certification, the FAFSA form should be 

the first step forward for every high school senior in the United States. FSA encouraged highschool seniors and their families to complete the 2023–24 FAFSA form. FSA worked with 

individual states, counselors, mentors, and college access professionals on initiatives to 

improve FAFSA completion rates.

FSA posted social media posts related to the FAFSA form and published other digital content 

including helpful articles on StudentAid.gov. FSA engaged local media outlets to raise 

awareness about the importance of completing the FAFSA form.

Performance Summary and Analysis

There is one performance indicator for this strategic objective. The customer satisfaction survey 

score associated with completing the FAFSA measure met its annual indicator target in 

FY 2023. 

Performance Indicator 

Performance Indicator 2.2.A: Customer satisfaction survey score associated with completing 

the Free Application for Federal Student Aid®.

Indicator Definition: This performance indicator measures the applicant’s satisfaction with 

completing the Free Application for Federal Student Aid®.

Period of Performance: October 2022 through September 2023.

Table 28: Performance Indicator 2.2.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A 78 80

Performance Result N/A N/A N/A N/A Met
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Key Successes and Opportunities

Through customer listening sessions, questions from customers via Aidan (chatbot), and survey 

responses, FSA heard loudly that customers were struggling to find their Student Aid Report 

(SAR). As a result, FSA moved the “View SAR” button to be the first option on the My FAFSA 

page. 

Additional changes made as a result of customer listening include changing the order of the 

"Renew My FAFSA Form" and "Start a New FAFSA Form" buttons, making it more intuitive to 

renew the form (and thereby answer fewer questions), ensuring that unauthenticated users 

have a better user experience by providing a more direct route to the FAFSA form once they 

have logged in, and providing additional guidance to students who are experiencing housing 

insecurity on how to apply for federal aid.
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Strategic Objective 2.3 

Provide accurate, seamless, easy, and customized interactions throughout 

the student aid lifecycle.

Strategic Objective Leader: Deputy Chief Operating Officer, Office of Student Experience and 

Aid Delivery 

Overview

FSA has continued to monitor and improve the customer channels across the student aid 

lifecycle. Channels that we have worked on include StudentAid.gov, our contact process 

operations (BPO) vendors, and Marketing Communications Platform (MCP). FSA continued to 

consolidate and improve services on StudentAid.gov, make data-informed improvements to 

our BPO operations, and deliver key customer outreach campaigns and communications at 

scale. By leveraging insights based on available data (as well as customer listening and 

usability research), FSA has been able to make informed decisions on our features and 

communications.

Performance Summary and Analysis

There are four performance indicators for this strategic objective. One measure (2.3.A 

StudentAid.gov Digital Satisfaction) met the annual indicator target. Three measures (2.3.B 

StudentAid.gov Post-transaction Satisfaction, 2.3.C Contact Center Customer Satisfaction, and 

2.3.D Email Campaign Helpfulness) were baseline for the FY 2023 annual performance year. 

FSA expects to meet or exceed these indicators in the following year based on improvements 

that have been made to key customer flows in FY 2023, such as the IDR application and loan 

consolidation application. The Email Campaign Helpfulness consisted of high priority and time 

sensitive communications. FSA informed our borrowers on updates and reminders regarding 

returning to repayment, IDR plans, debt relief, as well as the pages and information that may be 

relevant to our students, parents, and borrowers. A good portion of the larger campaigns were 

around Return to Repayment and IDR Plans which may adversely affect scores.
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Performance Indicator 

Performance Indicator 2.3.A: StudentAid.gov Digital Satisfaction.

Indicator Definition: This performance indicator measures customers’ overall satisfaction with 

StudentAid.gov. 

Period of Performance: October 2022 through September 2023.

Table 29: Performance Indicator 2.3.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A No survey 

developed

Developed 

survey

3.6 Maintain or 

increase

72

Performance Result N/A Not met Not met Baseline Met

Note: For 2.3.A, FSA will still ask customers for their satisfaction on a 5-point scale; however, for 

reporting purposes, FSA will then convert the score to 0-100 using the following formula: Formula: x = 

((Y/100)*4) + 1 x = 1-5 scale# Formula: Y = ((x - 1)/4)*100 Y = 0-100 scale#. The FY 2022 converted 

version will be 66. Based on the converted score, FSA met the target for FY 2023.

Performance Indicator 2.3.B: StudentAid.gov Post-transaction Satisfaction.

Indicator Definition: This performance indicator measures customers’ overall satisfaction after 

completing a transaction on StudentAid.gov. 

Period of Performance: October 2022 through September 2023.

Table 30: Performance Indicator 2.3.B Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 83

Performance Result N/A N/A N/A N/A Baseline

Performance Indicator 2.3.C Contact Center Customer Satisfaction.

Indicator Definition: This performance indicator measures customers’ overall satisfaction 

based on their interactions with FSA contact centers that are operated by BPO vendors.

Period of Performance: October 2022 through September 2023.

Table 31: Performance Indicator 2.3.C Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 71

Performance Result N/A N/A N/A N/A Baseline
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Performance Indicator 2.3.D Email Campaign Helpfulness.

Indicator Definition: This performance indicator measures the helpfulness of FSA’s email 

campaigns as rated by customers who receive campaign emails.

Period of Performance: October 2022 through September 2023.

Table 32: Performance Indicator 2.3.D Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 79

Performance Result N/A N/A N/A N/A Baseline

Key Successes and Opportunities

StudentAid.gov Digital and Post Transaction Satisfaction: StudentAid.gov and the 

products it supports leverage customer feedback through surveys, usability testing, and other 

mechanisms to inform improvements. In FY 2023, many improvements were made to 

StudentAid.gov that improved the user experience. The following are some highlights:

• Updated the PSLF Help Tool to provide borrowers with e-signature and submission 

functionality. 

• Released new IDR application that integrates with IRS’ Federal Tax information 

capability and supports borrower enrollment in the new SAVE IDR plan.

• Provided borrowers with the ability to view the status of their IDR application, loan 

consolidation application, and PSLF form in their Dashboard and My Activity.

• Improved website navigation.

• Delivered more than 120 smaller improvements.

As a result of these improvements, StudentAid.gov saw a significant improvement in its digital 

satisfaction score from last year increasing from 66 to 72, and it maintained its high post 

transaction satisfaction score.

Contact Center Customer Satisfaction: FSA is focused on supporting students, families, and 

borrowers as they navigate the financial aid process. Optimizing the customer service model 

throughout the student aid lifecycle is critical to this effort and adopting more service-oriented 

and streamlined approaches at the contact centers help improve the customer’s experience. 

Exceptional customer service will increase FSA’s ability to adapt to changing customer needs 

and ensure that customers easily understand the available options to make informed choices. 

The following are some highlights:

• The overall trend for customer experience scores remained strongly positive with 

satisfaction improving 3 points (on 100-point scale) from the prior fiscal year.

• Agent performance, time on the phone, and trust in information provided continued to 

score strongly.
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• Reduced hours of operation from April 2023, BPO’s continued to successfully handle 

customer interactions with a positive experience.

FSA has observed opportunities for improvement such as our ability to deliver training to BPO 

agents to optimize customer satisfaction and resolution in all channels of service. Additionally, 

FSA frequently engages with BPO vendors to ensure escalation of regular or recurring issues to 

provide guidance on assistance with customer interactions, which provide clarity to the 

customer and improved information exchange. 

Email Campaign Helpfulness: One of the main priorities for the Marketing and 

Communications Team was Debt Relief and Return to Repayment information. FSA informed its

borrowers on updates and reminders regarding debt relief, as well as the pages and information 

that may be relevant to the students, parents, and borrowers. FSA had several opportunities to 

utilize some of the actionable customer feedback to make improvements to its email such as, 

incorporating clarifying and relevant information for the borrowers regarding repayment 

information. One area of opportunity that FSA can do as it relates to the Return to Repayment 

emails would be its larger communications. Based on feedback from borrowers, the main items 

that they would like to see is around personalization and segmentation. FSA will look to see if 

there are any additional data points that it has at its disposal to make the communications more 

relevant in the future. 

FSA sent out several communications promoting the renewal of FAFSA applications for the 

fiscal year. One of the top goals for the communications is to increase the awareness of the 

2023–24 FAFSA, as well as encourage borrowers to complete the form. FSA’s efforts with the 

Winter Renewal campaign have proven successful with a combined score of 84/100 for email 

helpfulness.

One area of opportunity that FSA can look at is around the seasonality of FAFSA campaigns 

beyond the Fall and Winter student aid deadlines. One of the campaigns that FSA has sent was 

sent closer to the Spring period, which may be too late given some of the major state deadlines 

have passed. One way that the organization can improve is to see if it can align the Spring 

Renewal sends closer to major deadlines to encourage and remind borrowers on renewing their 

FAFSA if they have not already.
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Strategic Goal 3: Strengthen Engagement and Accountability 

for Educational and Financial Institutions

Goal Leaders: Deputy Chief Operating Officer, Office of Partner Participation and 

Oversight (Strategic Objectives 3.1 and 3.3)

FSA Chief Enforcement Officer (Strategic Objective 3.2)

Table 33: Goal Objectives

Strategic Objective No. Strategic Objective

Strategic Objective 3.1 Utilize a comprehensive suite of monitoring tools to oversee 

participating partners.

Strategic Objective 3.2

Build enforcement capabilities, in coordination with federal and state 

partners to protect students, families, and taxpayers from deceptive, 

fraudulent, or harmful practices in the student aid marketplace.

Strategic Objective 3.3 Provide inclusive and effective partner outreach, training, and 

technical assistance. 

Goal Spotlight

Strategic Goal 3 is focused on how FSA assists schools, third-party servicers, and financial 

institutions to deliver federal student aid and safeguard data integrity. FSA provides training and 

technical assistance, as well as conducts oversight, monitoring, and enforcement to ensure 

these institutions understand and comply with Title IV requirements and other relevant laws, in 

addition to the terms of their Partner Participation Agreements. FSA has gauged its 

performance in these areas using three performance indicators that target each strategic 

objective. FSA has met or exceeded each of its Goal 3 strategic objective performance 

indicators for FY 2023. 

FSA’s Office of Partner Participation and Oversight (PPO) is responsible for administering a 

program of eligibility, certification, financial analysis, and oversight of schools participating in 

Title IV programs. PPO used a comprehensive suite of monitoring tools to ensure schools 

appropriately administered Title IV programs by conducting comprehensive compliance reviews 

for certification actions, deficient audit resolutions, flagged financial statements, program 

reviews, method of payment actions, and technical assistance. In FY 2023, FSA’s School 

Eligibility and Oversight Service Group (SEOSG) conducted oversight reviews for more than 

2,130 educational institutions.

FSA is committed to continuing to build its investigative and enforcement capabilities. The 2021 

reestablishment of a stand-alone Enforcement Office, led by a chief enforcement officer 

reporting directly to the Chief Operating Officer, was the first step in a re-dedicated effort at FSA 

to further prioritize school oversight and accountability. Since then, FSA has built that office 

through the hiring of additional high-quality staff, expanded the capacity to conduct 

investigations and adjudicate borrower defense claims, developed a data-driven model to 

assess risk and inform the allocation of enforcement resources, and enhanced its 

communications with schools using tools such as Enforcement Bulletins. FSA has also 

deepened coordination with state and federal enforcement partners to protect borrowers, their 

families, taxpayers, and the Title IV program while safeguarding public investment in higher 

education.
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Strategic Goal 3 also highlights FSA’s responsibility for providing high quality training products 

and technical assistance services to Institutions of Higher Education (IHEs), third-party 

servicers, auditors, and participating school business officers. Its extensive online training 

system, the FSA Training Center (fsatraining.ed.gov), provided training and technical 

assistance services to more than 28,000 individual staff from more than 4,500 IHEs. This 

represents 84% of all Title IV participating institutions. FSA also supported training, outreach, 

and executive engagement through national, regional, and state level conferences along with 

focused support for minority-serving institutions (MSIs) and under-resourced institutions. 

FSA has continued to be responsive in disaster relief efforts for schools through its 

communications, such as post-disaster emails, which offered key reminders and information on 

the special resources available to schools and individuals that were impacted by natural 

disasters.

The remainder of this section provides additional details of FSA’s efforts in accomplishing 

Strategic Goal 3 to Strengthen Engagement and Accountability for Educational and Financial 

Institutions.
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Strategic Objective 3.1 

Utilize a comprehensive suite of monitoring tools to oversee participating 

partners.

Strategic Objective Leader: Director, Partner Eligibility and Oversight Services, 

Office of Partner Participation and Oversight

Overview

To safeguard Title IV funds on behalf of students and taxpayers, FSA provides an effective, 

compliant student aid delivery process and a program of partner oversight and monitoring. 

These efforts are aimed at reducing program risks by monitoring the performance of 

participating partners such as schools, third-party servicers, and financial institutions, as well as 

assessing their compliance with program participation requirements. FSA performs this 

oversight by using a comprehensive suite of monitoring tools to review participating partner 

compliance. The expansive set of monitoring tools includes:

• Title IV compliance audit reviews and resolutions

• Institution financial health ratio analyses and periodic financial reporting reviews

• Title IV program reviews encompassing assessments of administrative capability, 

policies, and procedures

• Calculation and distribution of cohort default rates

• Comprehensive Compliance Reviews (CCRs)

Performance Summary and Analysis

There is one performance indicator for strategic objective 3.1. FSA measures its performance 

through its use of Comprehensive Compliance Reviews (CCRs) to evaluate participating 

educational institutions that are experiencing potential problems in the administration and 

management of Title IV funds. Reviews are triggered by oversight events such as recertification, 

initial applications, reinstatement of Title IV eligibility, deficient annual audits, flagged annual 

financial statements, and risk-based program review candidate assessments. Strategic 

Objective 3.1 measures FSA’s completion of CCRs to evaluate high-risk partners as defined by 

their provisional certification status. In FY 2023, there were 889 institutions in a provisionally 

certified status. FSA conducted CCRs on 591 of those representing 66.5 percent of provisionally 

certified institutions.
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Performance Indicator 

Performance Indicator 3.1.A: Review for participating partners that have been provisionally 

certified. 

Indicator Definition: This indicator measures the completion rate of holistic comprehensive 

compliance reviews of provisionally certified institutions.

Period of Performance: October 2022 through September 2023.

Table 34: Performance Indicator 3.1.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A 51% 62.6% 80% 40% 66.5%

Performance Result N/A Met Met Met Met 

Note: To assess FSA’s progress toward achieving Strategic Objective 3.1 during the FY 2023–27 

Strategic Plan period, FSA established cumulative annual targets for completing CCRs for all 

provisionally certified partners. The annual target goal during the first year of the FY 2023–27 Strategic 

Plan was for FSA to complete CCRs for at least 40% of provisionally certified partners during FY 2023. 

For the second and third fiscal years of the FY 2023–27 Strategic Plan, FSA’s annual target goals are to 

complete CCRs for 60% of provisionally certified partners during FY 2024 and 80% during FY 2025. FSA 

intends to complete CCRs for 90% of provisionally certified partners during FY 2026 and 100 percent by 

the end of FY 2027.

Key Successes and Opportunities

FSA far exceeded the FY 2023 annual target goal for completing CCRs on at least 40% of 

provisionally certified partners during the first year of the FY 2023-27 Strategic Plan period. FSA’s 

strong performance ensured that more than 65 percent of provisionally certified partners 

received a Comprehensive Compliance Review during FY 2023. This ensured that FSA 

maintained greater attention and focus on its provisionally certified partners as these institutions 

may pose greater risk. This result also provides a margin against potential adversity in future 

fiscal years while FSA: 

• deploys new enabling technologies and implements new regulations, 

• launches new programs and capabilities to deliver additional types of Title IV oversight 

such as for the proposed Gainful Employment regulations, 

• navigates challenging shortfalls in requested appropriations and staffing levels, and 

• manages staffing challenges related to retirements and other planned change within the 

Department.
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Strategic Objective 3.2 

Build enforcement capabilities, in coordination with federal and state 

partners to protect students, families, and taxpayers from deceptive, 

fraudulent, or harmful practices in the student aid marketplace. 

Strategic Objective Leader: Chief Enforcement Officer, Enforcement Office

Overview

Since the Enforcement Office (Enforcement) was reestablished in 2021, Enforcement has been 

proactively working to build additional investigative and enforcement capabilities to bolster 

oversight of schools and their service providers. The goal of these efforts is to identify and 

address conduct that is deceptive, fraudulent, or otherwise violates the laws and regulations 

governing the Title IV program, and that imposes significant costs on students, families, and 

taxpayers. The stand-alone Enforcement Office includes the Borrower Defense Group (BDG), 

the Investigations Group (Investigations), the Administrative Actions and Appeals Service Group 

(AAASG), and the Resolution and Referral Management Group (RRMG). 

Enforcement is responsible for certain FSA core work, including certain statutory, regulatory, 

judicially, and otherwise-required duties and functions. This includes proper and timely 

resolution of student complaints (through RRMG), initiation and timely resolution of 

investigations where appropriate (through Investigations), proper and timely resolution of 

referrals for adverse and administrative actions (through AAASG), and proper and timely 

resolution of borrower defense applications (through BDG). 

In addition, Enforcement developed and is implementing a strategic plan to inform the build of 

the office. This plan includes five strategic imperatives including: 

• BUILD. Build and grow a robust, dedicated, and modern Enforcement Office within FSA, 

capable of meeting the demands of the ever-changing higher education community and 

risk landscape.

• PROTECT. Develop and employ the full range of Enforcement’s authorities to deter 

predatory institutional and individual misconduct, strengthen oversight of high-risk 

institutions, improve institutional and individual accountability, and provide resolution or 

relief, where appropriate, for those harmed by predatory misconduct.

• PRIORTIZE AND MODERNIZE. Efficiently utilize resources and prioritize activities 

through the use of modern technology and data-driven approaches to our work. 

• PARTNER. Maximize and share resources, capabilities, and expertise through 

partnership and collaboration, including within Enforcement, FSA, and the Department 

and with other state/federal enforcement agencies and partners.

• COMMUNICATE. Enhance communication and transparency of Enforcement’s 

authorities and activities with the public, policymakers, the higher education community, 

and other stakeholders.
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Performance Summary and Analysis

There is one performance indicator for this strategic objective. The performance indicator target

was met. The FSA Enforcement Strategic Plan, developed in FY 2023, guides Enforcement’s 

priorities and resource allocation, and is contributing to the build of an effective and resilient 

office.

Performance Indicator 

Performance Indicator 3.2.A: Build and implement an FSA Enforcement Strategic Plan that 

incorporates a risk model for identifying schools that pose risk to students and taxpayers. 

Indicator Definition: Identify and provide a Strategic Plan to guide and inform the work and 

priorities of the Enforcement Office.

Period of Performance: October 2022 through September 2023.

Table 35: Performance Indicator 3.2.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Develop 

Strategic Plan

Strategic Plan 

completed

Performance Result N/A N/A N/A N/A Met

Key Successes and Opportunities

In addition to developing a strategic plan, Enforcement has completed several initiatives in 

support of the plan’s strategic imperatives including:

Build: 

• Enforcement onboarded 26 new staff in FY 2023. 

• Enforcement implemented a plan to update policies and procedures that guide the 

office’s work.

Protect: 

• Enforcement opened new investigations into schools and their service providers where 

risk indicators suggested potential violations.

• Enforcement developed a robust suite of investigative tools, including a secret shopper 

program and a tip line.

• Enforcement developed findings to support BDG discharges and common findings 

related to schools. 

Prioritize and Modernize:

• Enforcement developed a data-driven model to assess risk of violations that could 

impose significant harm to students, families, and taxpayers.
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• Enforcement integrated FSA complaint data into its risk scoping.

Partner:

• Enforcement strengthened FSA’s relationships with federal and state partners, including 

the Federal Trade Commission, Consumer Financial Protection Bureau, Department of 

Defense, Department of Veterans Affairs, and state attorneys general through the 

Principles of Excellence Working Group pursuant to Executive Order 13607, 

Establishing Principles of Excellence for Educational Institutions Serving Service 

Members, Veterans, Spouses, and Other Family Members. 

• Enforcement entered into information sharing agreements with partners, where 

appropriate and supported by a common interest in investigations of potential legal, 

regulatory, and contractual violations arising under agencies’ respective authorities.

Communicate:

• Enforcement updated the Borrower Defense webpage with substantive information 

about the borrower defense application and process to help potentially impacted 

borrowers understand how to file an application. 

• Enforcement issued four public bulletins in FY 2023. 

• The first bulletin announced a new avenue for knowledgeable sources to submit tips and 

information directly to the Enforcement Office about potential violations of the laws and 

regulations governing the federal student aid programs. 

• The second bulletin announced that FSA will use secret shoppers as an additional tool 

to monitor schools’ Title IV compliance. Secret shoppers will evaluate recruitment, 

enrollment, financial aid, and schools’ other practices to help identify potentially 

deceptive or predatory practices used to recruit and enroll students.

• The third bulletin clarified that nondisclosure agreements that prohibit or limit employee 

communication with the Department violate Title IV regulations.

• The fourth bulletin reminded schools to ensure programs are properly accredited before 

disbursing funds.

In meeting the annual target goal for Strategic Objective 3.2.A, Enforcement encountered 

several challenges and opportunities including:

• Difficulty hiring staff quickly enough to meet requirements including increased 

investigations and implementation of the Sweet v. Cardona settlement. To supplement 

and speed-up the hiring process, Enforcement assigned attorneys as subject matter 

experts to assist Human Resources (HR) with screening applicants for the substantive 

and educational experience requirements for hundreds of applications. FSA also 

contracted with a vendor to provide a dedicated HR resource to further mitigate this 

problem. 

• Uncertainty regarding the Department’s authority to require individuals to provide oral 

testimony under oath. This is currently being reviewed and considered to enhance 

effective oversight.
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Strategic Objective 3.3 

Provide inclusive and effective partner outreach, training, and technical 

assistance. 

Strategic Objective Leader: Director of Partner Outreach and Communication, 

Office of Partner Participation and Oversight

Overview

FSA has experienced an unprecedented demand for training and support resources due to 

legislatively driven regulatory and policy changes. FSA has risen to that challenge by 

redesigning and reengineering its offerings for training and technical assistance through virtual 

and in-person engagements via the FSA Training Center (fsatraining.ed.gov), the Wednesday 

Webinar training series, the annual FSA Training Conference (FSATC), and regional 

professional association conferences. FY 2023 saw a small return to in-person technical 

assistance site visits and a significantly increased use of webinars and training delivered 

virtually via the FSA Training Center. Additional training and outreach resources have focused 

on minority serving institutions (MSIs), under-resourced institutions and Institutions of Higher 

Education (IHE) presidential leadership events. Technical assistance is also provided through 

the Ask-a-Fed service, Partner Connect/ Common Origination and Disbursement (COD) 

customer service representatives, and the Partner Technical Assistance group. The expansion 

of FSA’s virtual content delivery allowed a larger group of schools with limited travel budgets 

and/or limited staffing to attend the FSATC, state and regional conferences, and the statutorily 

mandated Fundamentals of Title IV Training. 

Performance Summary and Analysis

There is one performance indicator for this strategic objective: participation rates. Training, 

technical assistance and outreach activities exceeded the annual indicator targets for FY 2023. 

Of note, the FSA Training Center provided training and technical assistance services to more 

than 28,000 individual staff from more than 4,500 Institutions of Higher Education (IHEs). This 

represents 84% of all Title IV Participating institutions.
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Performance Indicator 

Performance Indicator 3.3.A: Institutional participation rates in Title IV training and specialized 

technical assistance programs.

Indicator Definition: This performance indicator measures the percentage of institutions 

participating in training and technical assistance programs using the Office of Postsecondary 

Education Identification (OPEID) of the school.

Period of Performance: October 2022 through September 2023.

Table 36 Performance Indicator 3.3.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A 88.0% 94.0% 75-80% 84%

Performance Result N/A N/A Baseline Met Met

Note: The 84% reflects FSA’s method of counting an OPEID number once regardless of the number of 

events attended using that OPEID or the number of people from an institution who attend different events 

using the same OPEID.

Key Successes and Opportunities

FSA’s success in meeting this objective is due to its focus on creating more instructionally 

sound virtual events allowing for more participation. FSA recognizes that virtual events do not 

always offer the same level of satisfaction as a face-to-face event and therefore will strive to reincorporate some face-to-face or hybrid events when possible, if resources are available.

Opportunities also exist through the development of self-directed learning modules as well as 

new systems being developed and implemented that allow for single sign-on. Single sign-on is 

expected to ease partner access and reduce entry errors.
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Strategic Goal 4: Increase Workforce and Workplace 

Capabilities

Goal Leader: Director, Executive Services

Table 37: Goal Objectives

Strategic Objective No. Strategic Objective

Strategic Objective 4.1 Promote workplace diversity, equity, inclusion, and accessibility.

Strategic Objective 4.2 Attract, develop, and retain an agile workforce that can quickly 

respond to a changing environment and emerging priorities. 

Strategic Objective 4.3

Foster an organizational culture that promotes a productive, 

connected, and engaged workforce, particularly in a hybrid 

workplace environment. 

Goal Spotlight

In any industry or sector, an organization’s most important asset is its talent. FSA strives to be a 

model federal employer, creating an environment where individuals maximize their potential and 

teams collectively move the agency forward. Achieving FSA’s mission requires attracting, 

developing, and retaining a skilled and agile workforce. To continue to excel as a highperforming organization and meet the challenges of the current environment, FSA must invest in 

the knowledge, skills, and abilities of its employees. To meet the expectations outlined in the 

FY 2023–27 Strategic Plan, it is essential that staff are trained, aligned, and equipped to provide 

best-in-class customer service while fulfilling the fiduciary responsibilities of the organization.

Following unprecedented flexibility and a mindset shift in how we work during the global 

pandemic, FSA’s future workplace environment offers new opportunities and calls for different 

ways to connect and engage employees. A hybrid workplace, with some employees working in 

an office while others work remotely, can facilitate broad connectivity but may also introduce 

risks to work-life balance. FSA will leverage data to assess and track progress, including using 

results from the annual Federal Employee Viewpoint Survey (FEVS). The FEVS contains 

questions designed to measure employees' feelings and attitudes in topic areas such as talent 

development, leadership, management/supervision, knowledge management, performance 

culture, employee engagement, and other areas important to creating an effective work 

environment.
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Strategic Objective 4.1 

Promote workplace diversity, equity, inclusion, and accessibility. 

Strategic Objective Leader: Director, Diversity, Equity, Inclusion, and Accessibility

Overview

Organizations with strong diversity, equity, inclusion, and accessibility (DEIA) initiatives are 

more likely to have employees that are more engaged, with higher levels of trust, and increased 

job satisfaction while also improving work productivity. FSA is committed to attracting, retaining, 

and developing a workforce that is representative of the communities it serves, and creating 

more positive experiences for employees, customers, and stakeholders. In FY 2023, FSA took 

the following steps toward meeting this objective:

• In alignment with Executive Order 14035, Diversity, Equity, Inclusion, and Accessibility in 

the Federal Workforce and the Department’s strategic plan, FSA hired a DEIA Director 

to lead its DEIA efforts.

• In FY 2023, there were four monthly special emphasis programs that focused on Black 

History Month, Women’s History Month, Asian-American Pacific Islander Month and 

Pride Month. 

• Workforce Development Division developed the Power Users Learning Series for 

Employees (PULSE) Program to provide staff with the necessary tools and strategies to 

close skill gaps using a peer-to -peer learning approach. 

• Initiated the FSA VOICE program this year. The intent of the program is to provide a 

platform for them to voice their opinions, innovative ideas, and responses to some FEVS 

questions to continue to improve the efficiency and effectiveness of operations in the 

agency.

In the upcoming fiscal year, FSA will consult with the Department’s Chief Diversity Officer and 

OPM’s DEIA office to ensure initiatives are in alignment with the Department’s DEIA strategic 

plan and Executive Order 14035. The DEIA Director will collaborate with leadership, the Human 

Capital Group, the Workforce Development Division, across business units, and with Workforce 

Relations Division to engage the union to develop DEIA initiatives that promote an inclusive and 

diverse workplace that is equitable and accessible to all. 

Performance Summary and Analysis

Because this strategic objective is new, three indicators will serve as a baseline for future 

success measurements. Performance indicator 4.1.D was established, but the target goal was 

not met. 

FEVS data from the FY 2023 FEVS survey needed for this report will not be available until 

sometime after January 2024. However, preliminary FY 2023 data were available and used for 

comparative analysis to FEVS FY 2022 data for this report.
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Performance Indicator 

Performance Indicator 4.1.A: Federal Employee Viewpoint Survey Diversity and Inclusion 

Index: New Inclusion Quotient Index.

Indicator Definition: The Federal Employee Viewpoint Survey DEIA Index (formerly New 

Inclusion Quotient Index) is a composite score of measures of diversity, equity, inclusion, and 

accessibility from the FEVS survey.

Period of Performance: October 2022 through September 2023.

Table 38: Performance Indicator 4.1.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 73%

Performance Result N/A N/A N/A N/A Baseline

Note: The Federal Employee Viewpoint Survey data for FY 2023 has not been released. These data are 

typically not reported until November of the fiscal year in which the survey is given. Preliminary data for 

2023 were used for this analysis.

Performance Indicator 4.1.B: Percentage of qualified new hires and backfills coming from 

identified underrepresented workforce populations.

Indicator Definition: This indicator assesses promotion of workforce diversity by measuring the 

percentage of qualified new hires and backfills coming from underrepresented workforce 

populations. Underrepresented populations in the workforce are defined as racial/ethnic 

minorities and disabled individuals, independent of race or ethnicity. 

Period of Performance: October 2022 through September 2023.

Table 39: Performance Indicator 4.1.B Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 37% 

Performance Result N/A N/A N/A N/A Baseline

Note: Currently, it is not possible to delineate between new hires and backfills; however, a method is 

being developed to capture and report this data in the future.
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Performance Indicator 4.1.C: Percentage of underrepresented populations included in 

organizational talent acquisition, promotion, and development/training activities.

Indicator Definition: This indicator measures the percentage of underrepresented populations 

in either leadership or competency training programs.

Period of Performance: October 2022 through September 2023.

Table 40: Performance Indicator 4.1.C Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline 36% 

Performance Result N/A N/A N/A N/A Baseline

Performance Indicator 4.1.D: Percentage of employees participating in formal diversity, equity, 

inclusion, and accessibility efforts.

Indicator Definition: Results from formal DEIA efforts will measure participation and 

attendance in offered events, such as the monthly special emphasis programs.

Period of Performance: October 2022 through September 2023.

Table 41: Performance Indicator 4.1.D Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A 10-15% of total 

employee count 8% 

Performance Result N/A N/A N/A N/A Not met

Key Successes and Opportunities

• Special emphasis programs were held in FY 2023. Attendance at the monthly programs 

ranged from 90 participants at the Women’s History Month event to 148 participants at 

the Black History Month event. On average, 8% of FSA employees attended these 

special emphasis programs which does not fall within the target range of 10-15%.

• A key success was the Workforce Development Division, the DEIA Director, and the 

Acquisitions Team collaboration to secure DEIA training and development courses to 

support FSA’s DEIA training and education plan.

• FSA has an opportunity to revise some of the key metrics to ensure the validity of its 

performance measures.
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Strategic Objective 4.2 

Attract, develop, and retain an agile workforce that can quickly respond to 

a changing environment and emerging priorities.

Strategic Objective Leader: Director, Human Capital Group

Overview

In accordance with the Presidential Management Agenda priorities and strategies that “Federal 

agencies must attract, hire, develop, and empower talented individuals who are well suited and 

well prepared to face the challenges the government faces, both in the near and long term,” the 

Human Capital Group (HCG) continues to execute initiatives that facilitate FSA’s human capital 

management (HCM) practices, which have been adjusted to what is becoming the new 

normal—hybrid workforce environments. In FY 2020, the global COVID-19 pandemic changed 

FSA’s workplace, recruitment outreach efforts, talent development, and work-life balance. 

However, the agency’s long-standing HR policies evolved to reflect and keep pace with these 

changes. Some of these adjustments included the expansion of telework, the implementation of 

remote work, and change in workforce expectations. 

To meet the expectations outlined in the FY 2023–27 Strategic Plan, FSA continues to strive in 

its effort to build and sustain a technological-savvy and innovative workforce in an ecosystem of 

the right people, engaged with the right processes and platforms all while supported in a culture 

focused on the future of work in a high-performing, highly rewarding, safe, diverse, and inclusive 

environment. FSA recognizes it is essential that staff are well-trained, aligned, and equipped to 

provide best-in-class customer service while fulfilling the fiduciary responsibilities of the 

organization.

Performance Summary and Analysis

There is one performance indicator for this strategic objective. The indicator completed the 

baseline assessment in FY 2023, which will be used to set targets for future years.

In FY 2022–23, the HCG, Human Capital & Employee Initiatives (HCEI) team continued its 

efforts to comply with the agency-wide initiative to implement strategic workforce planning. 

Workforce planning and analytics is the process of discovering, interpreting, and communicating 

meaningful patterns in workforce-related data to inform decision-making and improve 

performance. It is not only about data analysis but also about change management generating 

meaningful insights to drive behavioral change and increase organizational effectiveness.

HCEI partnered with key stakeholders within the Department, HCG and FSA to ensure that 

qualitative and quantitative baseline outcomes were met. HCEI conducted the introduction of 

and preliminary workforce planning activities within the business unit of PPO.
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Performance Indicator

Performance Indicator 4.2.A: Federal Employee Viewpoint Survey: Intrinsic Work Experience. 

Indicator Definition: OPM Federal Employee Viewpoint Survey (FEVS) measures employees' 

perceptions of whether, and to what extent, conditions and characteristics of successful 

organizations are present in their agencies. The Federal Employee Viewpoint Survey score 

within the Employee Engagement Index, specifically Intrinsic Work Experience will be the one of 

the key indicators to assess progress towards the objective.

Period of Performance: October 2022 through September 2023.

Table 42: Performance Indicator 4.2.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Baseline. 76% 

Performance Result N/A N/A N/A N/A Baseline

Note: The Federal Employee Viewpoint Survey data for FY 2023 has not been released. Results are 

typically not reported until November of the fiscal year in which the survey is given. Preliminary data for 

FY 2023 were used for this analysis.

Key Successes and Opportunities

• HCG/HCEI effectively introduced and implemented stages 1-3 of the Office of Personnel 

Management (OPM) strategic workforce maturity model within PPO. These efforts also 

included an in-depth creation of a human capital analytical dashboard (with heat maps) 

of PPO’s workforce that provides current and projected workforce needs. It also 

demonstrates demographic data related to staffing patterns. 

• FSA achieved a 77% training participation rate which will serve as a baseline for 

FY 2024. Training courses in the areas of supervisory/leadership development, data 

literacy, acquisitions, and IT were among the main categories in which training was 

taken.

• The Performance Confidence Index (PCI) a metric in the Federal Employee Viewpoint 

Survey, will be used next year to measure the hiring and talent management 

components described above. The PCI assesses the extent to which employees believe 

their organization has an outstanding competitive future, based on innovative, highquality products and services that are highly regarded by the marketplace. The PCI is an 

average of the responses for the five items: Employees in my work unit meet the needs 

of our customers; Employees in my work unit contribute positively to my agency’s 

performance; Employees in my work unit produce high-quality work; Employees in my 

work unit adapt to changing priorities; and Employees in my work unit achieve our goals. 

• The OPM Annual Time-to-Hire Metrics measures the time to hire and will be used as a 

basis for measuring success in hiring
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Strategic Objective 4.3 

Foster an organizational culture that promotes a productive, connected, 

and engaged workforce, particularly in a hybrid workplace environment.

Strategic Objective Leader: Director, Organizational Development

Overview

FSA remains committed to enabling its organizational success by working towards fostering an 

organizational culture that promotes a productive, connected, and engaged workforce in a 

hybrid workplace environment. In conjunction with creating an environment with the appropriate 

tools and programs for staff, FSA is also striving to foster and support a culture where all 

employees feel engaged, included, informed, and connected to its mission. In FY 2023, FSA 

completed the Employee Engagement Action Plan which focused on improving communications 

throughout the organization, recognizing employee accomplishments, and benchmarking 

employee engagement to promote a workplace conducive to productivity.

The FEVS is a key tool that can be used to measure employee engagement throughout the 

federal government including FSA. The FY 2022 FEVS results were made available in 

December of 2022. The data was used to develop and execute plans to improve employees’ 

engagement in the productivity and efficiency of the agency. Currently the agency is operating 

in a hybrid form. For this practice to succeed, FSA must remain focused on strengthening 

employee communication channels. Communication platforms provide information and 

feedback (e.g., The Source Employee Newsletter, which includes a new, regional feature, FSA 

First Class, Management Services Regional Liaison Newsletter, FSA Communications emails). 

FSA developed a new program which combines FEVS focus groups and the innovation 

programs. The program was held this past spring with a total of 205 participants in 21 focus 

groups. The VOICE Focus Groups have helped FSA leadership identify underlying problems 

and work toward forming solutions to create a productive, connected, and engaged workforce.

Performance Summary and Analysis

There are three performance indicators for this strategic objective: employee engagement, 

communication, and collaboration, which were derived from the preliminary results of the 

FY 2023 FEVS survey score data. Results from the FY 2022 FEVS survey score data, received 

in December 2022, were used to create the FY 2023 FEVS Employee Engagement Action Plan

and the performance indicators for the FY 2023 FEVS. 

Performance Indicator 4.3.A compared the overall FY 2022 FEVS FSA EEI with the FY 2023 

FEVS EEI. The target for Performance Indicator 4.3 A is an increase in the employee 

engagement score by 1–2% from the previous FEVS EEI which was met this year. The 

performance indicators for 4.3.B and 4.3.C are new. The FY 2023 FEVS data were used to set 

baselines.
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Performance Indicator 

Performance Indicator 4.3.A: Federal Employee Viewpoint Survey: Employee Engagement 

Index.

Indicator Definition: OPM FEVS measures employees' perceptions of whether, and to what 

extent, conditions and characteristics of successful organizations are present in their agencies. 

The EEI assesses the critical conditions conducive for employee engagement (e.g., effective 

leadership, work which provides meaning to employees, etc.) It is made up of three subfactors: 

Leaders Lead, Supervisors, and Intrinsic Work Experience.

Period of Performance: October 2022 through September 2023.

Table 43: Performance Indicator 4.3.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance 61% 70% 74% 73% Maintain or 

improve by 1% 75%

Performance Result Met Met Met Not met Met 

Note: The FEVS data for FY 2023 has not been released. The data is typically not reported until 

November of the fiscal year in which the survey is given. Preliminary data for FY 2023 was used for this 

analysis.

Performance Indicator 4.3.B: Federal Employee Viewpoint Survey: Communication. 

Indicator Definition: Responses to three questions in FY 2023 FEVS were used to develop 

this indicator: Question 58: “Information is openly shared in my organization”, Question 66: 

“Managers promote communication among different work units”, and Question 68: “How 

satisfied are you with the information you receive from management on what's going on in your 

organization”.

Period of Performance: October 2022 through September 2023.

Table 44: Performance Indicator 4.3.B Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Maintain or 

improve by 1% 61%

Performance Result N/A N/A N/A N/A Baseline

Note: The FEVS data for FY 2023 has not been released. Results are typically not reported until 

November of the fiscal year in which the survey is given. Preliminary data for FY 2023 was used for this 

analysis.
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Performance Indicator 4.3.C: Federal Employee Viewpoint Survey: Collaboration. 

Indicator Definition: Results from two questions in the FY 2023 FEVS were used to develop 

this indicator: Question 15: “I can make decisions about my work without getting permission 

first”, and Question 18: “Employees in my work unit share job knowledge.”

Period of Performance: October 2022 through September 2023.

Table 45: Performance Indicator 4.3.C Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Maintain or 

improve by 1% 84%

Performance Result N/A N/A N/A N/A Baseline

Note: The Federal Employee Viewpoint Survey data for FY 2023 has not been released. The data is

typically not reported until November of the fiscal year in which the survey is given. Preliminary data for 

2023 was used for this analysis.

Key Successes and Opportunities

• FSA implemented an enhanced communication campaign to increase employee 

participation in the FEVS. The FY 2023 participation rate was identical to the FY 2022 

FEVS which stands at 68%. 

• Action plans and focus groups were developed to address challenge areas from 

previous FEVS surveys.
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Strategic Goal 5: Boost Operational Efficiency

Goal Leader: Director of Strategy and Performance, Office of Strategic Measures and 

Outcomes

Table 46: Goal Objectives

Strategic Objective No. Strategic Objective

Strategic Objective 5.1

Strengthen enterprise-wide data analytics and modernize 

information management to foster a customer-centric, data-driven, 

performance-based organization.

Strategic Objective 5.2 Continuously improve systems, structures, and operations to 

enhance organizational efficiency and performance.

Strategic Objective 5.3 Enhance procurement planning, management, and execution. 

Strategic Objective 5.4 Improve cybersecurity detection, prevention, and protection ensuring 

data confidentiality, integrity, and availability. 

Goal Spotlight

Strengthening enterprise-wide data analytics and information management is essential for 

fostering a customer-centric, data-driven, performance-based organization. For FSA, this means 

using data to better understand the needs of students and families, develop products and 

services that better meet those needs, make more informed decisions about how to allocate 

resources and improve operations, measure the impact of its programs and services, and 

improve the overall performance of the agency. FSA has used data analytics to develop and 

implement interventions that have helped borrowers make informed decisions about education 

and finances and protected the agency from fraud. FSA has also completed the Annual Data 

Maturity Assessment (DMA) and achieved a score of 57, meeting its target for the year. The 

DMA has been used to fulfill a critical role in driving data-driven decision-making and to ensure 

that FSA is effectively leveraging data as a strategic asset. By continuing to invest in data 

analytics and information management, FSA can become a more customer-centric, data-driven, 

and performance-based organization. This will allow the agency to better serve its customers 

and achieve its mission of ensuring that all eligible students and families have access to federal 

student aid.

The Finance Directorate worked to continuously improve the financial systems, structures, and 

operations through a variety of avenues. Leveraging tools developed in the federal government, 

detection and prevention of improper payments was expanded over a larger population. 

Strategic use of small business contracts helped manage risks of cost overages leading to 

overall savings over the next five years.

In FY 2023, the Acquisitions Directorate accomplished initiatives to promote greater teamwork, 

collaboration, and efficient resource planning/management across the organization. It prepared 

and distributed a list of all procurement-related tasks and durations necessary to timely execute 

a full and open competition. The tasks and durations account for statutory, regulatory, policy, 

etc. requirements and guidance, as well as historic performance. Access to this information 

facilitates advance program planning, prevents gaps in service, and helps promote better 

procurement planning and execution. This enables program and project managers to begin their 
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planning activities earlier to ensure an effective and efficient beginning to, or transition of, 

programmatic needs being met by contract support thereby reducing FSA’s risk. The 

Acquisitions Directorate continues to explore creating additional task and duration lists for other 

than full and open competitions in support of continuous process improvement.

A commitment to cybersecurity enhances the confidentiality, integrity, and availability of student 

and borrower data. Upholding and enforcing rigorous cybersecurity standards enables FSA to 

better achieve its mission. Through a review of the cybersecurity posture of our information 

systems, FSA has adopted a phased approach to upgrading existing FSA systems to 

incorporate multi-factor authentication, block malicious/suspicious activity, and facilitate incident 

response. These changes are to better protect borrower data, prevent identity theft, and ensure 

continuity of service.

In FY 2023, the Chief Information Officer led FSA’s activities that directly contributed to the 

Department’s highest ever Federal Information Security Modernization Act of 2014 (FISMA) 

audit score and an “A”, one of only three Federal Agencies, on the most recent Federal 

Information Technology Acquisition Reform Act scorecard. 

In addition to the above, the Technology Directorate Cyber Operations Division lead the way on 

the following:

• Maintained an average cybersecurity risk scorecard nearly 28% above the Department 

average while securely operating 82% of the Departments High Value Assets. The 

scores validate the investment and resources FSA expends to ensure the customers can 

access systems and their personal data is well protected. 

• Heavily leveraged low code cloud solutions to automate business practices, provide 

better internal controls, increase managements insight into critical activities, and reduce 

the resource requirements ensuring the successful delivery of IT and cybersecurity 

capabilities.
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Strategic Objective 5.1

Strengthen enterprise-wide data analytics and information management to 

foster a customer-centric, data-driven, performance-based organization. 

Strategic Objective Leader: Chief Data Officer, Enterprise Data Office

Overview

There are three performance indicators for this strategic objective. The first indicator pertains to 

FSA’s score in the Department’s Annual Data Maturity Assessment (DMA). The DMA, launched 

in 2020, is administered by the Department’s Chief Data Officer for all Department principal 

offices. The DMA provides a comprehensive framework of data management practices 

organized into key categories that allows for the benchmarking of capabilities, the identification 

of strengths and gaps, and the leveraging of data assets to improve business performance. 

Conducting the DMA provides an understanding of data maturity relative to subsequent 

measurements. The DMA fulfills a critical role in driving data-driven decision-making and 

ensuring that data is effectively leveraged as a strategic asset.

The process areas evaluated in the assessment vary; the most recently completed assessment 

(2022) covered 18 process areas within the following seven categories:

• Data Management Strategy and Oversight

• Data Quality

• Data Operations

• Data Management

• Systems and Architecture

• Knowledge and Skills

• Customer Support and Engagement

The second two performance indicators for this strategic objective both pertain to FSA data 

modeling efforts. FSA has developed, implemented, and maintained large-scale data models to 

perform and optimize customer communications and other customer-level interventions that 

improve customer outcomes, prevent fraud, and assess school related risks. A single model can 

touch millions of customers and cost billions of dollars each year.

Performance Summary and Analysis

There are three performance indicators for this strategic objective. One indicator did not have 

results and two indicators met their target for FY 2023. FSA’s DMA score has increased and is 

above the target. The targets for models in maintenance and development were also met.
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Performance Indicator 

Performance Indicator 5.1.A: The Sum of Annual Data Maturity Assessment (DMA) for DMA 

Processing Areas.

Indicator Definition: This performance indicator measures the sum of assessed scores of the 

20 key data process areas in the Annual DMA.

Period of Performance: October 2022 through September 2023.

Table 47: Performance Indicator 5.1.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A 56 N/A

Performance Result N/A N/A N/A N/A N/A

Note: The result for this indicator for FY 2023 was unavailable at the time of publication of FY 2023 

Annual Report. The table above reflects the target based on the results for FY 2022.

Performance Indicator 5.1.B: Successful maintenance and use of statistical models in Title IV

operations.

Indicator Definition: This performance indicator measures the successful development, 

maintenance, and use of statistical models in Title IV operations to promote better outcomes for 

customers.

Period of Performance: October 2022 through September 2023.

Table 48: Performance Indicator 5.1.B Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A

8 total number of 

new and existing 

modeling initiatives

Perfor

m8ce

Performance Result N/A N/A N/A N/A Met

Performance Indicator 5.1.C: Implement new Statistical Modeling Initiatives.

Indicator Definition: This performance indicator measures the successful development and 

use of statistical models in Title IV operations to promote better outcomes for customers.

Period of Performance: October 2022 through September 2023.

Table 49: Performance Indicator 5.1.C Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A 2 total number 

new initiatives P2ce

Performance Result N/A N/A N/A N/A Met
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Key Successes and Opportunities

FSA’s DMA scores have improved every year since the assessments began in FY 2020. In 

FY 2022, FSA scored a 57 across 18 process areas, exceeding the target score by one. This 

was up from the FY 2021 score of 56, which was achieved across 19 process areas. FSA’s 

highest scores in FY 2022 were in the areas of ‘Data Management Strategy and Oversight’ and 

‘Systems and Architecture’. The ‘Systems and Architecture’ Process Area score increased with 

the completion of data capture from decommissioned private collection agencies (PCAs) and 

servicers for archival and retention purposes. 

Each year, FSA focuses on the key data initiatives consistent with our priorities. The FY 2023 

focus is on ‘Data Quality’ (aligned with the Federal Processing System (FPS) initiative to 

standardize FAFSA demographic data, including personally identifiable information (PII), across 

Title IV systems). FSA is on track to achieve its planned objective for further score improvement 

in FY 2023. 

FSA uses statistical models to support borrower decision-making and demonstrate how targeted 

engagement can improve outcomes when interventions become necessary. Even with most of 

the student loan portfolio being in mandatory administrative forbearance, the Default Risk 

models, and TPDR fraud interventions remained in operation throughout FY 2023. The 

Origination and Disbursement Default Risk model and “always-on” email campaign began in the 

summer 2021 and have continued in operations. “Always-on” means automated interventions 

are event-driven, such as at the point of FAFSA submission, a disbursement made, or a missed 

payment, which differs from a normal system notification (i.e., “We’ve received your FAFSA”). 

The development of the analytical models reflected under this objective allows FSA to offer 

proactive support and interventions at various intervals within the student aid lifecycle from an 

application, to initial borrowing through repayment, to improve overall student loan repayment. 

Data analytics and risk modeling allow FSA to track customer trends more carefully to improve 

its ability to understand customer challenges.

In the face of large amounts of uncertainty caused by the pandemic, FSA has leveraged data 

and analytics to keep customers informed in an ever-changing environment and mitigate risks to 

the Title IV programs. FSA has used its IT systems and analytics abilities to implement and 

optimize communications, helping our customers make informed decisions about education and 

finances. These efforts include communications for and implementations of general debt relief, 

as well as planning for returning to repayment. FSA has produced fraud detection models to 

help detect and prevent identity theft with the FAFSA, preventing more than an estimated 

$1.0 billion dollars in fraudulent disbursements.

FSA has been developing and maintaining models to assess school related risk. During this 

fiscal year these models have undergone significant maintenance and development to support 

their display in the Partner Connect School Health Dashboard. The new dashboard will 

empower FSA to proactively manage school risks and make informed decisions. It will help to 

align employee efforts with our strategic goals by providing transparency, enhancing 

communication, and promoting data-driven decision-making.

During different stages of the student aid lifecycle, such as application, disbursement, and 

repayment, different types of interventions are beneficial. In FY 2023, there are several 

examples wherein FSA used analytics to positively impact borrowers, including using modeling 

to protect FSA against fraudulent actors. In one example, the California mass application 
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scheme, which first emerged in fall 2021, has been an unprecedented attack on the 

organization’s systems; however, the development and implementation of a model to deny aid 

to fraudsters have protected more than $1 billion of disbursements to date and a quarter of a 

billion during FY 2023. A second example of fraud protection, TPDR fraud, identifies 

unscrupulous actors who contact and convince FSA’s borrowers to pay them for services that 

the government offers for free. The FSA model is leveraged every day to reach out to borrowers 

at risk of falling victim to these schemes. Currently, FSA has communicated with more than 

419,000 borrowers with a total outstanding loan balance of more than $10.7 billion. 

In the future, FSA will provide incentives to enhance servicing to ‘at risk’ customers. To 

implement these incentives, FSA has developed a model to assess borrower default risk that 

could be leveraged to determine which customers a servicer should consider ‘at risk’.

Specific customer outreach models include:

• Default at Risk Application model allowed FSA to contact 7.7 million applicants through 

email, always-on and notification interventions including during FY 2023.

• Default at Risk Origination and Disbursement model facilitated FSA in communications 

to 3.5 million borrowers during FY 2023, including both always-on and notification 

interventions.
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Strategic Objective 5.2 

Continuously improve systems, structures, and operations to enhance 

organizational efficiency and performance. 

Strategic Objective Leader: Chief Financial Officer, Finance Directorate

Overview

The FSA Finance Directorate assessed and improved delivery of financial management and 

supported investment decisions effectively to drive FSA’s mission. In FY 2023, the Finance 

Directorate initiated the following activities to support improving the system, structures, and 

operations to enhance organizational efficiency and performance: 

• Complied with applicable laws, regulations, and policies.

o Implement Secured Overnight Financing Rate (SOFR) system functionality to 

replace the London Inter-Bank Offered Rate (LIBOR) with the SOFR.

o Implement Treasury Report on Receivables (TROR) Phase III functionality 

enhancements to improve data integrity and FSA’s reporting capability to 

Treasury. 

• Continuously initiated financial system improvements, structures, and operations.

o Upgrade the Financial Management System (FMS) Oracle Electronic Business 

Signature from version 12.2.11 to version 12.2.12 (Point Upgrade) to modernize 

FMS and mitigate risks for cybersecurity incidents and unplanned costs related to 

unforeseen system issues.

o Execute FMS contract recompete and award for operations and maintenance 

support services. The Finance Directorate procured a small-business vendor in 

support of the Department’s small business targets, reduced risks of cost 

overages by utilizing a Firm Fixed Price contract model and realized significant 

cost savings of more than $1.5 million per year and nearly $10 million in the next 

five years for FSA. This savings was determined by the difference between the 

forecasted budget amount and final award amount of the contract.

o Continue to support Unified Servicing and Data Solution (USDS) and servicing 

initiatives.

o Continue to improve cybersecurity detection, prevention, and protection through 

compliance with FSA and Federal Cybersecurity initiatives and mandates. 

o Use of the Department of Treasury’s Do Not Pay (DNP) capability (a no-cost, 

robust analytics tool) to help detect and prevent improper payments made to 

vendors, grantees, loan recipients, and beneficiaries through sophisticated data 

matches against 19 validation databases. The databases that are included in the 

DNP can be found at https://fiscal.treasury.gov/DNP/

o Payment “Bundling”. Implementation of a payment bundling initiative to require 

servicers to consolidate multiple refund payments to one borrower into one 

payment to meet a Treasury mandate to reduce the number of checks disbursed 

by Education and improve payment integrity.
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• Delivery of planning and budget execution.

o Timely planned and executed on $1.9 billion of FY 2023 funding in support of 

USDS and other core operations across the various business units at FSA.

o Lapsed less than 1% of prior year funds during the fiscal year end closeout. 

Performance Summary and Analysis

There is one performance indicator for this strategic objective. By improving delivery of financial 

management and support of investment decisions, FSA can efficiently and effectively deliver 

organizational mission requirements.

Performance Indicator 

Performance Indicator 5.2.A: Operational Performance.

Indicator Definition: This performance indicator measures the effectiveness of the 

organization's financial planning and budget execution processes, management of financial 

systems, and compliance with applicable laws, regulations, and policies.

Period of Performance: October 2022 through September 2023.

Table 50: Performance Indicator 5.2.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A

Investment portfolio 

aligned to key 

organizational drivers 

and current fiscal year 

enacted appropriation. 

Investment portfolio 

achieves 75% of 

planned milestones. 

Organization/program 

risks are documented 

(Y/N)

Y 

Performance Result N/A N/A N/A N/A Met

Key Successes and Opportunities

In FY 2023, the Finance Directorate assessed and improved the delivery of the financial 

management by working closely with the Acquisitions Directorate and the Human Resource 

Office. The decisions to modernize FMS helped to significantly mitigate the increased risks from 

cybersecurity incidents. Continued deliberate use of federal tools, contract vehicles and focus 

on operational and process improvements will help FSA engage in more customer-centric and 

outcome-based activities.
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Strategic Objective 5.3 

Enhance procurement planning, management, and execution. 

Strategic Objective Leader: Executive Director, Acquisitions Directorate 

Overview

FSA relies on a multitude of contracts and thousands of vendor employees to deliver its 

mission. Achieving the program requirements, objectives, and outcomes requires a 

comprehensive plan. Drawing on industry-leading practices, FSA will enhance its acquisition 

strategies, develop requirements consistent with customer and partner expectations, and 

execute contractual instruments and other agreements that yield exceptional services and 

outcomes in a secure manner. By aligning FSA’s efforts regarding program and project 

planning, acquisition planning, budget formulation, and human resource management, FSA will 

be well-positioned to provide exceptional student aid experiences for borrowers and their 

families. These efforts will also enhance our engagements with our partners and other financial 

and educational institutions that contribute to the student aid experience. Collaboration and 

coordination across FSA will help streamline procurement-related processes and procedures. 

Through FSA’s requirements definition processes, program office staff will identify and clearly 

articulate key program objectives and outcomes for contracts. Critical enhancements include 

conducting market research with industry; engaging in acquisition planning as part of the 

investment management process; identifying key performance indicators, acceptable service

levels/performance metrics, and methodologies for determining program outcomes for inclusion 

in contractual instruments; and supporting both internal and external reviews and examinations 

to assess vendor performance. These improvements will enhance the quality of products and 

services procured, permit greater oversight and accountability of vendors, promote effective 

communication with stakeholders, leverage economic efficiencies with enterprise-focused 

solutions, improve FSA’s cybersecurity posture, increase socio-economic achievements, and 

lead to better outcomes for customers and partners.

Performance Summary and Analysis

There are two performance indicators for this strategic objective. This objective refers to 

procurement planning, management, and execution as it is addressed across the Federal 

Government; meaning, the planning, management, and execution of programmatic needs via 

procurement actions.
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Performance Indicator 

Performance Indicator 5.3.A: Time-duration estimates for procurement-related tasks for use in 

Program Schedules.

Indicator Definition: This performance indicator captures the time-duration estimates 

necessary to complete all procurement-related tasks, included in the Procurement Acquisition 

Lead Time (PALT) associated with meeting programmatic needs through an acquisition. As 

defined by the Federal Government, PALT is the time from date of solicitation issuance through 

the date of award. The Acquisitions Directorate, when fully staffed, will strive to execute 

procurements more efficiently than the Government’s standard without subjecting FSA to 

greater risk or sacrificing quality.

Period of Performance: October 2022 through September 2023.

Table 51: Performance Indicator 5.3.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A

Identify requisite 

tasks and 

durations for other 

procurement 

methods based 

upon law, 

regulation, policy, 

and historic 

performance

Completion of 

FSA 

Acquisitions 

Directorate 

Collaboration 

Site 

Performance Result N/A N/A N/A N/A Met

Note: The Acquisitions Directorate established a collaboration site to provide FSA partners real-time 

access to contracts-related information (where do we stand with our socio-economic achievements, 

competition, expiring contracts, active contracts, list of required procurement package contents, etc.) The 

Acquisitions Directorate added another element to the site—a list of procurement tasks and duration for a 

full-and-open competition. The intent is for program managers to leverage this list as they are 

creating/revising programmatic schedules. This planning tool should ultimately improve the program 

manager’s ability to manage a program/project’s timeline.

Performance Indicator 5.3.B: Plan, develop and implement a new investment management 

process aligning acquisitions, budget, and human capital with program planning.

Indicator Definition: This performance indicator will allow improvement to internal processing 

timelines for execution of contractual instruments and delivery of program needs.

Period of Performance: October 2022 through September 2023.

Table 52: Performance Indicator 5.3.B Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A Planning Planning

Performance Result N/A N/A N/A N/A Met
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Key Successes and Opportunities

In FY 2023, the Acquisitions Directorate, Finance Directorate, and Human Resource Office met 

frequently to brainstorm a new investment management process. These business units will 

continue to discuss and plan, as well as solicit input from other business units in the 

organization in preparation for the creation and roll-out of this new investment management 

process. The Acquisitions Directorate simultaneously led the initiative to begin consolidating 

multiple data calls of historically duplicate data elements into a single request under the annual 

Acquisition Plan development. The annual Acquisition Plan includes the list of programmatic 

needs planned to be met via a procurement action during the following fiscal year. In FY 2023, 

members of the Finance Directorate, Technology Directorate, Acquisitions Directorate, 

Enterprise Program Management Office, and Human Resources Office were all included in the 

Acquisition Plan process to capture information to support budget and spend planning, 

information technology planning, program/project planning, human capital planning, 

procurement planning, and internal and external reporting requirements.
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Strategic Objective 5.4 

Improve cybersecurity detection, prevention, and protection ensuring data 

confidentiality, integrity, and availability. 

Strategic Objective Leader: Chief Information Officer, Technology Directorate 

Overview

FISMA requires FSA’s Inspector General audit cybersecurity every year throughout the 

Department.  FSA is audited on its NIST Cybersecurity Framework functions of: Identify, 

Protect, Detect, Respond, and Recover. 

Performance Summary and Analysis

There is one performance indicator for this strategic objective. The measure met its annual 

indicator target.

Performance Indicator 

Performance Indicator 5.4.A: Cybersecurity Maturity-Level (OIG Maturity Levels).

Indicator Definition: This performance indicator measures the agencies’ progress toward 

achieving compliance with the five major FISMA categories (Identify, Protect, Detect, Respond, 

and Recover) that strengthen Federal cybersecurity, including implementing the Administration’s

priorities and best practices. 

Period of Performance: October 2022 through September 2023.

Table 53: Performance Indicator 5.4.A Results

Fiscal Year

FY 2019 FY 2020 FY 2021 FY 2022 FY 2023

Actual Actual Actual Actual Target Actual

Performance N/A N/A N/A N/A 60% at Level 

3 or higher 100%

Performance Result N/A N/A N/A N/A Met

Key Successes and Opportunities

The FY 2022 Federal Information Security Modernization Act of 2014 (FISMA) audit was the 

first time in the history of the Department that an “effective” rating, which is the highest overall 

outcome for a cybersecurity program, was achieved. In FY23’s audit that rating was exceeded 

with another “effective” score and overall higher numeric scores than the previous years. 

During FY 2023 several major initiatives contributed to the effective score: 

FSA’s Technology Directorate started the Advanced Analysis Group (AAG) as a fusion concept 

to amplify the output of several competencies within the FSA Security Operations Center 

(SOC). AAG brings together senior cybersecurity subject matter experts, threat intelligence 

specialists, and threat Hunt capabilities together in a cooperative environment to create and 

share actionable cybersecurity intelligence across the FSA and school organizations. 
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Contributions to the technical solution the highest administration priority to provide Student Aid 

Debt Relief. The debt relief initiative allowed 25 million borrowers to quickly submit relief forms 

from anywhere in the world. The Cyber Operations Division was actively to define the security 

architecture, perform pen testing, assist with issue resolution, and monitoring the service post 

deployment. This work received excellent reviews from the end users as well as news media. 

(New York Times: https://www.nytimes.com/2022/10/23/opinion/student-loan-debt-reliefapplication-process.html) 

Other significant accomplishments include priority focus on Student Aid and Borrower Eligibility 

Reform (SABER) related systems (Federal Tax Information (FTI) – Infrastructure, Module, and 

Data Mart) and risk assessments activities leading to “Authority to Operate (ATO).” This allows 

enhanced customer service by securely accessing and consuming FTI data from IRS to simplify 

and reduce the customer processing time for FAFSA applications. 

Results:

• All five Cybersecurity Framework functions assessed at Maturity Level 4 – Managed and

Measurable. 

• FY 2023’s score improved in ten areas over FY 2022

Initiatives to improve the scores in FY 2024: 

• Expand efforts to implement the capabilities described in Executive Order 14028, 

Improving the Nation's Cybersecurity. 

• Implement automation for configuration management, software asset management, IT 

operations management, and integrated cybersecurity risk identification and 

management. 

• Provide a cybersecurity information and incident reporting portal to automate for 

Institutions of Higher Education (IHEs) to securely share threat and cybersecurity 

incidents. Automate ticket generation for some use cases at the SOC.

Figure 24: FISMA Audit Results
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Fiscal Year 2023 Accomplishments of Federal 

Student Aid

During FY 2023, FSA realized additional accomplishments that were not measured specifically 

by the performance indicators implemented to measure performance against the FY 2023–27

Strategic Plan. Although not measured by FSA performance indicators, these accomplishments 

are the result of initiatives FSA undertook to support the implementation of the strategic plan or 

legislative changes. This section describes FSA’s additional accomplishments.

FSA realized the following additional accomplishments in support of Strategic Goal 1:

Improve Customer and Outcomes for Students and Borrowers.

• Introduced new features to support user questions within the Virtual Assistant for key 

administration programs such as the Debt Relief program, PSLF, Fresh Start, and return 

to repayment. Users can now find the status of their PSLF application within the Virtual 

Assistant window. 

• Introduced new features to support the digital repayment experience on Student.Aid.gov, 

including a new IDR application, the new SAVE IDR plan, a new loan consolidation 

application, an e-signature and submission solution for the PSLF form, and the ability to 

view the status of an IDR application, loan consolidation application, and PSLF form in a 

customer’s dashboard and My Activity.

• Launched the Student Loan Debt Relief application in support of the Administration’s 

student debt relief plan. While the Supreme Court issued a decision blocking the 

Department from moving forward with this plan, the application demonstrated FSA’s 

ability to rapidly deliver a customer-focused and effective form. 

• Added plain-language information to StudentAid.gov to explain the SAVE Plan 

repayment option for student loan borrowers, timelines, and processes to prepare for 

returning to repayment, details about the limited PSLF waiver, and an introduction to the 

Fresh Start option for defaulted borrowers. 

• As part of the DCC effort, FSA onboarded and updated several key communications 

within the Marketing Communications Platform as part of the DCC initiative. These 

communications enabled FSA to provide important information to its customers. Email 

communications that FSA updated as part of this effort include the PSLF Help tool, 

Federal Tax information Module, and IDR related emails. 

FSA realized the following additional accomplishments in support of Strategic Goal 2:

Advance Equity and Access to Student Financial Assistance. 

• Released the 2023-24 FAFSA form with FAFSA Simplification updates.

• Implemented two-factor verification when customers log in to StudentAid.gov to provide 

enhanced security.

• With the Marketing Communications Platform, FSA must be able to execute 

personalized and relevant communications at a crucial time where our students, parents, 

and borrowers need to have the most up-to-date status on our major programs and 
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efforts. This includes Return to Repayment, FAFSA application completions, and the 

introduction of the new SAVE plan. In addition to sending prioritized campaigns, we have 

also onboarded critical transactional communications that allow our borrowers to 

understand the status of their applications and other important programs.

FSA realized the following additional accomplishments in support of Strategic Goal 3:

Strengthen Engagement and Accountability for Educational and Financial Institutions.

• SEOSG conducted oversight reviews for more than 2,130 educational institutions 

relating to certification, deficient audit resolutions, flagged financial statements, program 

reviews, method of payment, and technical assistance. 

• Through Sept. 25, 2023, SEOSG completed 5,406 distinct eligibility actions, which 

included 1,214 recertification applications and 4,192 other institutional eligibility 

applications. SEOSG accomplished this work while resolving more than 2,130 flagged 

financial statements and deficient compliance audits, issuing 99 Program Review 

Reports and 75 Final Program Review Determinations assessing more than $38.7 

million in liabilities. SEOSG also finalized Automatic Closed School Discharge letters 

asserting $1,569,557 in liabilities on seven closed schools.

• SEOSG continued its monitoring of schools accredited by the Accrediting Council for 

Independent Colleges and Schools (ACICS) and their compliance with new 

requirements imposed after the Department's decision to withdraw recognition of the 

accrediting agency. ACICS-accredited educational institutions must submit enrollment 

reports every month, provide disclosures to students, submit a teach-out plan and a plan 

for records retention and reporting, discontinue enrolling new students into any 

educational program that cannot be finished within the 18-month period, provide 

students with access to educational records and transcripts, and provide financial 

protection to the Department. 

• Additionally, SEOSG continued to implement program participation accountability 

requirements, including requirements for owner entities to co-sign Partner Participation 

Agreements (PPAs) and a March 1, 2023, electronic announcement clarifying when the

Department would require individuals to sign PPAs in a personal capacity. 

• The Financial Institution Oversight Service Group (FIOS) initiated 18 new program 

reviews of financial institutions during FY 2023.

• During FY 2023, FIOS issued 33 oversight reports and determinations to FFEL Program 

commercial servicers, lenders, and GAs. Of those, FIOS issued 28 Final Program 

Review Determinations to financial institutions who collectively administered and 

serviced more than $85 billion dollars in FFEL Program loans during FY 2023. FIOS also 

developed and implemented updated methodologies for its program review processes.

• FSA's FIOS provided oversight of GAs, commercial lenders, and lender servicers who 

administer outstanding commercially held FFEL Program loans. At the start of FY 2023, 

that portfolio included more than $129 billion in outstanding FFEL Program loans held for 

nearly 5 million FFEL Program borrowers.

• FIOS provided operational support in the continued implementation of the Department’s 

Dear Colleague Letter GEN-21-03 expanding the loan collections pause to defaulted 

FFEL Program loans managed by non-federal GAs. FIOS performed weekly reviews of 

all participating GAs’ compliance with financial metrics, resulting in more than 780 critical 
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element assessments. FIOS also ensured GAs’ trade lines were removed from defaulted 

borrower credit reports, 0% loan interest rates were retroactively applied, involuntary 

collections ceased, Treasury Offsets were returned to borrowers, administrative wage

garnishments were addressed, refunds owed to borrower were paid, and loans subject 

to Special Mandatory Assignments were transferred.

• FIOS continued to supervise the transition of GA loan portfolios to approved successors 

and to assess and manage risks created by changes in the GA sector. Given the 

considerable financial impacts of the Department's Dear Colleague Letter GEN-21-03, 

GAs were authorized to reimburse themselves for lost revenue from Federal Fund 

accounts subject to reasonability requirements. During FY 2023, FIOS standardized the 

process to include quarterly transfers, which resulted in 48 transfers totaling $554M to 

13 GAs.

• FIOS continued to support the Department's “Fresh Start” initiative for defaulted loan 

borrowers, including providing expert consultations for the development of policy and 

policy guidance, supporting exploratory research on various policy proposals, and 

responding to communications from the FFEL Program loan participants and 

representatives. 

• FIOS was an active participant in the implementation and operation of Project Success, 

including approval of quarterly Project Success reimbursement requests from guaranty 

agencies, conducting program reviews, and random testing of expenses submitted for 

reimbursement of Project Success.

• Additionally, FIOS provided subject matter expertise within PPO, FSA, and the 

Department. FIOS staff served as the Department liaison to guaranty agencies 

participating in the FFEL Program "Common Review Initiative (CRI)" and as a non-voting 

representative to the CRI Governance Council. FIOS participated on bi-monthly FSA 

Ombudsman calls with all guaranty agencies to discuss pending issues.

• FSA’s Cohort Default Rates Group (CDR Group) reviewed the FY 2020 Draft Cohort 

Default Rates (CDRs) and the Official CDRs prior to their releases in Feb. 2023, and 

Sept. 2023, respectively. The FY 2020 Draft and Official CDR releases cover more than 

5,000 educational and financial institutions.

• After draft and official CDRs are issued, institutions may challenge the accuracy of the 

loan data used to calculate a CDR or appeal of CDR consequences. During FY 2023, 

the CDR Group processed four “Uncorrected Data Adjustment” appeals encompassing 

seven allegations of data inaccuracies in the FY 2019 Official CDRs released at the end 

of Sept. 2022. Following FSA’s Feb. 2023 release of the FY 2020 Draft CDRs, the CDR 

Group received and resolved 33 challenges submitted by schools questioning the 

accuracy of the draft CDR data with 361 allegations of incorrect data being used in the 

calculation.

• The student loan payment pause has reduced the national cohort default rate for FY 

2020 to 0%. Historically, CDRs have served as a valuable compliance tool for FSA to 

assess school eligibility to participate in the Direct Loan and Federal Pell Grant 

Programs. The FY 2020 Official CDR is based on number of borrowers who entered 

repayment on a student loan during FY 2020 and the number of those borrowers who 

were in default on one or more of their student loans as of Sept. 30, 2022. As a result of 

the student loan payment pause, which began effective March 13, 2020, nearly all 

student loan borrowers were protected against the risk of student loan default. For the 
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FY 2020 Official CDRs, more than 3.8 million student loan borrowers entered repayment 

while fewer than 200 borrowers defaulted on commercially held FFEL Program student 

loans that were excluded from the student loan payment pause.

• The Performance Management Group (PMG) supported FSA’s Partner Eligibility and 

Oversight Services Directorate (PEOSD), and other PPO directorates, groups, divisions, 

and branches through the development and review of policy, procedure development 

and refinement, training, documenting business procedures, providing subject matter 

expertise for internal and external audits, and the resolution of difficult matters. During 

FY 2023, PMG resolved 318 internal Operational Support Branch Action Requests, and 

resolved more than 150 technical questions from compliance teams and issued Formal 

Q&A procedural documents as necessary.

• During FY 2023 PMG processed 110 Financial Responsibility Notifications submitted by 

educational institutions and 335 Letters of Credit providing more than $583 million in 

financial protection to the Department.

• PMG staff also provided subject matter expertise to support the Department’s FY 2023 

negotiated rulemaking sessions and proposed regulations and public comment analysis, 

and they supported and delivered annual FSA Training Conference presentations.

• FSA’s Partner Eligibility and Oversight Services Directorate (PEOSD) Front Office 

provided ongoing support, information, and other resources including post-disaster 

communications, technical and operational assistance, regulatory and administrative 

relief, and reporting flexibilities, to students, institutions, and borrowers impacted by an 

upsurge of natural disasters across the southern and midwestern states, Pacific states 

and territories, and the East Coast.

• During the FY 2023 fiscal year, PEOSD ensured the delivery of responsive documents 

for more than 125 Freedom of Information Act (FOIA) requests for information 

concerning the Department's compliance oversight and monitoring activities for eligible 

postsecondary education institutions and ensured responses were provided to more 

than 120 inquiries submitted to senior Department officials by the public and by 

members of Congress through the Department's controlled mail processes. 

• PEOSD aided in the recovery efforts of 1,672 campuses who enrolled approximately 

2.24 million students who received more than $21.9 billion in Title IV funding to attend 

schools located in geographic areas that were adversely impacted by 35 natural 

disasters during FY 2023. A total of 3,344 emails and on-site assistance were delivered 

in conjunction with the Federal Emergency Management Agency and the U.S. 

Department of Health and Human Services. 

• PEOSD continued to support the publication of a series of updated data sets, reports, 

and other information regarding institutional outcomes and financial oversight including 

quarterly Heightened Cash Monitoring reports, Financial Responsibility Standards 

Requiring a Letter of Credit Report, Proprietary 90/10 Revenue Percentages Report, 

Financial Responsibility Composite Scores, and Proprietary Institution Conversions 

among other items. 

• PEOSD ensured fulfillment of source documents for auditor examination for a variety of 

federal audits and reviews conducted by the Department’s OIG and the GAO and 

managed responses to the draft report including corrective actions. 
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• The Clery Group assessed 117 media and complaint assessments, including 11 

complaints submitted by the public and 106 campus-crime media reports. Thirty (30) of 

these complaints and media reports warranted further assessment by the Clery Group. 

The assessments performed resulted in recommendations either for additional follow-up 

action, such as technical assistance or program review where warranted, or with 

recommendations for no further action based on the result of the additional review. 

Eighty-seven (87) media reports reviewed did not include initial information suggestive of 

school noncompliance with statutory requirements. The Clery Group extended technical 

assistance to ten schools in conjunction with the media and complaint assessments.

• As part of an internal compliance consultation program, the Clery Group provided 

feedback on draft findings of noncompliance and proposed final determinations to 

resolve more than 40 school program reviews and school audits assigned to SEOSG's 

School Participation Divisions for resolution.

• The Clery Group, together with Department colleagues, supported the implementation of 

new Violence Against Women Act (VAWA) 2022 provisions applicable to educational 

institutions including by representing Federal Student Aid on the federal interagency 

“Task Force on Sexual Violence in Education” with counterparts from the U.S. 

Departments of Education, Justice, and Health and Human Services. The Clery Group 

also significantly contributed to the November 30, 2022 "Interagency Task Force on 

Sexual Violence in Education 90-Day Report" submitted to Congress. The Clery Group 

also continued to provide support for the implementation of Section 1507 of VAWA 2022

requiring the Department to create a standardized, mandatory online campus climate 

survey tool for schools' use in gauging and reporting postsecondary student experiences 

with domestic violence, dating violence, sexual assault, sexual harassment, and stalking 

and to support future biannual reporting by the Secretary to Congress.

• The Clery Group provided expert guidance and analysis regarding school violations of 

the following laws: The Jeanne Clery Disclosure of Campus Security Policy and Campus 

Crime Statistics Act (Clery Act); the Violence Against Women Act (VAWA), the VAWA 

Reauthorization Act of 2022 (VAWA 2022), and the Drug-Free Schools and 

Communities Act Amendments of 1989 (DFSCA) including DFSCA's amendments to the 

Higher Education Act (HEA) requiring educational institutions to implement a Drug and 

Alcohol Abuse Prevention Program as a condition of their participation in the Title IV, 

HEA programs. 

• To support school compliance efforts, the Clery Group engages with educational 

institutions, professional associations, and other stakeholders to provide training and 

technical assistance. During FY 2023, the Clery Group delivered authoritative training 

and guidance to a wide number of school officials and public safety professionals who 

attended national and regional public safety conferences and workshops. The Clery 

Group also provided guidance in one-on-one and group technical assistance sessions. 

• The Clery Group recently assumed a wide range of responsibilities from the 

Department’s Office of the General Counsel to administer the Department’s collection 

and oversight of postsecondary institutions’ semiannual reporting of foreign gifts and 

contracts information required by Section 117 of the HEA. In addition to these new 

responsibilities, the Clery Group has continued providing direct oversight of Clery Act, 

VAWA, DFSCA, and VAWA 2022 requirements through program reviews of educational 

institutions and through active post-review monitoring processes for schools with a 

history of egregious violations.
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• FSA was responsible for many communication efforts with our partners in Title IV

programs. These efforts included notifications on THE new Student Aid Internet 

Gateway Enrollment Agreements, creation of a Federal Tax Information (FTI)-Specific 

Mailbox, information on the software required to receive 2024-25 ISIRs (May – 

December 2023), the 2024-25 FAFSA Launch and Prison Education Programs (June 

2021 – December 2023 and Beyond), the EDExpress 2024-25 Modernization (August

2023 – Early 2024), the 2023 Virtual FSA Training Conference (August – December

2023), the FY 2020 CDR Release (September 2023) and Foreign School Information 

Page updates (September 2023). 

• FSA’s Training Conference (FSATC) was held virtually from November 29 – December 

2, 2022. All sessions were pre-recorded and aired live. There were 13,645 participants 

representing 2,973 unique institutions. These institutions were responsible for disbursing 

more than $97 billion in Title IV aid, which represents nearly 88% of all Title IV aid 

disbursed and an average of $32 million in aid per institution. The FSA training 

conference included 38 sessions offering the latest information on policy and operations 

and seven Virtual Exhibit Hall stations. The Virtual Exhibit Hall was rebranded and 

offered at a time where there were no competing sessions. This resulted in an increase 

in attendance over previous years. 

• FSA’s Partner Technical Assistance Group (PTAG) conducted briefings for Presidents 

and Chancellors during the summer of 2023. These sessions highlighted the role of 

executive leaders and best practices for oversight and monitoring of Title IV programs, 

along with improved awareness of Title IV administration and its importance. One 

hundred forty-eight (148) leaders participated. PTAG also developed additional specialty 

training for Historically Black Colleges and Universities (HBCUs), Tribal Colleges and 

Universities (TCUs), Minority Serving Institutions (MSIs), and community colleges. 

These trainings were designed to strengthen administrative capability and reduce 

compliance and audit findings. There were five sessions with 1,087 participants. Our 

Virtual Title IV Technical Assistance provided a proactive approach to identifying the 

unique service needs of MSI’s and aids required to ensure their continued participation 

in all Title IV programs. Lastly, PTAG designed and coordinated virtual Birds of a 

Feather Engagement Sessions designed to provide financial aid administrators an 

opportunity to share ideas, strategies, and challenges associated with the administration 

of Title IV programs. These sessions provided excellent opportunities for the 

Department/FSA to receive feedback, ideas, and suggestions regarding current and 

proposed regulations, policy, and legislative guidance.

• The Project Success program was extended for three years for Phase III. The program 

continued to provide services in collaboration with guarantee agencies to 213 minority 

serving institutions. Services included but were not limited to internships, tutoring, 

coaching, emergency grant aid to support student retention, persistence, and graduation 

rates. 

• FSA’s Partner Engagement and Relationship Management Group presented an inperson session on Better FAFSA Better Future/Federal Update in Puerto Rico and the 

Better FAFSA Better Future/ American Indian Higher Education Consortium Presidents 

Meeting in Nashville, TN. They also coordinated four FSA Chief Operating Officer’s 

College and University visits (Montgomery College, University of District of Columbia, 

Northern Virginia Community College) that offered opportunities for increased 

awareness and engagement around issues of importance to these institutions. The 
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summer also afforded FSA an opportunity to attend and present at the United Negro 

College Fund UNITE Summit 2023 which brings together industry thought leaders, 

HBCU and Predominantly Black Institution leaders, educators, researchers, advocates, 

students, and practitioners to learn, share ideas, build connections, and transform 

institutions. Most recently, FSA attended and developed and presented content at the 

Annual National Historically Black Colleges and Universities (HBCUs) Week Conference 

that provides a forum to exchange information and share innovations among and 

between institutions. Stakeholders include federal agencies, private sector companies 

and philanthropic organizations.

• Earlier in this document, information was provided pertaining to the achievement of 

Strategic objective 3.3 regarding outreach and training for Title IV program participants. 

To further explain what has already been discussed, FSA provided 11 virtual Better 

FAFSA Better Future webinars in support of the FAFSA simplification and SABER 

legislation to more than 56,000 participants in the months of June and July 2023. The 

FSA Training Center (fsatraining.ed.gov) provided training and technical assistance 

services to more than 28,000 individual staff representing more than 4,500 Institutions of 

Higher Education (IHEs). This represents 84% of all Title IV Participating institutions. 

FSA provided the following: attendance at seven in-person regional conferences, seven 

virtual Wednesday Webinars, Ask-a-Fed in-person support to the National Association of 

Student Financial Aid Administrators (NASFAA) annual conference including the 

mandated Fundamentals of Title IV training, new school training site visits and 

recertification training. Training and technical assistance services were provided to 

68,385 participants as of September 15, 2023. 

• Partner Participation and Oversight’s managed systems has supported the award of 

more than $111 billion in Title IV funds for the Direct Loans, Federal Grants, and 

Campus based programs during the 2021-22 award year. Combined loans and grants 

were provided to approximately 9.9 million aid recipients.

• This fiscal year saw work on multiple Partner Connect system releases, both 

implemented and underway. FSA devoted a significant amount of time to support the 

development of the Partner Connect system release which, when fully implemented, will 

modernize FSA’s partner interactions. Activities included requirements development, 

system design aspects, design review, user acceptance testing, and postimplementation activities. 

• The Partner Management and Support Services (PMSS) Change Management team 

approved 497 Change Request (CR) packages for requirements, solution, and cost 

estimation for projects across FSA. This represents a record number of CRs. 

Approximately 97% of the change requests processed were completed within the 

established processing timelines from visioning to placing the CR under contract. 

• PMSS successfully oversaw 39 releases and 98 service packs for 9 systems. 

• Reconciled HEAL Online Processing System (HOPS) data; conducted an analysis of 

reporting differences between HOPS system data and servicer reporting data. The case 

level review included review of more than 700 loans across 3 servicers that identified 

discrepancies that date back as far as 20 years. The difference was approximately 

$3.2 million from Quarter 1 of FY 2022.  Once deployed, those loans were reconciled 

with the new system functionality. 
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• The PMSS team successfully completed several new sequencing views for PPO and the 

broader FSA organization. Sequencing illustrates the replacement and/or enhancement 

of legacy functionality with modernization efforts and flags any gaps, discrepancies, 

conflicts in timing, contract dates, Systems of Records Notices, funding, key Authorities 

to Operate, risks and decisions, and open discussion points. These new sequencing 

views included:

o Partner Connect & Participation Management Contingency View

o SABER FAFSA Award Year 24/25 Partner Communications and Training View

o FAFSA FPS Snapshot View (formerly known as the ‘Near Term View’)

o Title IV Origination & Disbursement (TIVOD) Modernization View

o FAFSA Process System 

o IDR 

o Priority Program View

o Federal Tax Information (FTI)-Data Mart

o Safeguard projects

• The COD system implemented the following key changes:

o Streamlined functionality for borrowers to apply for IDR plans—as part of the 

administration’s new SAVE Plan. 

o Created new functionality for institutions to report individual-level campus-based 

data for the Federal Work-Study program. 

o Created new functionality to restore Pell Grant eligibility for students who 

received an eligible loan discharge on or after July 1, 2017. 

• The Program Contract Management Division successfully executed several new 

Computer Matching Agreements and Memorandums of Understanding (MOUs) with the 

Federal Communication Commission which saved FSA $107,000 in Operations and 

Maintenance costs and $58,000 in development.

• The team implemented the Limited PSLF Waiver which allowed a temporary change 

such that borrowers were able to receive credit for past periods of repayment that 

otherwise wouldn't qualify for PSLF. 

• The PMSS Directorate assisted with the Better FAFSA Better Future Roadmap - An 

implementation timeline of resources, guidance, and training materials about the 

redesigned 2024-25 FAFSA® form. 

• During FY 2023, the National Student Loan Data System (NSLDS):

o Completed two runs of the Income Driven Repayment (IDR) Direct to Discharge 

Forgiveness files totaling 1.6 million loans impacting 854,000 borrowers.

o Modified processing and reporting of IDR applications to support the 

SABER/Federal Tax Information initiatives as well as creating a new interface to 

support IDR auto recertification which goes live in December 2023.
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o Created a new Application Programming Interface with the Digital Customer Care 

platform to provide a better customer experience to users on StudentAid.gov as 

they view the status of their IDR applications. 

o Completed FSA’s annual exchange with the Department of Defense to assist in 

identification of military borrowers eligible for the 0% rate benefit.

• New software and user interface have been developed for launch in EDExpress. This 

deployment addresses several longstanding requests from the user community, as well 

as implements several changes for FAFSA Simplification and IRS 1070 FTI protection.

• Managed program office acquisition support for two Federal Student Aid systems: the 

HEAL/HOPS, Postsecondary Education Participants System (PEPS), and PEPS Full 

and Open/Bridge Contract. 

• Supported the Title IV Origination & Disbursement (TIVOD) Modernization Program to 

secure the new acquisition vehicle for NSLDS, COD, Customer Service, and Enterprise 

Data Management Analytics Platform Services (EDMAPS).

• FSA’s Participation Management team:

o Updated Student Aid Internet Gateway (SAIG) Agreement/FT Mailboxes EA. 

o Implemented system enhancements for FPS integration and FTI. 

o Partnered with FSA’s Enterprise Data Office to implement a plan to allow for 

Partner Connect reports to be produced from the Enterprise Data Warehouse 

after Partner Connect 2.0 goes live. This will greatly streamline the production of 

reports and allow for significantly more comprehensive, timely, and accurate 

reports.

o Developed new data visualizations in both Tableau and Power BI, including a 

dashboard to provide a single source for vetting schools and an enhanced 

funding summary dashboard. 

• FSA has taken significant actions arising from the work of the Investigations Group, 

including denying one school’s application to continue participating in the Title IV

program based upon findings of significant fraud and misconduct, and ensuring that five 

law schools stopped enrolling students in unaccredited programs using Title IV funds 

and repaid liabilities accordingly. 

• FSA prepared to implement the Department’s new borrower defense regulation, which 

was effective July 1, 2023, but then was enjoined by a federal court in FY2023. To 

prepare to implement this regulation, the Borrower Defense Group (BDG) underwent an 

extensive process to update technologies and create new application forms. This 

process included two periods of public notice where external stakeholders could provide 

feedback and BDG incorporated or responded to all comments.

• BDG met all FY 2023 adjudication deadlines in the Sweet v. Cardona settlement. BDG 

worked with other FSA stakeholders to identify the approximately 200,000 Class 

Members eligible for Exhibit C relief under the settlement. BDG also adjudicated the 

applications from Class Members due in FY 2023 plus additional Class Member 

applications totaling approximately 40,000 total. These applications include those 

pending with the Department for the longest, including those filed between 2015 and 

2017. 
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• FSA also announced a group discharge based upon Borrower Defense findings and 

common findings related to 3 schools and resulting in discharges totaling $239 million in 

relief to more than 10,900 defrauded students in FY 2023. This included BDG 

adjudicating more than 4,800 post-Class applications which has resulted in both 

approvals and denials, including the first denial letters sent to borrowers since 2017. 

• AAASG completed more than 40 actions resulting from significant violations of Title IV

program requirements or serious harm to the programs including completing 12 loss of 

eligibility actions (seven recertification denials, three losses of eligibility for foreign 

graduate medical programs, and two PPA revocations), 18 fine actions for more than $1 

million, and 14 debarment or suspension actions against individuals. In addition to 

completed actions, AAASG also initiated three loss of eligibility actions (two 

recertification denials and one emergency/termination action), five fine actions for nearly 

$2.7 million, and three debarment actions against individuals.

• AAASG, following referrals from SEOSG and the Investigations Group, settled with 17 

schools to recover nearly $2.4 million in improperly disbursed funds for ineligible Title IV

programs or students.

• As part of FSA’s collaboration on enforcement and oversight matters, AAASG provided 

concurrence to SEOSG’s School Participation Divisions’ issuance of 40 school program 

compliance reports including findings of noncompliance identified in Program Review 

Reports, Final Program Review Determination, or Final Audit Determination, one 

approval of a reinstatement application, and two denials of initial certification 

applications.

• AAASG assisted in the resolution of 12 Final Audit Determination or Final Program 

Review Determination appeals totaling more than $4.3 million in liability payments.

• RRMG reviewed and resolved 5,635 student or borrower complaint cases against their 

institutions of higher education including 740 cases regarding the Grant Disbursement 

(Pay Out) Process at the school, 721 cases regarding the Loan Disbursement (Pay Out 

Process) at the school and 669 cases regarding Financial Allegations (Tuition and Fee 

Charges). Each case represents a student or borrower who had an issue, problem, or 

concern that FSA helped them to resolve.

FSA realized the following additional accomplishments in support of Strategic Goal 4:

Increase Workforce and Workplace Capabilities.

• Workforce Development Division initiated the Power Users Learning Series for 

Employees (PULSE) Program to provide staff with the necessary tools and strategies to 

close skill gaps using a peer-to-peer learning approach. 

• In alignment with the Department, FSA hired its first Director of DEIA to lead the 

agency’s diversity, equity, inclusion, and accessibility efforts. By hiring a dedicated

member to manage these initiatives, FSA is in alignment with Executive Order 14035 

and the Department’s DEIA Strategic plan.
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• The Workforce Development Division, the new DEIA Director, and the Acquisitions team 

collaborated to acquire DEIA training development courses to support FSA’s DEIA 

training and education plan.
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Overview of Additional Reporting Requirements

Additional Reporting Requirements presents the additional reports specifically mandated by the 

HEA to be included in the Annual Report. These required reports are listed below. 

• Legislative and Regulatory Recommendations: This report details legislative and 

regulatory recommendations that FSA provided to the Department in support of the 

Department’s regulatory activities.

• Annual Bonus Awards: This report discusses executive compensation at FSA in 

compliance with the legislative requirements under the PBO legislation that created FSA.

• Report of the Federal Student Aid Ombudsman: The report discusses the FSA 

Ombudsman’s activities in accomplishing its statutory mission of addressing complaints 

about Title IV financial aid programs.
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Legislative and Regulatory Recommendations

One of FSA’s mission responsibilities under the law is to provide input on legislative proposals 

from Congress and from the Administration and to support the Department’s regulatory activity. 

FSA also may suggest legislative or regulatory changes for consideration by the Department’s 

senior policy officials. These recommendations customarily center on improving and simplifying 

the Title IV federal student assistance programs for FSA customers, minimizing administrative 

costs, and improving program integrity. FSA’s recommendations inform the Department’s 

policymaking process, including its activities and decisions related to each year’s budget 

process. FSA provides this input and recommendations by direct contact with colleagues in the 

various policy offices within the Department, including the Office of the Under Secretary, the 

Office of Postsecondary Education, and the Office of Planning, Evaluation and Policy 

Development, at both the senior policy level and at the staff level. During the past year, FSA 

provided specific recommendations to policy officials on several issues, including:

• Interpreting the provisions of the FAFSA Simplification Act that will be implemented for 

the 2024-25 award year, including significant changes to the need analysis process and 

calculation of student eligibility for Pell Grants;

• Interpreting the provisions of the Stop Student Debt Relief Scams (STOP) Act and the 

Joint Consolidation Loan Separation Act; 

• Providing technical assistance to Congress regarding options for allowing Pell Grant 

eligibility for students enrolled in short-term programs;

• Supporting the Department’s negotiated rulemaking efforts related to gainful 

employment and financial transparency; financial responsibility; institutional certification; 

90/10 requirements; changes in ownership; administrative capability; PSLF; IDR plans; 

and student loan forgiveness.
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Annual Bonus Awards 

As required by the HEA, the Annual Report includes performance ratings and related awards for 

FSA senior managers and Senior Executive Service (SES) staff. Included in this section are the 

number of senior managers and SES staff on board as of the end of FY 2023. However, 

because FY 2023 performance results were not finalized at the time this report was prepared, 

the section discusses FY 2022 performance results.

At the end of FY 2023, there were 111 FSA senior managers and 7 SES members. The FSA 

Executive Committee contained 10 of the 111 senior managers and 2 of the 7 SES members. 

As members of the FSA Executive Committee, these senior managers reported directly to the 

COO. The remaining 101 senior managers and 5 SES staff served in a variety of senior 

positions and capacities within FSA.

The following section discusses FY 2022 performance results.

The FY 2022 performance rating and bonus for the COO are pending. For FY 2021, the COO 

received a rating of Exceptional Results and a performance bonus of $46,000 for his work at 

FSA. 

The composition of ratings for the remaining 10 senior managers and 1 SES member of the 

FSA Executive Committee achieved a performance rating of Exceptional Results. There were 3 

SES members not on the FSA Executive Committee who achieved a performance rating of 

Exceptional Results. 

Award amounts for the FSA Executive Committee ranged from approximately $9,999 to 

$26,162, depending on the performance rating and level of effort of everyone. Only individuals 

with performance ratings of High Results Achieved or Exceptional Results achieved were 

eligible for performance-based awards.

The composition of ratings for the 96 senior managers who did not serve on the FSA Executive 

Committee last year were as follows: 54 senior managers achieved a performance rating of 

Exceptional Results; 26 achieved a performance rating of High Results; and 16 achieved a 

performance rating of Results Achieved.

Award amounts for those senior managers achieving an Exceptional Results rating ranged from 

$7,117 to $9,999 with a median award of $9,042. Award amounts for those achieving a High 

Results rating ranged from $4,181 to $6,111 with a median award of $5,879.

For additional information, please refer to: Higher Education Amendments 1998/sec141
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Report of the Federal Student Aid Ombudsman

Introduction

Established by the HEA, the Ombudsman began operations on September 30, 1999. The 

Ombudsman is responsible for resolving complaints regarding Title IV financial aid programs. 

Pursuant to the HEA, the Ombudsman compiles and analyzes data on borrower complaints and 

makes appropriate recommendations. Additionally, each year the Ombudsman is required to 

describe the activities and evaluate the effectiveness of the role during the preceding year.

The Office of the Ombudsman oversees all complaints submitted directly to FSA, as well as 

complaints referred by the White House, Congress, the Department, the Consumer Financial 

Protection Bureau, state attorneys general, regulators, and other stakeholders. The information 

included in this report represents the Ombudsman’s independent judgment and does not 

necessarily represent the views of the Department. 

Overview of All Cases Received in Fiscal Year 2023

During FY 2023, FSA received 122,604 complaints—a 21% increase over the record number of 

complaints received in FY 2022.20 Complaints were submitted in a variety of ways, including by 

FSA’s website, telephone, postal mail, or email.

Figure 25: All Complaints Received by Fiscal Year

20 The FSA complaint system organizes public submissions into multiple types of cases, including complaints (cases in which an 

individual alleges a problem with the administration of federal financial aid programs or institutions of higher education), disputes 

(escalated complaints handled by the Office of the Ombudsman, which most commonly occur when a complainant disagrees with 

the initial resolution of their case), general inquiries (reports about the operation of federal student aid programs and the use of FSA 

tools), suspicious activity (reports of suspected fraud within federal financial aid programs), or unassigned cases (cases submitted 

over the web awaiting categorization by intake agents). Functionally, the Office of the Ombudsman does not distinguish between 

case types when reporting on the topics addressed in public submissions and this section refers to all cases as complaints. Data are 

current as of October 5, 2023, and reflect the number of cases stored in FSA’s case management system as of the date the data 

was extracted. FSA stopped collecting “positive feedback” cases in FY 2022. 

38,657 33,978 33,697

43,792

37,844

49,812

48,224 48,115

101,102

122,604

0

20,000

40,000

60,000

80,000

100,000

120,000

140,000

FY14 FY15 FY16 FY17 FY18 FY19 FY20 FY21 FY22 FY23
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In general, public announcements and visibility on StudentAid.gov drive traffic to FSA’s 

complaint system. For example, during FY 2016, FSA launched the first iteration of its webbased complaint intake form; complaint intake increased by more than 10,000 cases during its 

first full year of operations. In FY 2019, the announcement of the TEPSLF again drove a record 

number of complaint submissions.21

In October 2021, FSA improved the visibility of its complaint tool, which has driven elevated 

traffic to the system.22 In addition, the Administration announced several policy initiatives, 

including the limited PSLF waiver, the IDR Account Adjustment, and pandemic-related Debt 

Relief, which drove record traffic to the StudentAid.gov website, and subsequently to the 

complaint portal.23 The Department also announced its proposed settlement in the Sweet v. 

Cardona lawsuit, which prompted a significant number of complaints from students who alleged 

misconduct by their school(s).24 

During FY 2023, students and borrowers submitted complaints when they struggled to access 

the various repayment programs announced over the last two years, including the limited PSLF 

waiver, new IDR plan, SAVE. Additionally, borrowers submitted complaints about delays in loan 

discharges and forgiveness, expressing frustration that their loans were not discharged prior to 

payments resuming after the end of the COVID-19 payment pause. 

Recommendations from the Ombudsman to address operational deficiencies have been shared 

directly with the FSA COO and Department’s leadership. 

Data Limitations

The data analyzed in this section reflects the status of complaints received at the time of 

reporting. During FY 2022, as part of FSA’s broader effort to modernize how it engages with aid 

recipients, FSA transitioned to a BPO vendor model to manage FSA complaint intake, leading to 

changes in data collection and categorization.25 

During FY 2023, 91% of complaints were submitted through StudentAid.gov; web-based intake 

improves the customer experience by giving users more control over their narrative. However, 

the system currently requires intake agents to perform categorization work to route complaints 

to the correct entity or FSA business unit for resolution. The online complaint tool does not 

present users with the same categorization options as those maintained internally, so reporting 

is not uniform. The stage of the student aid lifecycle information presented in this report does 

21 The number of cases increased by 10,095 by FY 2016 and FY 2017 (See Figure 25)

22 FSA’s complaint portal link is now in the header of nearly every page on StudentAid.gov. 

23 Press Release, U.S. Department of Education, U.S. Department of Education Announces Transformational Changes to the Public 

Service Loan Forgiveness Program, Will Put Over 550,000 Public Service Workers Closer to Loan Forgiveness (October 6, 2021), 

https://www.ed.gov/news/press-releases/us-department-education-announces-transformational-changes-public-service-loanforgiveness-program-will-put-over-550000-public-service-workers-closer-loan-forgiveness; Press Release, U.S. Department of 

Education, Department of Education Announces Actions to Fix Longstanding Failures in the Student Loan Programs (April 19, 

2022), https://www.ed.gov/news/press-releases/department-education-announces-actions-fix-longstanding-failures-student-loanprograms; U.S. Department of Education, The Biden-Harris Administration’s Student Debt Relief Plan Explained (last visited 

October 20, 2022), https://studentaid.gov/debt-relief-announcement.

24 Press Release, U.S. Department of Education, Statement from U.S. Secretary of Education Miguel Cardona on Sweet Settlement 

(June 6, 2022), https://www.ed.gov/news/press-releases/statement-us-secretary-education-miguel-cardona-sweet-settlement. 25 U.S. Department of Education, Federal Student Aid, Answering the call for customers and partners: The Next Gen FSA Business 

Process Operations (BPO) vendors (September 22, 2022), https://studentaid.gov/sites/default/files/business-process-operations.pdf. 
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not necessarily reflect the selections of intake agents; where possible, it aligns with the 

selections made by students, borrowers, and aid applicants upon submission. 

In FY 2024, FSA plans to update and streamline its complaint system to assign complaints 

based on the selections made by users on the intake form. It will also update the categorization 

options presented to students, borrowers, and aid applicants so they can more accurately 

communicate their issues. These improvements will allow FSA to report in more detail on 

customer selections and will remove the need for vendors to perform categorization.

To accurately report on topics of interest, the Ombudsman Office reviewed samples of 

complaints about student loans (including those from military-connected borrowers), schools, 

and the FAFSA process. A sample population was identified by filtering on internal and external 

categories to align with the stage of the student aid lifecycle; complaints reviewed were selected 

randomly within each population. The report analyzed 10,738 complaints related to student 

loans, including 698 complaints from members of the military, 2,875 complaints related to 

schools, and 300 complaints related to the FAFSA process.26 

Complaint topics and subtopics were assigned based on an independent review of each 

complaint. Complaint narratives and associated records, including the NSLDS, the COD

database, and, where available, servicer data, were analyzed to determine the underlying cause 

of the complaint. Note that complaint topics and subtopics are distinct from online and internal 

complaint categorization options. 

Demographics of Borrower Complaints

As part of FSA’s commitment to understanding the equity impacts of the Title IV system, the 

Office of the Ombudsman is beginning to explore disparities in who is accessing FSA’s 

complaint system. This section explores differences in complainants by race and income. 

However, since the complaint system does not collect a complainant’s race or income, the 

report uses publicly available U.S. census tract data from the U.S. Census Bureau to 

approximate these characteristics. Due to case address limitations, 98,204 complaints out of the 

122,604 complaints for FY 2023 were matched to a U.S. census tract.27

During the fiscal year, borrowers reached out to FSA from every U.S. state and territory. By 

ensuring that FSA’s complaint system is accessible on StudentAid.gov, FSA gained insight 

into the issues faced by a large cross-section of federal student loan borrowers. Complaint 

volume was more concentrated in higher population areas and in cities with a higher proportion 

of public sector workers. There were also complaints from borrowers who lived outside the 

United States, borrowers who lived on military bases, incarcerated borrowers, and unhoused 

26 The number of complaints selected for each stage of the student aid lifecycle align with FSA’s FY 2023-27 Strategic Plan, which, 

under objective 1.4, directs the Ombudsman to monitor issues that affect student and borrower outcomes. The Ombudsman 

reviewed 15% of monthly volume of complaints about schools and student loans. Within applying for aid, the Ombudsman reviewed 

subset of complaints related to the FAFSA in advance of implementation of the FAFSA Simplification Act. The FY 2023 – 27 

Strategic Plan is available at https://studentaid.gov/sites/default/files/FY202327StrategicPlan.pdf

27 The U.S. Census Geocoder (https://geocoding.geo.census.gov/geocoder/) was used to match census tracts to only those cases 

with viable physical addresses from all U.S. states and Puerto Rico. Because the report uses 2021 American Community Survey 

(ACS) 5-year Estimates for data analysis (the most recent ACS five-year estimates available), the case addresses were matched to 

2021 ACS addresses, even though the geocoder may have more recent addresses. This is a possible reason why some of the case 

addresses were not viable. Other reasons for non-viable addresses were missing addresses, foreign addresses, misspelled 

addresses, and Post Office Boxes. 
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borrowers, each group of whom presents different challenges with respect to the ongoing 

communication that is required to resolve complaints.

Figure 26: Complaints by Geographic Location28

Demographics available in the case record show that borrowers of all ages complained to FSA. 

Other demographics show submission rate differences. For example, higher-balance borrowers 

disproportionately submit complaints about their loan or school. 

Figure 27: Select Demographics of Complaint Submissions29

28 The map uses borrowers’ zip codes to show geographic location. Complaints that were not made directly by the borrower and 

complaints without a U.S. zip code were not included.

29 Data in this table are based on complaints received through August 2022 and are matched to data in the NSLDS database using 

FSA’s EDWA tool. This information is limited to complainants who provided identifying information. 

 

 

 

 

 

 

 

 

 

 

 

 

 
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Complaints by Topic

Throughout the fiscal year, FSA received 122,604 complaints from students and borrowers 

seeking to manage their federal aid. Most complaints (71,588 complaints, 58%) were related to 

student loan repayment. The second most common complaint theme (22,554 complaints, 18%) 

related to web navigation problems, including reports of a website outage or site error 

messages while conducting business on StudentAid.gov. FSA received 12,834 complaints 

(11%) from individuals navigating the student aid application process, followed by 10,675 

complaints (9%) from individuals reporting problems with their school(s).

Figure 28: All Complaints Received by Stage of Federal Aid Lifecycle

Finally, FSA received 4,953 complaints (4%) about other topics, including complaints about debt 

relief scams, aid disbursement, and negative interactions with customer service agents. At the 

time of reporting, 901 complaints were still awaiting categorization by intake agents.

Servicing-Related Complaints

During FY 2023, complaints most commonly described issues related to student loan repayment 

and servicing breakdowns. Complaints described how borrowers struggled to navigate loan 

forgiveness and discharge opportunities or manage their loans as the COVID-19 payment 

pause ended. Nearly one-third of identified complaints (32%) concerned PSLF; many of these 

complaints were from borrowers who struggled to access the benefits of the limited PSLF 

waiver. Borrowers also submitted complaints about delays receiving expected discharges under 

Borrower Defense to Repayment (12%), followed by concerns related to the IDR Payment 

Count Adjustment (9%). 

The COVID-19 payment pause ended In August 2023. The return to repayment spurred a surge 

of complaints in the closing months of the fiscal year as borrowers complained about problems 

they encountered with their loans (6%) or about enrolling in and recertifying IDR plans (5%). 

Finally, borrowers complained about delays or unfulfilled requests for refunds of voluntary 

payments made during the payment pause (5%). 

Issues with Student Loans, 58%

Issues with Web Navigation, 18%

Issues Applying for Aid, 11%

Issues with Schools, 9%

Other, 4%
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Figure 29: Complaints About Student Loans by Topic30

The limited PSLF waiver period ended in October 2022. However, complaints from borrowers 

who took the necessary steps to qualify for the waiver indicate that they are still struggling to 

access the limited PSLF waiver benefits. More than 60% of borrowers who submitted 

complaints about PSLF complained about pending applications (34%) or Qualifying Monthly 

Payment counts (28%). Almost one-quarter of complaints were about unexpected Employer 

Certification Form denials (12%), problems documenting qualifying employment (6%), or issues 

with the PSLF application (6%). Finally, 6% of complaints were about delays and disputes 

regarding refunds for payments made beyond the required 120 (6%). 

Figure 30: PSLF Complaints by Subtopic31

30 This figure reports10,738 complaints reviewed; See Data Limitations section for methodological description.

31 This figure reports 3,453 PSLF complaints identified as a subset of the 10.738 servicing-related complaints reviewed by 

Ombudsman staff.

31%

5%

5%

6%

9%

12%

32%

Other

Refund Status

IDR Plans

Repayment

Payment Count

Adjustment

Borrower

Defense

PSLF

9%

6%

6%

6%

12%

28%

34%

Other

Refund Status

Application Issues

Qualifying Employment

ECF Denial

QMP Count

Application Status
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Borrowers who submitted PSLF applications during the waiver period faced backlogs or inaction 

on their pending applications. For example, one PSLF borrower awaiting servicing transfer was 

told that the PSLF servicer had no account information more than a year after application 

approval: 

In 2021, I submitted all of my PSLF paperwork. In July 2022 the servicer changed 

to MOHELA. Since that time - one full year - they have made ZERO progress on 

my application. At this point, my application has been in process for nearly 2 years, 

which I find indefensible. I have called MOHELA multiple times. I have requested 

an expedited review. Nothing ever changes. 

During the final two months of the year, borrowers submitted complaints about return to 

repayment. These complaints concerned IDR enrollment (27%), issues making payments 

(12%), difficulty accessing forbearance while waiting for discharge under Borrower Defense to 

Repayment (BD) (7%), trouble setting affordable repayment (7%), concern about the terms and 

eligibility of IDR plans (6%) and reports of being placed in the wrong repayment status (5%). 

Figure 31: Return to Repayment Complaints by Subtopic32

During the summer of 2023, FSA redesigned its IDR application to be more user-friendly and to 

allow borrowers to automatically transfer tax information from the IRS. This change provided 

borrowers with their expected payment upon completion of the application. 

Borrowers submitted complaints to FSA describing their struggles to access affordable 

payments including delays processing approved IDR applications, calculation errors that left 

them with unaffordable bills, difficulties setting up auto-debit and/or making payments, being 

switched to non-requested repayment plans, payment due dates that preceded the restart of 

payments, and untenable call wait times when they attempted to verbally apply for IDR or report 

an error. One borrower wrote: 

32 This figure reports 877 complaints about return to repayment submitted during final two months of the fiscal year 

and identified as a subset of the 10.738 servicing-related complaints reviewed by Ombudsman staff.

 

 

 

 

 

 

 

 

 

 

 

 

 

 
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I applied for the SAVE program with my servicer, Ed Financial, 8/24/23. My [FSA] 

account says that [the] application was processed on 8/25/23. ... [N]o changes 

have been made to my amount due. I have called their contact number several 

times but have been unable to speak to anyone. Today's wait time was 303 

minutes. That's over 5 hours. That is unreasonable and burdensome. I have tried 

live chat to no avail. My current amount due says $861. I am a single mother 

with 3 dependents who live with me and I make approximately $3000/month.

There is NO WAY this is feasible, reasonable, fair or anything. At the very least, I 

should be able to communicate with my loan servicer and get my loans switched 

from standard repayment plan to something that is reasonable and affordable.

School-Related Complaints

During FY 2023, FSA received 10,675 school-related complaints. These submissions covered a 

wide range of issues related to school operations after enrollment. A review of a sample of 

school-related complaints demonstrates the most common issues reported by students. More

than one-quarter of the sampled complaints concerned the timing and amount of aid awards 

(27%) 

Figure 32: School Complaints by Topic

Students complained that schools did not clearly explain school charges and out-of-pocket 

costs, sometimes impairing their ability to progress, attend, and succeed in class. One student 

enrolled in a predominantly online, public school wrote: 

My school has blocked my ability to use my financial aid. All my documents have 

been submitted. Last semester, they told me I would have $0 to pay, but by 

the end of the semester, they said I owed $491. They keep changing what I owe 

and what I can use from my aid. I have no idea how to plan. When these problems 

17%

5%

8%

9%

11%

11%

12%

27%

Other

Misrepresentation

Tuition and Fees

Withdrawal

Eligibility

Refunds

Academic Issues

Aid Award
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happen, I must stop school. They also block me from completing my classes. 

I can't submit work and do not get the education they promised. They still expect 

payment when they do this. Release my financial aid and tell me the correct 

amount that I need to pay per semester. Allow me to complete my course.

The second-most common topic concerned academic issues (12%), including reports of 

problems involving their school’s degree requirements or academic policies and administration, 

followed by concerns about aid eligibility (11%) and the timing and amount of refunds (11%). 

Students also complained about withdrawal (9%), including school charges and the return of 

aid, about tuition and fee charges (8%), and that their school made false or misleading 

statements prior to enrollment (5%).33 

Students who attended for-profit schools disproportionately submitted complaints about their 

schools relative to the share of Title IV aid funds disbursed to those schools. The for-profit 

sector accounts for 13% of annual aid volume but represents more than double (28%) that 

share of FSA’s identified complaints. In contrast, the public and private, not-for-profit school 

sectors account for a smaller share of complaints than annual federal aid volume.

Figure 33: School-Related Complaints and Federal Aid Volume by School Sector34

In addition to the sector imbalance, FSA received a disproportionate number of complaints from 

predominantly online schools. FSA received 1,872 complaints (19%) about schools where more 

than 80% of students are enrolled exclusively online. In contrast, these schools accounted for 

only 10% of enrollment in Title IV-eligible schools during the 2021-22 school year, the most 

recent year data was available. 

33 The Office of the Ombudsman Office reviewed 2,875 likely school-related complaints. This visualization does not include 666 

complaints primarily from former students about school misconduct as they sought discharge under borrower defense to repayment. 

34 The Office of the Ombudsman matched school complaints by sector using the Integrated Postsecondary Education Data System 

for the 2021-22 school year, the most recent year for which final data are available. Aid volume information was reported by the FSA 

Data Center (Award Year Summary by School Type) for the 2020-21 school year, the most recent year for which data are available. 
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Figure 34: School-Related Complaints about Predominantly Online Schools Compared 

with Share of Total Enrollment

While FSA does not track the enrollment modality of students who submit complaints, many 

complaints from students attending predominantly online schools suggest that students struggle 

to interact with those who administer relevant programs at their school(s) in this format. These 

complaints describe an environment where students must await response from financial 

advisors or supervisors to answer questions or to process enrollment changes. A student 

enrolled in a predominantly online college writes: 

I'm getting no return calls from financial aid supervisor for over a week now. I'm 

trying to speak with the supervisor to review my aid, what I will be receiving and 

when. Although I was sent an email a couple of weeks ago of a breakdown of my 

aid/tuition, I do not understand what I'm looking at. The school has [Supplemental 

Education Opportunity Grants] and I'd like to understand why I wasn't considered 

for the grant given my circumstances. According to the university, I have a student 

loan as well but that isn't shown on my FSA account and I don't know much about 

that either. There's a lot of numbers and it's intimidating. I’m very confused and am 

getting no response from the school. Before I get much further into this, I feel this 

needs to be addressed. 

Another student enrolled in a predominantly online school complained about difficulty 

processing a withdrawal request and attached documentation to the complaint, showing the 

request had been submitted more than a month prior to the withdrawal date reported to FSA in 

NSLDS: 

[School Name] took over $1,700.00 from my student loan account AFTER I had 

withdrawn IN WRITING and left a message with my “student advisor.” My email 

was acknowledged, yet they took the funds anyway and are trying to collect 

additional money from me. ... Anything taken by [school name] after March 2022 

[should be] returned by them and my student loan balanced lowered to reflect that 

reduced amount.

FSA received school complaints about more than 2,000 institutions of higher education.35

Students submitted 1,676 complaints (17 percent) about the 20 schools with the most complaint 

35 This number does not include cases where school information was not logged upon intake. 

 
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volume during the year. Many of the top 20 schools listed had the highest student enrollment for 

the most recent year data is available; other schools listed received more complaints than 

expected for their enrollment size.36

Table 54: Number of Complaints by School from Top 20 by Volume37

School No. of Complaints

University of Phoenix 162

Liberty University 134

Post University 130

Southern New Hampshire University 115

Grand Canyon University 113

Strayer University 109

Capella University 97

Colorado Technical University 96

Walden University 80

Rutgers University 80

Western Governors University 66

Florida Agricultural and Mechanical University 61

American InterContinental University 61

Florida Career College 57

Purdue University Global 56

Arizona State University Campus Immersion 55

South University 53

Hussian College 52

National University 50

Full Sail University 49

Applying for Aid Complaints

During FY 2023, FSA received 12,834 cases related to applying for aid. These cases fall into 

three broad categories: issues incurred while completing and submitting the FAFSA form, 

problems creating or logging in to StudentAid.gov using an FSA ID, and complaints about the 

FAFSA customer experience.38 

A review of a sample of complaints related to the FAFSA process found that the most common 

topic was about the inability to sign and submit the FAFSA form (16 percent), which typically 

occurs when an error has been identified somewhere on the form. Most applicants expressed 

confusion about how to resolve errors, while some did not seem to understand that an error 

prevented signature.

36 Narratives discussed in this section pertain to one of the top 20 schools by complaint volume. 

37 School complaints were aggregated by OPEID and the names were matched using the Integrated Postsecondary Education Data 

System for the 2021-22 school year, the most recent year for which final data are available. 

38 Of the 12,834 cases related to applying for aid, FSA received 7,879 complaints about the FAFSA process, 4,227 complaints 

about the FSA ID, 677 complaints about the FAFSA customer experience, and 51 complaints awaiting categorization. 
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Figure 35: Complaints About the FAFSA by Topic39

Applicants also commonly complained about the status or transmission of a completed FAFSA 

to their school (15%), web outages that prevented access to the FAFSA form (15%), and trouble 

or confusion while correcting a FAFSA (13%). A smaller share of applicants complained about 

problems transmitting income data from the IRS (7%). The remaining one-third (34%) of 

applicants complained about other topics. 

Throughout the aid application complaints, students and parents complained about the 

complexity of the FAFSA form and their frustration with the process: 

I have been correcting these complicated questions on the FAFSA form since 2020 

for my child. It is terrible for someone with low income to fill out FAFSA form. 

Please provide better guidance for people.

— 

This form is the most confusing and least user friendly to ever exist. Every single 

year I have filled this out it I feel confused, stressed, and frustrated with how long 

it takes and how inconvenient it is for parent information.

FSA will introduce a streamlined FAFSA for the 2024-25 award year as part of the FAFSA 

Simplification Act.40

39 This figure reports on a sample of 300 complaints about the FAFSA. Percentages do not add up to 100% due to rounding.

40 US Department of Education, “What is the FAFSA Simplification Act?”, available at StudentAid.gov/helpcenter/answers/article/fafsa-simplification-act.

34%

7%

13%

15%

15%

16%

Other

IRS Data

Exchange

PostSubmission

Corrections

Website

FAFSA

Transmission

and Status

Submission

Error
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Complaints from Underserved Communities

Each year, the Ombudsman Office examines the complaints received from underserved 

populations to identify potential gaps in aid delivery and make recommendations for service 

improvements. 

Nearly 100,000 complaints were matched to U.S. Census Bureau census tract data to assess 

differences in complaints based on the community where a student, borrower, or aid applicant 

lives. The analysis found that borrowers from communities of color disproportionately 

complained about the earlier stages of the financial aid lifecycle compared to other borrowers. 

One-in-four people who lived in communities of color complained about issues applying for aid 

(12 percent) or schools (13 percent). Meanwhile, 9 percent of people from majority-White 

communities complained about applying for aid and 7 percent complained about schools.41 

Figure 36: Complaints by Stage of Federal Aid Lifecycle and Race/Ethnicity of Borrower's 

Community42

There was also a notable difference in complaints between borrowers from low-income 

communities and high-income communities. Borrowers who lived in low-income communities 

complained about applying for aid and schools at a higher rate than those from high-income 

communities. Complaints about applying for aid accounted for 8 percent of complaints from 

high-income communities and 13 percent from low-income communities. Complaints about 

41 Communities of color are defined as census tracts where a majority of residents identified as either one or a combination of: 

Black or African-American only, American Indian or Alaska Native only, Asian only, Native Hawaiian or Other Pacific Islander only, 

Some Other Race only, Two or More Races, and Hispanic or Latino ethnicity (any race). Majority White communities are census 

tracts where a majority of residents identified as White only. Of the 98,204 cases that were matched to a census tract, 98,114 had 

ACS race and ethnicity data.

42 Source: Descriptive analysis of 98,114 complaints that were matched to census tracts with available race and ethnicity data from 

the ACS 2021 5-Year Estimates of BO3002: Hispanic or Latino Origin by Race table. Percentages do not add up to 100 percent due 

to rounding.

10%

12%

9%

9%

13%

7%

62%

56%

65%

17%

16%

17%

3%

4%

3%

All Complaints

Complaints from

Communities of Color

Complaints from White

Communities

Issues Applying for Aid Issues with Schools Issues with Student Loans

Issues with Web Navigation Other
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schools accounted for just 6 percent of complaints from high-income communities and 14 

percent from low-income communities.43

Figure 37: Complaints by Stage of Federal Aid Lifecycle and Income Level of Borrower's 

Community44

Complaints from Military-Affiliated Borrowers

Pursuant to its responsibilities under the Principles of Excellence, FSA monitors complaints 

submitted from service members and military families.45 During FY 2023, FSA received 7,536 

complaints from military-affiliated borrowers; of those nearly two-thirds (62 percent) concerned 

issues managing student loans.

During the fiscal year, military-related borrowers submitted complaints describing a wide range 

of student loan issues. A review of these complaints identified that more than one-third (35 

percent) concerned PSLF, followed by Borrower Defense to Repayment (15 percent), the IDR 

Account Adjustment (6 percent), general repayment issues (5 percent), IDR plans (4 percent), 

and limitations imposed on borrowers of joint consolidation loans (4 percent).

43 The report uses the lower and upper quartile of household median income by census tract to determine low- and high-income 

communities. Low-income communities are defined as census tracts where a majority of residents have a median household 

income of less than $48,679 (the 25th highest median income of all U.S. census tracts). High-income communities are defined as 

census tracts where a majority of residents have a median household income of $90,000 or more (the 75th highest median income of 

all U.S. census tracts). The U.S. Census Bureau defines household income as “pretax cash income of the householder and all other 

people 15 years old and older in the household.” Of the 98,204 cases that were matched to a census tract, 97,765 had ACS median 

income data.

44 Source: Descriptive analysis of 97,765 complaints that were matched to census tracts with available household median income 

data from the ACS 2021 5-Year Estimates of S1903: Median Income in The Past 12 Months (in 2021 Inflation-Adjusted Dollars) 

table. Percentages do not add up to 100 percent due to rounding. 

45 Executive Order No. 13607, 3 C.F.R. § 13607 (2012), https://www.federalregister.gov/documents/2012/05/02/2012-

10715/establishing-principles-of-excellence-for-educational-institutions-serving-service-members-veterans. Complainants are able 

to log their affiliation as an active member of the military, a veteran, or a dependent of an active member or veteran.

10%

13%

8%

9%

14%

6%

62%

52%

67%

17%

17%

17%

3%

4%

3%

All complaints

Complaints from

low-income communities

Complaints from

high-income communities

Issues Applying for Aid Issues with Schools Issues with Student Loans

Issues with Web Navigation Other
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Figure 38: Military-Related Complaints About Student Loans by Topic

Military-affiliated borrowers had trouble accessing forgiveness and discharge opportunities, 

which impact their ability to engage in military and civilian life and access benefits earned 

through their service.46 For example, one borrower seeking an approved loan discharge under 

Borrower Defense to Repayment described the negative effects of a protracted wait for 

discharge: 

[My l]oans should not be in repayment status, loans should be discharged due to 

[my schools] both being sued and shutdown. I received a notice in November 2022 

from the Department of Education in regards to my loans being discharged for the 

reasons above and falling off of my credit reports. Instead, I keep receiving emails 

in reference to updating the repayment plan before October 2023. ... This has 

negatively affected me for years. I have not been able to use my VA home loan 

due to my poor credit score and I am basically surviving on VA Comp/Pen. 

46 See CFPB blog post, “Time is running out for student loan servicers to help servicemembers with student loans get debt relief,” 

available at: https://www.consumerfinance.gov/about-us/blog/time-is-running-out-for-student-loan-servicers-to-helpservicemembers-with-student-loans-get-debt-relief/.

31%

4%

4%

5%

6%

15%

35%

Other

Joint

Consolidation

IDR

Repayment

Repayment

IDR Adjustment

Borrower

Defense

PSLF
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Incarcerated Students and Borrowers

In July 2023, people in prison officially regained eligibility for Pell Grants under the new Prison 

Education Program regulation.47 As colleges and universities roll out their new programs in 

2024 and beyond, hundreds of thousands of incarcerated students could eventually gain access 

to higher education. However, higher education access remains in jeopardy for those with 

defaulted student loans from before their incarceration. In FY 2023, the Ombudsman Office 

heard from currently and formerly incarcerated borrowers and students, college program staff, 

advocacy organizations, and other stakeholders about the challenges of rehabilitating the 

defaulted loans of incarcerated borrowers—a required step for Pell Grant eligibility. The 

Ombudsman Office also received 145 complaints from currently and formerly incarcerated 

borrowers.48 These sources offer insights into the challenges of managing student loans in 

prison.

Incarcerated borrowers struggle to manage their loans because of the restrictions on their 

access to the internet, email, phone, and mail. As a result, most incarcerated borrowers end up 

in default. These borrowers commonly complain about the quality of customer service they 

receive from servicers, and they lament their inability to prevent default, despite their best 

efforts.

Unfortunately, my loans went into default when I was incarcerated. . . . I could not 

receive any kind of bill while in custody. . . . When I was released from prison . . . 

I found it extremely difficult to find a job with a felony conviction on my record. [M]y 

wages . . . were garnished and I talked to someone at [my servicer] where my loan 

was held and found out my loan amount had ballooned up to more than $120,000 

from $40,000; I was told the difference was from collection fees over the years and 

interest. I don't understand how this is even legal . . . There is no way I can ever 

repay the current loan amount. . . .

Many of the incarcerated and formerly incarcerated complainants are not actually student loan 

borrowers; they are identity theft victims.49 A typical complainant of this nature alleges that while 

incarcerated, an unknown perpetrator stole their personal information to take out loans and Pell 

Grants in their name at a college they never attended. The complainants are often unaware of 

the aid disbursements until after release from prison when they get collections calls, run credit 

reports, or attempt to apply for financial aid. The Department and its contracted servicers assist 

these complainants to get the fraudulent financial aid off their accounts. Using the identities of 

incarcerated people to steal federal financial aid money is a well-documented scam, and more 

efforts are needed to combat this specific form of identity theft, particularly because it poses 

47 U.S. Department of Education, (GEN-23-05) Eligibility of Confined or Incarcerated Individuals to Receive Pell Grants (March 29, 

2023), https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2023-03-29/eligibility-confined-or-incarceratedindividuals-receive-pell-grants. 48 This also includes complaints from students who complained about being incorrectly flagged as incarcerated and complaints from 

employees of college prison programs who complained about various aspects of program administration. 

49 In 2023, the Department of Education finalized new regulations to streamline the false certification and identity theft process. 

See: https://www.ed.gov/news/press-releases/education-department-releases-final-regulations-expand-and-improve-targeted-debtrelief-programs
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such grave risks to the Administration’s goals of re-integrating formerly incarcerated borrowers 

into employment, housing, and participation in civil society.50

To address the issues faced by incarcerated borrowers, the Department launched several 

initiatives in FY 2023. First, because of the barriers identified by stakeholders related to calling 

toll-free phone numbers in prison,51 the Default Resolution Group established a new phone 

number available to incarcerated borrowers to promote accessibility. Second, FSA published a 

factsheet on how incarcerated borrowers can use the Fresh Start initiative to get out of default 

or get their loans written off.52 This fact sheet is a critically important first step towards 

communicating the benefits associated with Fresh Start since all defaulted borrowers who fail to 

register for Fresh Start will be returned to collection after August 2024. Third, FSA began an 

initiative to work directly with correctional facilities to reduce the barriers to information access 

and communication for incarcerated borrowers. These efforts—and more—demonstrate the 

Department’s commitment to improving outcomes for incarcerated borrowers.

Activities of the Ombudsman

The Ombudsman Office’s Stakeholder Engagement Group (SEG) facilitates three activities—

engagement, outreach, and financial literacy—to support FSA’s mission, as well as its 

responsibilities under various laws to increase awareness about Title IV programs and solicit 

feedback on opportunities for improvement. SEG effectuates the principles of accessibility, highquality customer service, and responsive government through a variety of engagements, 

including listening sessions, webinars, meetings, and outreach efforts. In addition, SEG uses 

stakeholder feedback to lead initiatives aimed at improving outcomes for financial aid recipients, 

especially student loan borrowers from historically underserved populations. This section 

provides examples of SEG’s most impactful work from FY 2023 and outlines programmatic 

goals for FY 2024.

Engagement 

FSA has a statutory obligation to consult with stakeholders and to solicit their feedback to 

improve the federal student aid system.53To ensure FSA hears from diverse communities, 

throughout the fiscal year, SEG worked to enhance existing relationships and create new 

connections with leaders in government, advocacy, industry, and the higher education 

community. 

Throughout the fiscal year, SEG coordinated listening sessions with stakeholders to hear 

feedback about the federal student aid system. 

50 For example, see: Press Release, United States Attorney’s Office Central District of California, Three Women Indicted for Alleged 

Scheme that Used Prison Inmates’ Identities to Fraudulently Obtain Federal Student Loans (March 3, 2023), 

https://www.justice.gov/usao-cdca/pr/three-women-indicted-alleged-scheme-used-prison-inmates-identities-fraudulentlyobtain#:~:text=LOS%20ANGELES%20%E2%80%93%20Three%20women%20were,obtain%20federal%20student%20loans%20tot

aling

51 Student Borrower Protection Center, Collection at all Costs: Examining the Intersection of Mass Incarceration and the Student 

Debt Crisis (July 2022), https://protectborrowers.org/wp-content/uploads/2022/08/Collection-at-All-Costs_Final.pdf. 52 U.S. Department of Education, (LOANS-23-08) Fact Sheet on Fresh Start Available for Confined or Incarcerated Borrowers 

(September 6, 2023), https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-09-06/fact-sheet-freshstart-available-confined-or-incarcerated-borrowers

53 20 U.S.C. § 1018(c)(3). 
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Across several listening sessions with consumer advocates, stakeholders highlighted the 

problem of language accessibility on FSA’s websites and forms. In particular, stakeholders 

requested more Spanish-language materials, that materials be written in plain language, and 

that information be made easier to find on StudentAid.gov. As a result of this feedback, FSA 

translated the IDR website and the PDF application form into Spanish. Consumer groups 

continue to push for a Spanish-language online version of the SAVE application, and for more 

multi-language outreach materials with return to repayment content. 

SEG held a listening session about joint spousal consolidation loans with representatives from 

legal aid organizations, consumer advocacy groups, and a coalition of borrowers who faced 

obstacles with uncooperative former spouses or who were victims of domestic abuse. 

Stakeholders identified how implementation delays of the Joint Consolidation Loan Separation 

Act of 2022 resulted in commercial FFEL borrowers having to pay on loans that may have 

qualified for forgiveness if not for being jointly consolidated. In response, FSA created a process 

to give commercial FFEL borrowers the option to request a forbearance pending the separation 

of their loans.54 Consumer groups and attorneys general offices described how despite this 

work, these borrowers still do not have a path to separate their loans and many had been 

denied administrative forbearance at the servicer level when payments resumed in September 

2023. Further, advocates and state attorneys general explained that these borrowers have yet 

to receive sufficient communication about initiating separation requests ahead of the one-time 

IDR account adjustment.

State agencies are critical partners to FSA, and during FY 2023, SEG worked with state 

ombudsman offices, attorneys general, state regulators, state corrections agencies, and more. 

SEG met monthly with each of the 15 state-level ombudsman offices or the state official 

equivalent to exchange information about borrower complaints, outreach efforts, and FSA’s 

student loan programs. The partnerships with these offices result in direct complaint resolution 

and new opportunities to collaborate. For example, SEG partnered with Washington state’s 

ombudsman office to create PSLF informational materials for state employees. Similarly, SEG 

shared 8,781 student debt relief scam complaints with attorneys general in 44 states, the District 

of Columbia, Puerto Rico, and the U.S. Virgin Islands. SEG convened 15 follow up meetings 

with a subgroup of these offices to assist as they leveraged FSA’s complaint data to open 

investigations, send cease and desist letters to scammers, and improve their educational 

materials about third-party debt relief scams.

In each of these engagements, SEG invites students, borrowers, state officials, legal aid 

attorneys and others to submit complaints directly to Ombudsman Office. In total, the office 

handled 466 complaints during FY 2023 that originated from SEG engagements. In addition to 

finding resolutions for the complainants, the Ombudsman Office uses these complaints to 

identify systemic problems and issues that require additional outreach and education.

54 https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2023-07-19/joint-consolidation-loan-separationact-forbearance-guidance
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Figure 39: Stakeholder Complaints by Topic

Outreach

In addition to its engagement work, SEG conducts direct outreach to students and borrowers 

through educational webinars. These outreach efforts, while generally smaller than other FSA 

outreach work, focus on communities that are traditionally underserved by FSA’s broader 

communications channels. To supplement FSA’s other efforts, SEG prioritizes creating 

customized content to better meet the communications needs of its target audiences. 

During FY 2023, SEG presented information about forgiveness programs and return to 

repayment to a variety of audiences, including university systems, AmeriCorps employees and 

alumni, borrowers working in PSLF-eligible sectors, borrowers affected by school misconduct or 

closure, borrowers impacted by natural disasters, and others, collectively reaching more than 

ten thousand students and borrowers.

SEG also hosted meetings with stakeholders to highlight the launch of new programs and 

products. For example, FSA met with state ombudsman offices, FFEL servicers, and guarantors 

to highlight the new digital application forms for PSLF and IDR, which make it easier for 

borrowers to apply for these forgiveness programs. SEG and SEAD also participated in fireside 

chats with legal aid organizations to discuss the implementation of Fresh Start. These efforts 

ensure that community partners have the best available information about FSA’s programs to 

serve their constituents.

Financial Literacy

Students and families make many high-stakes decisions regarding higher education such as 

whether to continue education beyond high school, the type of institution to attend, and how to 

pay for higher education. The choices are complex. For many, paying for higher education 

involves taking on debt. 

28%

3%

4%

7%

8%

50%

Other

Default

Fraud & Identity Theft

Borrower Defense

IDR Adjustment

PSLF
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FSA embraces the opportunity and obligation to equip students with information and resources 

to help them make informed financial decisions before, during, and after college. FSA can 

provide these resources both directly to students and families as well as collaborate with 

schools and other partners, especially other federal agencies. Federal-partner relationships are 

enhanced through Department’s role in the Treasury Department’s Financial Literacy and 

Education Commission. According to the Commission’s report on Best Practices for Financial 

Literacy and Education, effectively engaging students and providing clear, timely, and 

customized information about student borrowing could be key to reducing poor financial 

outcomes.55

The Ombudsman Office’s SEG has been tasked with defining FSA’s financial literacy strategy, 

which targets financial decisions during the student lifecycle and categorized as follows:

• Prepare: FSA will identify and execute initiatives to assist students and families in 

exploring postsecondary institutions, comparison shopping based on programs of study, 

and understanding the true cost of attendance. Applying for financial aid and completing 

the FAFSA and deciding when, whether and in whose name to borrow money are 

important concepts to understand when preparing to attend college or career school.

• Succeed: In addition to making choices about higher education and how to pay for it, 

students make many other important decisions during college such as opening a bank 

account, using a credit card, understanding the value of budgeting, and more. Building 

knowledge and good financial habits has proven to be a contributing factor for students 

to succeed and complete their program of study. FSA will focus on supporting its school 

partners with financial literacy education resources and sharing best practices as they 

endeavor to create financially capable Americans.

• Repay: Student loans are often the only means by which students can pursue higher 

education, therefore it is crucial that students understand their loan options and 

obligations well in advance of when repayment takes place. Repaying student loans is 

one of the many financial decisions that students are faced with as they transition into 

the workplace. FSA will continue its financial literacy education efforts to reach 

borrowers directly, support the work of loan servicers, and engage with stakeholders 

such as schools and third-party organizations that have relationships and direct 

influence on borrowers.

Looking Ahead

In FY 2024, SEG will build upon engagement with underserved communities identified in 

FY 2023 by prioritizing additional underserved communities, including incarcerated borrowers, 

service members, military families, older Americans, borrowers with disabilities, students and 

borrowers living in rural communities, and members of the LGBTQ+ community. 

SEG will continue to capitalize on existing relationships, disseminating critical student loan 

updates via these relationships, and seek their support in identifying community organizations 

55 See: U.S. Financial Literacy and Education Commission, Best Practices for Financial Literacy and Education at Institutions Of 

Higher Education, available at https://home.treasury.gov/system/files/136/Best-Practices-for-Financial-Literacy-and-Education-atInstitutions-of-Higher-Education2019.pdf
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that reach underserved students and families. SEG will also provide quarterly webinars on 

timely federal student aid topics. 

Further, SEG will timely communicate concerning trends and issues to those within FSA 

responsible for addressing solutions. SEG will continue to seek complaint resolutions and use 

those complaints to identify systemic problems and issues that require additional outreach and 

education. 

Through its financial literacy work, SEG looks forward to continuing to collaborate with 

stakeholders through webinars about paying for college and the impacts of student debt. In 

FY 2024, SEG will harness National Financial Capability month to bring together state and 

federal partners to share best practices for teaching personal finance and the merits of FAFSA 

completion. Finally, SEG will host listening sessions with postsecondary institutions that offer 

peer-to-peer financial counseling and provide resources and information to institutions that are 

seeking assistance on financial literacy education.
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Overview of the Financial Section

This section includes the consolidated Balance Sheet and related notes and the Independent 

Auditors’ Report. The subsections are listed below: 

• The Consolidated Balance Sheet.

• Notes to the Consolidated Balance Sheet. The Notes to the Consolidated Balance 

Sheet provide a description of significant accounting policies and detailed information on 

select financial statement line items. The notes also include information that supports the 

computation of the various financial statement activities.

• Report of the Independent Auditors. The Report of the Independent Auditors presents 

the audit report issued by the Independent Auditors. The subsection also includes the 

Office of Inspector General Audit Transmittal Letter, and Management’s Response to the 

Audit. 
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Consolidated Balance Sheet

 
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Notes to the Consolidated Balance Sheet

Note 1. Summary of Significant Accounting Policies

Note 2. Non-entity Assets

Note 3. Fund Balance with Treasury

Note 4. Other Assets

Note 5. Loan Receivables, Net and Loan Guarantee Liabilities

Note 6. Liabilities Not Covered by Budgetary Resources

Note 7. Debt Associated with Loans

Note 8. Subsidy Due to Treasury

Note 9. Other Liabilities

Note 10. Commitments and Contingencies
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Notes to the Consolidated Balance Sheet for the 

Year Ended, September 30, 2023 

Note 1. Summary of Significant Accounting Policies

Reporting Entity and Programs

Federal Student Aid (FSA) was created as a Performance Based Organization (PBO) within the 

U.S. Department of Education (the Department) in 1998, as a result of amendments to the 

Higher Education Act of 1965 (HEA), from previously existing Department student financial 

assistance program offices. FSA operates under the PBO mandate to develop a management 

structure driven by strong incentives to manage for results. FSA’s primary goal is to assist 

lower-income and middle-income students in overcoming the financial barriers that make it 

difficult to attend and complete postsecondary education.

FSA is a component of the U.S. government. For this reason, some of the assets and liabilities 

reported by FSA may be eliminated for government-wide reporting. The Consolidated Balance 

Sheet should be read with the realization that it is for a component of the U.S. government.

Federal Student Loan Programs. FSA and the Department administer the William D. Ford 

Federal Direct Loan (Direct Loan) Program, the Federal Family Education Loan (FFEL) 

Program, the Health Education Assistance Loan program (HEAL), and the Federal Perkins Loan 

program to help students and their families finance the costs of postsecondary education. A 

direct loan is any debt instrument issued to the public by the federal government. A FFEL loan 

guarantee is a guarantee, insurance, or other pledge with respect to the payment of all or part of 

the principal or interest on any debt obligation of a non-federal borrower to a non-federal lender.

The Direct Loan Program, added to the HEA in 1993 by the Student Loan Reform Act of 1993, 

authorizes FSA to make loans through participating schools to eligible undergraduate and 

graduate students and their parents. The Direct Loan Program offers four types of loans: 

Stafford, Unsubsidized Stafford, Parent Loan for Undergraduate Students (PLUS), and 

Consolidation. Evidence of financial need is required for an undergraduate student to receive a 

subsidized Stafford loan. The other three loan programs are available to borrowers at all income 

levels. Loans can be used only to meet qualified educational expenses.

The FFEL Program, authorized by the HEA, operates through state and private nonprofit 

guaranty agencies that provide loan guarantees on loans made by private lenders to eligible 

students. The SAFRA Act, which was included in the Health Care and Education Reconciliation 

Act of 2010 (HCERA), stated that no new FFEL loans would be made effective July 1, 2010. 

FFEL Program receivables include defaulted FFEL loans and acquired FFEL loans. Acquired 

FFEL loans include student loan assets acquired using temporary authority provided in the 

Ensuring Continued Access to Student Loans Act of 2008 (ECASLA). ECASLA gave FSA 

temporary authority to purchase FFEL loans and participation interests in those loans. FSA 

implemented three activities under this authority: loan purchase commitments; purchases of 

loan participation interests; and a put, or forward purchase commitment, with an Asset-Backed 

Commercial Paper (ABCP) Conduit. This authority expired after September 30, 2010; as a 

result, loan purchase commitments and purchases of loan participation interests concluded. 
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However, under the terms of the Put Agreement with the conduit, ABCP Conduit activity ceased 

operations in January 2014. (See Note 5)

Grant Programs. FSA and the Department manage numerous grant programs, which provide 

financial aid that in most cases does not need to be repaid, to students with financial need. The 

largest of these programs is the Federal Pell Grant (Pell Grant) program, which provides needbased grants to low-income undergraduate and certain post baccalaureate students that 

promotes access to postsecondary education. Other grant programs include Federal WorkStudy Program, Federal Supplemental Educational Opportunity Grants (FSEOG), Teacher 

Education Assistance for College and Higher Education (TEACH) Grants, and Iraq and 

Afghanistan Service grants.

COVID-19. COVID-19 relief legislation and administrative actions provided support for student 

loan borrowers by:

o Temporarily suspending nearly all federal loan payments, interest free. 

o Authorizing Guaranty Agencies to reimburse themselves from the Federal Student Loan 

Reserve Fund for lost revenue that resulted from student loan repayment deferrals.

o Making temporary changes to the PSLF program to allow student borrowers to get credit 

for payments made while working for a qualifying employer.

o Addressing issues with IDR payment counting.

Funding for these actions was provided through indefinite appropriations. 

Other regulatory flexibilities and incentives provided to help students through COVID-19 include:

o Stopping all federal wage garnishments and collection actions for borrowers with 

federally held loans in default. 

o Federal Supplemental Educational Opportunity Grants to provide emergency aid to 

students.

o Continuation of work-study payments, even if students can no longer work on-site.

o Pell Grants, financial aid, and loans originated for the spring 2020 term, which students 

who have had to leave college campuses will not have to pay back. Moreover, none of 

this aidwill count against students’ financial aid lifetime limits.

o Waiving satisfactory academic progress requirements to help ensure that students do 

not lose academic standing and the ability to receive federal financial student aid.

o Tax credits that incentivize employers to help pay for student loans.

Basis of Accounting and Presentation

The Consolidated Balance Sheet was prepared to report the financial position of FSA, as 

required by the Chief Financial Officers Act of 1990 and the Government Management Reform 

Act of 1994. The Consolidated Balance Sheet was prepared from the books and records of the 

Department and FSA, in accordance with Generally Accepted Accounting Principles (GAAP) 

accepted in the United States for federal entities, issued by the Federal Accounting Standards 

Advisory Board (FASAB), and the Office of Management and Budget (OMB) Circular No. A-136, 
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Financial Reporting Requirements, as revised. This Consolidated Balance Sheet is different 

from the Consolidated Balance Sheet prepared by the Department.

The accounting structure of federal agencies is designed to reflect both accrual and budgetary 

accounting transactions. Under the accrual method of accounting, revenues are recognized 

when earned and expenses are recognized when a liability is incurred, without regard to receipt 

or payment of cash. Budgetary accounting facilitates compliance with legal constraints and 

controls over the use of federal funds.

Transactions and balances among FSA funds have been eliminated from the Consolidated 

Balance Sheet.

Accounting standards require all reporting entities to disclose that accounting standard practices 

allow certain presentations and disclosures to be modified, if needed, to prevent the disclosure 

of classified information.

Accounting for Federal Credit Programs

FSA’s accounting for its loan and loan guarantees is based on the requirements of the Federal 

Credit Reform Act of 1990 (FCRA). The purpose of the FCRA is to record the lifetime subsidy 

cost (expense) of direct loans and loan guarantees, in present value terms, at the time the loan 

is disbursed (subsidy). Components of subsidy costs for loans and guarantees include defaults

(net of recoveries); contractual payments to third-party, private loan collectors who receive a set 

percentage of amounts collected; and, as an offset, origination and other fees collected. For 

direct loans, the difference between interest rates incurred by FSA on its borrowings from the 

U.S. Department of Treasury (Treasury) and interest rates charged to particular borrowers is 

also subsidized (or may provide an offset to subsidy if FSA’s rate is less).

Under the FCRA, subsidy cost is estimated using the net present value of future cash flows to 

and from FSA. In accordance with the FCRA, credit programs either estimate a subsidy cost to 

the government (a “positive” subsidy), breakeven (zero subsidy cost), or estimate a negative 

subsidy cost. Negative subsidy occurs when the estimated cost of providing loans to borrowers 

from Treasury borrowing, collection costs and loan forgiveness is less than the value of 

collections from borrowers for interest and fees, in present value terms.

The FCRA establishes the use of financing, program, and Treasury General Fund receipt 

accounts for loan guarantees committed and direct loans obligated after September 30, 1991.

o Financing accounts borrow funds from Treasury, make direct loan disbursements, collect 

fees from lenders and borrowers, pay claims on guaranteed loans, collect principal and 

interest from borrowers, earn interest from Treasury on any uninvested funds, and 

transfer excess subsidy to Treasury General Fund receipt accounts. 

o Program accounts receive and obligate appropriations to cover the positive subsidy cost 

of a direct loan or loan guarantee when the loan is approved and disburses the subsidy 

cost to the financing account when the loan is issued. Program accounts also receive 

appropriations for administrative expenses.

o Treasury General Fund receipt accounts receive amounts paid from financing accounts 

when there are negative subsidies for new loan disbursements or downward reestimates of the subsidy cost of existing loans.
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When a loan is placed in deferment or forbearance, loan repayment is temporarily suspended 

with the length of postponement different for each borrower. Interest accrues while a loan is in 

deferment or forbearance for all loan types except subsidized Direct Loans. Loans are cancelled 

if a person dies, meets disability requirements, or occasionally through the bankruptcy courts. 

Loans are also cancelled through the Public Service Loan Forgiveness (PSLF) program, which 

forgives the remaining balance on a Direct Loan after 120 qualifying monthly payments are 

made. These payments must be made under a qualifying repayment plan while working full-time 

for a qualifying employer. In addition, FSA offers income-driven repayment plans under which 

borrowers may receive forgiveness of the remaining balance of their loans after 10, 20 or 25 

years under certain rules.

Entity and Non-Entity Assets

Assets are classified as either entity or non-entity assets. Entity assets are those that FSA has 

authority to use for its operations. Non-entity assets are those held by FSA but not available for 

use in its operations. FSA non-entity assets are offset by liabilities to third parties and have no 

impact on net position. FSA combines its entity and non-entity assets on the balance sheets and 

discloses its non-entity assets in the notes. (See Note 2)

Fund Balance with Treasury

The Fund Balance with Treasury includes amounts available to pay current liabilities and 

finance authorized purchases, as well as funds restricted until future appropriations are 

received. Treasury processes cash receipts and cash disbursements for FSA. FSA’s records 

are reconciled with Treasury’s records. (See Note 3)

Accounts Receivable

Accounts receivable are amounts due to FSA from other federal agencies (intragovernmental) 

and the public (other than intragovernmental). Other than intragovernmental receivables result 

from overpayments to recipients of grants and other financial assistance programs, and 

disputed costs resulting from audits of educational assistance programs. Amounts due from 

federal agencies result from reimbursable agreements entered into by FSA with other agencies 

to provide various goods and services. Accounts receivable are reduced to net realizable value 

by an allowance for uncollectible amounts. The estimate of an allowance for loss on 

uncollectible accounts is based on FSA’s experience in the collection of receivables and an 

analysis of the outstanding balances. (See Note 4)

Cash and Other Monetary Assets

Cash and other monetary assets are the federal government’s interest in the program assets 

held by state and nonprofit FFEL Program guaranty agencies (guaranty agencies’ federal funds). 

Section 422A of the HEA required FFEL guaranty agencies to establish federal student loan 

reserve funds. Guaranty agencies’ federal funds include initial federal start-up funds, receipts of 

federal reinsurance payments, insurance premiums, guaranty agency share of collections on 

defaulted loans, investment income, administrative cost allowances, and other assets.

The balance of guaranty agencies’ federal funds represents consolidated reserve balances of 

the 15 guaranty agencies based on the guaranty agency financial reports that each agency 

submits annually to FSA. Although FSA and the guaranty agencies operate on different fiscal 
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years, all guaranty agencies are subject to an annual audit. A year-end valuation adjustment is 

made to adjust FSA’s balances to comply with federal accounting principles and disclose funds 

held outside of Treasury.

Guaranty agencies’ federal funds are classified as other than intragovernmental non-entity assets 

and are offset by a corresponding liability due to Treasury on FSA’s balance sheets. The funds 

are held by the guaranty agencies but can only be used for certain specific purposes listed in 

FSA’s regulations. The guaranty agencies’ federal funds are the property of the United States and 

are reflected in the President’s Budget. Payments made to FSA from guaranty agencies’ federal 

funds through a statutory recall or agency closures represent capital transfers and are returned to 

Treasury’s General Fund. (See Note 2)

Loan Receivables, Net and Loan Guarantee Liabilities

The financial statements reflect FSA’s estimate of the long-term subsidy cost of direct and 

guaranteed loans in accordance with the FCRA. Loans and interest receivable are valued at 

their gross amounts less an allowance for the present value of amounts not expected to be 

recovered, and thus having to be subsidized—called an “allowance for subsidy.” The difference 

between the gross amount and the allowance for subsidy is the present value of the cash flows 

to, and from, FSA that are expected from receivables over their projected lives. Similarly, 

liabilities for loan guarantees are valued at the present value of the cash outflows from FSA less 

the present value of related inflows. The estimated present value of net long-term cash outflows 

of FSA for subsidized costs is net of recoveries, interest supplements, and offsetting fees.

The loan guarantee liabilities represent the net present value of all future cash flows from 

currently insured FFEL loans, including claim payments, interest assistance, allowance 

payments, and recoveries from assigned loans. Guaranteed loans that default are initially turned 

over to guaranty agencies for collection. Defaulted FFEL loans are accounted for as assets and 

reported at their net present value, similar to direct loans, although they are legally not direct 

student loans. Credit program receivables, net includes defaulted FFEL loans owned by FSA 

and held by FSA or guaranty agencies. In most cases, after approximately four years, defaulted 

guaranteed loans not in repayment are turned over by the guaranty agencies to FSA for 

collection.

FFEL Program receivables include purchased loans and other interests acquired under an 

expired program. The cash flows related to these receivables include collections on purchased 

loans and other activities, including transfers of re-estimated subsidy. The cash flows of these 

authorities also include inflows and outflows associated with the underlying or purchased loans 

and other related activities, including any positive or negative subsidy transfers.

Capitalization of interest occurs as a result of various initiatives such as loan consolidations. As 

a result, interest receivable is reduced, and loan principal is increased. (See Note 5)

Property and Equipment, Net and Leases

FSA has very limited acquisition costs associated with buildings, furniture, and equipment as all 

federal and contractor staff are housed in leased buildings. FSA does not own real property for 
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the use of its staff. FSA leases office space from the General Services Administration (GSA). 

The lease contracts with GSA for privately and publicly owned buildings are operating leases.

The Department and FSA also lease information technology and telecommunications 

equipment, as part of a contractor-owned, contractor-operated services contract. Lease 

payments associated with this equipment have been determined to be operating leases and, as 

such, are expensed as incurred. The noncancellable lease term is one year, with the 

Department holding the right to extend the lease term by exercising additional one-year options. 

(See Notes 4 and 10)

Liabilities

Liabilities represent actual and estimated amounts to be paid as a result of transactions or 

events that have already occurred. Liabilities are classified as covered by budgetary resources if 

budgetary resources are available to pay them. Credit program liabilities funded by permanent 

indefinite appropriations are also considered covered by budgetary resources.

Liabilities are classified as not covered by budgetary resources when congressional action is 

needed before they can be paid. Although future appropriations to fund these liabilities are 

likely, it is not certain that appropriations will be enacted to fund these liabilities. Liabilities not 

requiring appropriated budgetary resources include those related to deposit funds, Subsidy Due 

to Treasury General Fund for future liquidating account collections (pre-1992 loan guarantee 

programs), and Federal Perkins Loan program balances due to be repaid to the Treasury 

General Fund. (See Note 6)

Debt Associated with Loans

FSA borrows from Treasury to provide funding for the Direct Loan, FFEL, and other credit 

programs for higher education. The liability to Treasury from borrowings represents unpaid 

principal at year-end. FSA repays the principal based on available fund balances. Interest rates 

are based on the corresponding rate for 10-year Treasury securities and are set for those 

borrowings supporting each cohort of loans once the loans for that cohort are substantially 

disbursed. Interest is paid to Treasury on September 30. (See Note 7)

Subsidy Due to Treasury

FSA must transfer to the Treasury General Fund all excess funding resulting from downward reestimates of credit program loans that are subject to FCRA requirements. This excess funding is 

included in the liability for subsidy due to Treasury and will be transferred to Treasury in the 

succeeding fiscal year upon receipt of authority from OMB. Subsidy due to Treasury also 

includes future liquidating account collections (estimated collections in excess of estimated 

outlays) for FSA’s pre-1992 FFEL and HEAL loans that, when collected, will also be transferred 

to the Treasury General Fund. (See Note 8)

Accounts Payable

Accounts payable include amounts owed by FSA for goods and services received from other 

entities, as well as payments not yet processed. Other than intragovernmental accounts payable 

to the public includes in-process grant and loan disbursements. 
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Accrued Grant Liabilities

FSA records grant expenses as grantees drawdown funding on their available grant balances. 

Some grant recipients incur allowable expenditures as of the end of an accounting period but 

have not yet drawn on their available balances to be reimbursed by FSA. FSA accrues liabilities 

for these allowable expenditures. The liability amounts are estimated using a combination of 

historical data and a statistical sample survey of current unliquidated balances. Some grantees 

drawdown funding in advance of incurring grant expenditures. A statistical estimate is made for 

these advance drawdowns and is recorded as other than intragovernmental advances (see 

Note 4).

Personnel Compensation and Other Employee Benefits

Annual, Sick, and Other Leave. The liability for annual leave, compensatory time off, and other 

vested leave is accrued when earned and reduced when taken. Each year, the accrued annual 

leave account balance is adjusted to reflect current pay rates. Sick leave and other types of 

nonvested leave are expensed as taken. Annual leave earned but not taken, within established 

limits, is funded from future financing sources. (See Notes 6 and 9)

Retirement Plans and Other Retirement Benefits. Employees participate in either the Civil 

Service Retirement System (CSRS), a defined benefit plan, or the Federal Employees 

Retirement System (FERS), a defined benefit and contribution plan. For CSRS employees, FSA 

contributes a fixed percentage of pay.

FERS consists of Social Security, a basic annuity plan, and the Thrift Savings Plan. FSA and 

the employee contribute to Social Security and the basic annuity plan at rates prescribed by law. 

In addition, FSA is required to contribute to the Thrift Savings Plan a minimum of 1 percent per 

year of the basic pay of employees covered by this system, match voluntary employee 

contributions up to 3 percent of the employee’s basic pay, and match one-half of contributions 

between 3 percent and 5 percent of the employee’s basic pay. For FERS employees, FSA also 

contributes the employer’s share of Medicare.

Contributions for CSRS, FERS, and other retirement benefits are insufficient to fund the 

programs fully and are subsidized by the Office of Personnel Management (OPM). FSA imputes 

its share of the OPM subsidy, using cost factors provided by OPM, and reports the full cost of 

the programs related to its employees in FSA’s Statements of Net Cost. These OPM imputed 

costs are offset by imputed financing sources from costs absorbed by others in FSA’s 

Statements of Changes in Net Position.

Federal Employees’ Compensation Act. The Federal Employees’ Compensation Act (FECA) 

(Pub. L. 103-3) provides income and medical cost protection to covered federal civilian 

employees injured on the job, to employees who have incurred work-related occupational 

diseases, and to beneficiaries of employees whose deaths are attributable to job-related injuries 

or occupational diseases. The FECA program is administered by the U.S. Department of Labor 

(DOL), which pays valid claims and subsequently seeks reimbursement from FSA for these paid 

claims.

The FECA liability consists of two elements. The first element, accrued FECA liability, is based 

on claims paid by DOL but not yet reimbursed by FSA. FSA reimburses DOL for claims as funds 

are appropriated for this purpose. In general, there is a two- to three-year period between 
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payment by DOL and reimbursement to DOL by FSA. As a result, FSA recognizes an 

intragovernmental liability, not covered by budgetary resources, for the claims paid by DOL that 

will be reimbursed by FSA.

The second element, actuarial FECA liability, is the estimated liability for future benefit 

payments and is recorded as an other than intragovernmental liability, not covered by budgetary 

resources. The actuarial FECA liability includes the expected liability for death, disability, 

medical, and miscellaneous costs for approved compensation cases. DOL determines the 

actuarial FECA liability annually, as of September 30, using an actuarial method that considers 

historical benefit payment patterns, wage inflation factors, medical inflation factors, and other

variables. The projected annual benefit payments are discounted to present value. (See Notes 6 

and 9)

Net Position

The components of net position are classified on the Department’s Consolidated Balance 

Sheet as follows:

Unexpended Appropriations. Unexpended Appropriations is the portion of the Department's 

appropriations received that are represented by undelivered orders or are unobligated.

Cumulative Results of Operations. Cumulative Results of Operations represents the 

accumulated net difference since inception between (1) expenses and (2) revenues and 

financing sources.

Taxes

FSA is part of a federal entity and is not subject to federal, state, or local taxes. Therefore, no 

provision for income taxes is recorded.

Use of Estimates

FSA and Department management are required to make certain estimates while preparing the 

Consolidated Balance Sheet in conformity with GAAP. These estimates are reflected in the 

assets, liabilities, and net position of the Consolidated Balance Sheet and may differ from actual 

results. FSA’s estimates are based on management’s best knowledge of current events, best 

available data, economic assumptions, historical experiences, and other assumptions that are 

believed to be reasonable under the circumstances. Significant estimates reported on the 

financial statements include: allocation of administrative overhead costs; allowance for subsidy 

and subsidy expense for direct, defaulted guaranteed and acquired loans; the liability for loan 

guarantees; and grant liability and advance accruals. (See Notes 4 and 5)

FSA’s estimates for credit reform programs are calculated using a series of assumption models 

that are updated using a statistically valid sample of National Student Loan Data System 

(NSLDS®) data, data from the Debt Management and Collection System (DMCS), and economic 

assumptions provided by the Office of Management and Budget. Actual results may differ from 

those assumptions and estimates. Differences between actual results and these estimates may 

occur in the valuation of credit program receivables and liabilities for loan guarantees under 

guidelines in the FCRA. FSA recognizes the sensitivity of credit reform modeling. Slight 

changes in modeling methodology or data used to derive assumptions can produce largely 
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varied results. FSA therefore continually reviews its model factors and statistical modeling 

techniques to reflect the most accurate credit program costs possible in its annual financial 

statements. FSA updates its assumption models in accordance with its model update plan, 

which takes into consideration statutory or new program requirements, major changes to the 

model structure or methodology, and data updates. This level of granularity in the modeling 

methodology is essential to the financial reporting and budgeting processes so that FSA can 

forecast the costs of various program options when making policy decisions. (See Note 5)

Note 2. Non-Entity Assets

(Dollars in Millions)

FSA’s FY 2023 assets are predominantly entity assets (99.8 percent), leaving the small portion 

of assets remaining as non-entity assets. Other than intragovernmental non-entity assets 

primarily consist of guaranty agency reserves (28.8 percent), reported as cash and other 

monetary assets, and Federal Perkins Loan program loan receivables (70.9 percent), reported 

as loan receivables, net. The corresponding liabilities for these non-entity assets are reflected in 

various accounts, including intragovernmental accounts payable, Guaranty Agencies’ Federal 

Funds due to Treasury, and other liabilities. (See Note 9)

Note 3. Fund Balance with Treasury

(Dollars in Millions)

In FY 2023, $297 million of unused funds from canceled appropriations were returned to 

Treasury. Such balances are excluded from the amount reported as Fund Balance with 

Treasury in accordance with Treasury guidelines.

 

 
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Note 4. Other Assets

(Dollars in Millions)

Note 5. Loan Receivables, Net and Loan Guarantee Liabilities

Loans Receivable

(Dollars in Millions)

The federal student loan programs provide students and their families with the funds to help 

meet postsecondary education costs. Funding for these programs is provided through 

permanent indefinite budget authority. The emergency relief measures provided by Congress 

and the Administration in response to the COVID-19 pandemic were recorded as loan 

modifications and are described in each of the programs below. Per OMB guidance, loan 

modifications were calculated using the President’s Budget formulation discount rates. 

As the net loans receivable represents the net present value of future cash flows, it is not 

necessarily representative of the proceeds that might be expected if these loans were sold on 

the open market.

What follows is additional analysis for each of the loan programs.

Direct Loan Program. The federal government makes loans directly to students and parents 

through participating institutions of higher education under the Direct Loan Program. Direct 

Loans are originated and serviced through contracts with private vendors.

Direct Loan Program loan receivables include defaulted and nondefaulted loans owned and 

held by FSA. Of the $1,419.6 billion in gross loan receivables, as of September 30, 2023, $76.5 

billion (5.4 percent) in loan principal was in default and had been transferred to FSA’s defaulted 

loan servicer.

 

 
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Direct Loan Program Loan Disbursements by Loan Type

(Dollars in Millions)

The allocation of disbursements for the first three loan types is estimated based on historical 

trend information.

Student and parent borrowers may prepay existing loans without penalty through a new 

consolidation loan. Under the FCRA and requirements provided by OMB regulations, the 

retirement of direct loans being consolidated is considered a collection of principal and interest. 

This receipt is offset by the disbursement related to the newly created consolidation loan. 

Underlying direct or guaranteed loans, performing or nonperforming, are paid off in their original 

cohort; new consolidation loans are originated in the cohort in which the new consolidation loan 

was obligated. Consolidation activity is taken into consideration in establishing subsidy rates for 

defaults and other cash flows. The cost of new consolidations is included in subsidy expense for 

the current-year cohort; the effect of prepayments on existing loans could contribute to reestimates of prior cohort subsidy costs. The net receivables include estimates of future 

prepayments of existing loans through consolidations; they do not reflect subsidy costs

associated with anticipated future consolidation loans.

Direct loan consolidations were $37.8 billion during FY 2023. The effect of the early payoff of 

the existing loans—those being consolidated—is recognized in the future projected cash flows 

associated with that cohort.

Direct Loan Subsidy Rates—Cohort 2023 (Unaudited)

The subsidy rates disclosed pertain only to the current year’s cohorts. These rates cannot be 

applied to the direct loans disbursed during the current reporting year to yield the subsidy 

expense. The subsidy expense for new loans reported in the current year could result from 

disbursements of loans from both current year cohorts and prior-year cohorts. The subsidy 

expense reported in the current year also includes modifications and re-estimates. 

 

 
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The subsidy costs of FSA’s student loan programs, especially the Direct Loan Program, are 

highly sensitive to changes in actual and forecasted interest rates. The formulas for determining 

program interest rates are established by statute; the existing loan portfolio has a mixture of 

borrower and lender rate formulas. Interest rate projections are based on probabilistic interest 

rate scenario inputs developed and provided by OMB.

Federal Family Education Loan Program. FFEL was established in fiscal year 1965 and is a 

guaranteed loan program. As a result of the SAFRA Act, no new FFEL loans have been made 

since July 1, 2010. Federal guarantees on FFEL program loans and commitments remain in 

effect for loans made before July 1, 2010, unless they were sold to FSA through an ECASLA 

authority (acquired FFEL loans), consolidated into a direct loan, or otherwise satisfied, 

discharged, or canceled.

FFEL Guaranteed Loans Outstanding

(Dollars in Billions)

As of September 30, 2023, the total principal value of guaranteed loans outstanding and the 

amount of that principal which is guaranteed is approximately $80.6 billion. 

Additionally, the FFEL program guarantees outstanding interest balances. As of September 30, 

2023, the interest balances outstanding for guaranteed loans held by lenders was approximately

$3.8 billion. 

FSA’s total FFEL program guarantees (principal and interest) are approximately $84.4 billion as 

of September 30, 2023. Of the total guaranteed amount, FSA would expect to pay a smaller 

amount to the guaranty agencies. The guarantee rates range from 75 to 100 percent of the 

principal and interest balance depending on the type of claim, when the loan was made, and the 

guaranty agency's claim experience. For purposes of disclosing FSA’s total risk exposure for 

FFEL guarantees, the highest reimbursement rate of 100 percent is assumed.

Defaulted and acquired FFEL loans are accounted for as assets as shown in the following table.

FFEL Program Loan Receivables

(Dollars in Millions)

 

 
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Liabilities for Loan Guarantees

(Dollars in Millions)

Other Credit Programs for Higher Education

(Dollars in Millions)

Federal Perkins Loan Program. Loans made through the Federal Perkins Loan program were 

low-interest federal student loans for undergraduate and graduate students with exceptional 

financial needs. Schools made these Perkins loans to their students and are responsible for 

servicing the loans throughout the repayment term. Borrowers who undertake certain public, 

military, or teaching service employment are eligible to have all or part of their loans cancelled.

The Perkins Loan program was a revolving loan program where the loan repayments collected 

from former students were used to make new loans to current students. FSA provided most of 

the capital used by schools to make these loans to eligible students. Participating schools 

provided the remaining program funding. In some statutorily defined cases, funds were provided 

by FSA to reimburse schools for loan cancellations. The above schedule includes only Perkins 

loans that were assigned to FSA when schools discontinued their participation in the program. 

For these assigned Perkins loans, collections of principal, interest, and fees, net of amounts 

paid to cover contract collection costs totaled $343 million for FY 2023.

The Federal Perkins Loan Program Extension Act of 2015 (Extension Act) eliminated the 

authorization for schools to make new Perkins loan disbursements as of September 30, 2017, 

and ended all Perkins loan disbursements by June 30, 2018. Before the authority for new 

Perkins loans ended, collections made by the schools would go back into each school’s Perkins 

fund to be used to make more loans. Schools are required to return to FSA the federal share of 

any excess beyond what is needed (excess liquid capital).

Schools are not required to liquidate and close out their programs now that no new Perkins 

loans are being made. Schools continue to take in collections and are required to return the 

federal share of the capital that is collected to FSA on an annual basis. Schools returned $521 

million to FSA in FY 2023 for the federal share of collected cash.

 

 
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Beginning with the 2023 reporting year, as part of the wind-down of the Federal Perkins Loan 

Program, the Secretary began requiring schools to assign to FSA all Perkins Loans that have 

been in default for more than two years for which there have been no current collections. While 

the mandatory assignment policy has driven more schools to liquidate, the majority of schools 

are continuing to service existing portfolios to recover the money they contributed to their 

Perkins funds and will do so for as long as it is feasible or until the eventual wind-down of their 

portfolios. Schools that liquidate and close out their programs must transfer any outstanding 

portfolio to FSA and liquidate any final cash. Most recent data from the 2024-25 FISAP shows a 

$1.6 billion outstanding principal balance on Perkins loans held by schools and FSA’s equity 

interest on this portfolio is $1.4 billion.

The amounts collected by FSA annually for defaulted Perkins loans and for the return of the 

federal share of schools’ Perkins capital contributions are returned to the Treasury General 

Fund. 

TEACH Grant Program. FSA awards annual grants of up to $4,000 to eligible undergraduate 

and graduate students who agree to serve as full-time mathematics, science, foreign language, 

bilingual education, special education, or reading teachers at high-need schools for four years

within eight years of graduation. The maximum lifetime grant for students is $16,000 for 

undergraduate programs and $8,000 for graduate programs. For students failing to fulfill the 

service requirement, the grants are converted to Direct Unsubsidized Stafford Loans. The 

program is operated as a loan program under the FCRA for budget and accounting purposes 

since grants can be converted to direct loans. 

TEACH Subsidy Rates—Cohort 2023 (Unaudited)

HEAL Program. FSA assumed responsibility in FY 2014 for the HEAL program and the 

authority to administer, service, collect, and enforce the program. The HEAL program is 

structured as required by the FCRA. A liquidating account is used to record all cash flows to and 

from the government resulting from guaranteed HEAL loans committed before 1992. All loan 

activity for 1992 and beyond is recorded in corresponding financing accounts.

 
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Note 6. Liabilities Not Covered by Budgetary Resources

(Dollars in Millions)

Note 7. Debt Associated with Loans

(Dollars in Millions)

FSA borrows from Treasury’s Bureau of the Public Debt to fund the disbursement of new loans 

and the payment of credit program outlays and related costs. FSA makes periodic principal 

payments, after evaluating the cash position and liability for future outflows in each program and 

pays interest, as mandated by the FCRA. 

Approximately 94.8 percent of FSA’s debt, as of September 30, 2023, is attributable to the 

Direct Loan program. 

Note 8. Subsidy Due to Treasury

(Dollars in Millions)

 

 

 
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Note 9. Other Liabilities

(Dollars in Millions)

Note 10. Commitments and Contingencies

FSA discloses contingencies where any of the conditions for liability recognition are not met and 

there is at least a reasonable possibility that a loss or an additional loss may have been incurred 

in accordance with FASAB Standard No. 5, Accounting for Liabilities of the Federal 

Government. The following commitments are amounts for contractual arrangements that may 

require future financial obligations.

Future Minimum Lease Payments 

(Dollars in Millions)

FSA leases from GSA all or a portion of privately owned and publicly owned buildings in 11 

cities. The table above presents the estimated future minimum lease payments for these 

privately and publicly owned buildings. The decrease in the estimated future minimum lease 

payments is due to anticipated releases of building and floor rentals. 

Guaranty Agencies

FSA may assist guaranty agencies experiencing financial difficulties. FSA has not done so in FY 

2023 and does not expect to in future years. No provision has been made in the financial 

statements for potential liabilities.

 

 
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Litigation and Other Claims

The Department is involved in various lawsuits incidental to its operations. In the opinion of 

management, the ultimate resolution of pending litigation will not have a material effect on 

FSA’s financial position. As appropriate, the Department would seek recovery from Treasury’s 

Judgment Fund for any loss in litigation that may occur. The Judgment Fund is a permanent, 

indefinite appropriation available to pay judgments against the government if appropriated funds 

cannot be used.

The cost of loan forgiveness related to borrower defense claims reflected in the accompanying 

financial statements is limited to loans originated through September 30, 2023. The final 

disposition of claims filed and those yet to be filed from loans originated before September 30, 

2023, is not expected to have a material impact on these financial statements.
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Overview of the Other Information Section

This section includes the consolidated Statement of Net Cost, consolidated Statement of 

Changes in Net Position and the combined Statement of Budgetary Resources and related 

notes. It also includes Required Supplementary Information, a summary of the financial 

statement audit, links to the Management Assurance and Management Challenges sections 

located in the AFR, and the Payment Integrity section. The subsections are listed below:

• Unaudited Financial Statements: The unaudited financial statements consist of the 

following statements: Statement of Net Cost, Statement of Changes in Net Position and 

Statement of Budgetary Resources.

• Notes to the unaudited Financial Statements: The notes to the unaudited financial 

statements provide a description of significant accounting policies and detailed 

information on select financial statement line items. The notes also include information 

that supports the computation of the various financial statement activities.

• Required Supplementary Information (Unaudited): The unaudited Required 

Supplementary Information includes the Combining Statement of Budgetary Resources 

by Program.

• Summary of the Financial Statement audit 

• Management Assurance

• Management Challenges

• Payment Integrity Section
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Consolidated Statement of Net Cost 

 
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(Unaudited)

Consolidated Statement of Changes in Net Position 

 
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Combined Statement of Budgetary Resources

 
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Notes to the Consolidated Statement of Net Cost, 

Consolidated Statement of Changes in Net Position, 

and Combined Statement of Budgetary Resources

Note 11. Other Accounting Policies

Note 12. Property and Equipment

Note 13. Credit Program Subsidy Expense and Reconciliations of Loans Receivable, 

Allowance for Subsidy, and Liabilities for Loan Guarantees

Note 14. Roll-Forward of Debt Associated with Loans

Note 15 Net Cost

Note 16 COVID-19 Activity

Note 17. Statements of Budgetary Resources

Note 18. Reconciliation of Net Cost to Net Outlays

Note 19. Other Matters
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Other Information

(Unaudited)

Notes to the Consolidated Statement of Net Cost, Consolidated 

Statement of Changes in Net Position, and Combined Statement 

of Budgetary Resources for the Year Ended, September 30, 

2023 (Unaudited)

Note 11. Other Accounting Policies

Basis of Accounting and Presentation

These financial statements were prepared to report the net cost of operations, changes in net 

position, and budgetary resources of the Department, as required by the Chief Financial Officers 

Act of 1990 and the Government Management Reform Act of 1994. 

These financial statements were prepared from the books and records of the Department and 

FSA, in accordance with Generally Accepted Accounting Principles (GAAP) accepted in the 

United States for federal entities, issued by the Federal Accounting Standards Advisory Board 

(FASAB), and the Office of Management and Budget (OMB) Circular A-136, Financial Reporting 

Requirements, as revised. For FY 2023, FSA elected to present these financial statements as 

unaudited and include them in the Other Information section. These financial statements are 

different from the financial reports prepared by the Department pursuant to OMB directives. 

The accounting structure of federal agencies is designed to reflect both accrual and budgetary 

accounting transactions. Under the accrual method of accounting, revenues are recognized 

when earned and expenses are recognized when a liability is incurred, without regard to receipt 

or payment of cash. Budgetary accounting facilitates compliance with legal constraints and 

controls over the use of federal funds.

Subsidy Cost and Budgetary Accounting for Federal Credit Programs 

Under the FCRA, subsidy cost is estimated using the net present value of future cash flows to 

and from the Department. In accordance with the FCRA, credit programs either estimate a 

subsidy cost to the government (a “positive” subsidy), breakeven (zero subsidy cost), or 

estimate a negative subsidy cost. Negative subsidy occurs when the estimated cost of providing 

loans to borrowers from Treasury borrowing, collection costs, and loan forgiveness is less than 

the value of collections from borrowers for interest and fees, in present value terms.

Subsidy cost is an estimate of the present value cost of providing direct loans but excludes the 

administrative costs of issuing and servicing the loans. The Department estimates subsidy costs 

using a set of econometric and financial models, as well as cash flow models. 

FSA estimates subsidy costs annually for new loans disbursed in the current year; updates to 

the previous cost estimates for outstanding loans disbursed in prior years (subsidy reestimates); and updates to previous cost estimates based on new legislation or other 

government actions that change the terms of existing loans (loan modifications) that alter the 

estimated subsidy cost and the present value of outstanding loans. Loan modifications can also 

include modification adjustment gains and losses to account for the difference between the 
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discount rate used to calculate the cost of the modification and the interest rate at which the 

cohort pays or earns interest.

The subsidy costs of direct loan and loan guarantee programs are budgeted and tracked by the 

fiscal year in which the loan award is made, or the funds committed. Such a grouping of loans or 

guarantees is referred to as a “cohort.” A cohort is a grouping of direct loans obligated or loan 

guarantees committed by a program in the same year even if disbursements occur in 

subsequent years.

To account for the change in the net present value of the loan portfolio over time, the subsidy 

cost is amortized each year. Amortization accounts for the differences in interest rates, accruals, 

and cash flows over the life of a cohort, ensuring that cost is reflected in subsidy estimates and 

re-estimates. Amortization of subsidy is calculated as the difference between interest received 

from borrowers and Treasury (on uninvested funds) and interest paid to Treasury on 

borrowings. 

Promissory notes are signed when schools reach individual agreements with borrowers and the 

schools subsequently report each disbursement of advanced funds to FSA. A new promissory 

note is usually not required for students in the second or later year of study.

Half of all loan awards are issued in the fourth quarter of the fiscal year. Loans awarded are 

typically disbursed in multiple installments over an academic period. As a result, loans may be 

disbursed over multiple fiscal years. Loan awards may not be fully disbursed due to students 

leaving or transferring to other schools. The Department’s obligation estimate may also not 

reflect the actual amount of awards made. Based on historical averages, the Department 

expects approximately 7.8 percent of the amount obligated for new loan awards will not be 

disbursed.

Budgetary Terms

The purpose of Federal budgetary accounting is to control, monitor, and report on funds made 

available to the Department by law and help ensure compliance with the law.

Budgetary resources are amounts that are available to incur and liquidate obligations in a given 

year. FSA’s budgetary resources include unobligated balances of resources from prior years 

and new resources, which include appropriations, authority to borrow from Treasury, and 

spending authority from collections. Obligations are legally binding agreements that will result in 

outlays, immediately or in the future. Budgetary resources must be available before obligations 

can be incurred legally. 

Borrowing authority is an indefinite budgetary resource authorized under the FCRA. This 

resource, when realized, finances the unsubsidized portion of the Direct Loan, FFEL, and other 

loan programs. In addition, borrowing authority is requested to cover the cost of the initial loan 

disbursement as well as any related negative subsidy to be transferred to Treasury General 

Fund receipt accounts. Treasury prescribes the terms and conditions of borrowing authority and 

lends to the financing account amounts as appropriate. Amounts borrowed, but not yet 

disbursed, are included in uninvested funds and earn interest. Treasury uses the same 

weighted average interest rates for both the interest charged on borrowed funds and the interest 

earned on uninvested funds. Treasury sets a different fixed interest rate to be used for each 

loan cohort once the loans are substantially disbursed. FSA may carry forward borrowing 
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authority to future fiscal years if cohorts are disbursing loans. All borrowings from Treasury are 

effective on October 1 of the current fiscal year, regardless of when FSA borrowed the funds, 

except for amounts borrowed to make annual interest payments.

Authority to borrow from Treasury provides most of the funding for disbursements made under 

the Direct Loan, FFEL, and other loan programs. Subsidy and administrative costs of the 

programs are funded by appropriations. Borrowings are repaid using collections from borrowers, 

fees, and interest on uninvested funds.

Unobligated balances represent the cumulative amount of budgetary resources that are not 

obligated and that remain available for obligation under law, unless otherwise restricted. 

Resources expiring at the end of the fiscal year remain available for five years, but only for 

upward adjustments of prior-year obligations, after which they are canceled and may not be 

used. Resources that have not expired at year-end are available for new obligations, as well as 

upward adjustments of prior-year obligations. Funds are appropriated on an annual, multiyear, 

or no-year basis. Appropriated funds expire on the last day of availability and are no longer 

available for new obligations. Amounts in expired funds are unavailable for new obligations but 

may be used to adjust previously established obligations.

Permanent Indefinite Budget Authority. The Direct Loan, FFEL, and other loan programs 

have permanent indefinite budget authority through legislation to fund subsequent increases to 

the estimated future costs of the loan programs. Parts B, Federal Family Education Loan 

Program, and D, Federal Direct Student Loan, of the HEA pertain to the existence, purpose, and 

availability of permanent indefinite budget authority for these programs.

Reauthorization of Legislation. Funds for most Department programs are authorized, by 

statute, to be appropriated for a specified number of years, with an automatic one-year 

extension available under Section 422 of the General Education Provisions Act. Congress may 

continue to appropriate funds after the expiration of the statutory authorization period, effectively 

reauthorizing the program through the appropriations process. The current President’s Budget 

presumes all programs continue in accordance with congressional budgeting rules.

Outlays are the liquidation of obligations that often takes the form of an electronic funds transfer. 

Outlays are reported on the SBR net of offsetting collections and distributed offsetting receipts.

Offsetting collections and offsetting receipts are generally amounts collected from (1) businesslike transactions with the public or (2) intragovernmental transfers. Offsetting collections usually 

may be used by the Department once received without further legislation whereas offsetting 

receipts must be appropriated to be used.

Offsetting receipts and offsetting collections both “offset” or reduce outlays. Offsetting 

collections reduce outlays at the expenditure account level, whereas offsetting receipts 

generally reduce outlays at the agency or Government-wide level. Offsetting receipts can be 

either “distributed” or “undistributed,” with distributed offsetting receipts shown on the SBR 

reducing agency outlays and undistributed offsetting receipts reducing Government-wide 

outlays (and not shown on the SBR).

Budgetary transactions are included as outlays or receipts in the Budget and ultimately affect 

the budget deficit or surplus whereas non-budgetary amounts are a means of financing and do 

not affect the deficit or surplus. Non-budgetary amounts include the non-budgetary financing 
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account amounts for loan and loan guarantee programs shown on the SBR. Financing accounts 

reflect program cash flows as distinct from credit “program” accounts, which are budgetary and 

reflect the subsidy cost of the programs. 

Imputed Costs

Services are received from other federal entities at no cost or at a cost less than the full cost to 

FSA. Consistent with accounting standards, certain costs of the providing entity that are not fully 

reimbursed by FSA are recognized as imputed costs in the Statements of Net Cost and are 

offset by imputed revenue in the Statements of Changes in Net Position. Such imputed costs 

and revenues relate to employee benefits. However, unreimbursed costs of services other than 

those related to employee benefits are not included in FSA’s financial statements.

Net Cost

Net cost consists of gross costs less earned revenue. Major components of FSA’s net costs 

include credit program subsidy expense, credit program interest revenue and expense, and 

grant expenses. Administrative overhead costs are allocated to loan and non-credit programs 

based on number of applications processed, number of loans serviced, dollar amount of loan 

originations, cost of school compliance actions, and the cost to collect defaulted loans.

Credit Program Subsidy Expense. Subsidy expense is an estimate of the present value cost 

of providing loans, excluding the administrative costs of issuing and servicing the loans. To 

estimate subsidy expense, FSA must project lifetime cash flows associated with loans disbursed 

in a specific fiscal year (i.e., the loan cohort). FSA projects these lifetime cash flows using a set 

of econometric and financial models, as well as cash flow models. FSA estimates subsidy 

expenses annually for new loans disbursed in the current year; updates the previous cost 

estimates for outstanding loans disbursed in prior years (subsidy re-estimates); and updates 

previous cost estimates based on changes to terms of existing loans (loan modifications). Loan 

modifications include actions resulting from new legislation or from the exercise of 

administrative discretion under existing law, which directly or indirectly alters the estimated 

subsidy cost of outstanding direct loans (or direct loan obligations). The change in book value of

direct loans resulting from a modification and the cost of modification will normally differ due to 

the use of different discount rates or the use of different measurement methods. Any difference 

between the change in book value and the cost of modification is recognized as a modification 

adjustment transfer gain or a modification adjustment transfer loss. 

Credit Program Interest Revenue and Expense. FSA recognizes other than 

intragovernmental interest revenue when interest is accrued on Direct Loan Program loans, 

defaulted and acquired FFEL loans, and outstanding principal for other loan programs. Interest 

due from borrowers is accrued at least monthly and is satisfied upon collection or capitalization 

into the loan principal. Federal interest revenue is recognized on the unused fund balances with 

Treasury in the financing accounts.

Federal interest expense is recognized monthly on the outstanding borrowing from Treasury 

(debt) used to finance direct loan and loan guarantee programs. Accrued interest to Treasury is 

paid on September 30. The interest rate for federal interest expense is the same as the rate 

used for federal interest revenue.
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Other Information

(Unaudited)

Interest expense equals interest revenue plus administrative fees accrued for all credit 

programs due to subsidy amortization. Subsidy amortization is required by the FCRA and 

accounts for the difference between interest expense and revenue cash flows. For direct loans, 

the allowance for subsidy is adjusted with the offset to interest revenue. For guaranteed loans, 

the liability for loan guarantees is adjusted with the offset to interest expense. 

Net Position

Net position consists of unexpended appropriations and cumulative results of operations. 

Unexpended appropriations include undelivered orders and unobligated balances, except for 

amounts in financing accounts, liquidating accounts, and trust funds. Cumulative results of 

operations represent the net difference since inception between (1) expenses and (2) revenues 

and financing sources.

Use of Estimates

FSA and Department management is required to make certain estimates while preparing 

consolidated financial statements in conformity with GAAP. These estimates are reflected in the 

net cost and net position of the financial statements and may differ from actual results. The 

Department’s estimates are based on management’s best knowledge of current events, best 

available data, economic assumptions, historical experiences, and other assumptions that are 

believed to be reasonable under the circumstances. Significant estimates reported on the 

Consolidated Statement of Net Cost and the Consolidated Statement of Changes in Net 

Position include: allocation of Department administrative overhead costs; and subsidy expense 

for direct, defaulted guaranteed, and acquired loans. (See Notes 13 and 15)

Note 12. Property and Equipment

Changes in property and equipment balances were as follows.

Property and Equipment

(Dollars in Millions)

Note 13. Credit Program Subsidy Expense and Reconciliations

of Loans Receivable, Allowance for Subsidy, and Liabilities for 

Loan Guarantees

The net loans receivable increased by $214.3 billion during FY 2023 as a result of activity 

identified in the following table.

 
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Reconciliation of Loan Receivables, Net

(Dollars in Millions)

When Department-held loans are written off, the unpaid principal and interest are removed from 

the gross amount of loans receivable, along with an offsetting amount charged to the allowance 

for subsidy. Prior to the write off transaction, the estimated uncollectible amounts are provided 

for in the subsidy cost allowance through the subsidy cost estimate, re-estimates, or loan 

modifications. Therefore, the write off transactions do not affect the net loan receivable or 

expenses.

Other adjustments to allowance for subsidy for defaulted FFEL guaranteed loans shown in the 

table above includes the Department’s allocation of current year subsidy re-estimates and 

 
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modifications to the allowance for subsidy for Department-held defaulted FFEL guaranteed 

loans.

What follows is additional analysis for each of the loan programs.

Direct Loan Program 

Direct Loan Program Reconciliation of Allowance for Subsidy

(Dollars in Millions)

The estimation process used to determine the amount of positive or negative subsidy expense 

each fiscal year, and subsequently the cumulative taxpayer cost of the program (allowance for 

subsidy), is subject to various external risk factors that often show strong interdependence with 

one another. These risks include uncertainty about changes in the general economy, changes in 

the legislative and regulatory environment, and changing trends in borrower performance 

related to contractual cash flows within the loan programs.

Due to the complexity of the Direct Loan Program, there is inherent projection risk in the 

process used for estimating long-term program costs. As stated, some uncertainty stems from 

potential changes in student loan legislation and regulations because these changes may 

fundamentally alter the cost structure of the program. Operational and policy shifts may also 

affect program costs by causing significant changes in borrower repayment timing. Actual 

performance may deviate from estimated performance, which is not unexpected given the longterm nature of these loans (cash flows may be estimated up to 40 years), and the multitude of 

projection paths and possible outcomes. The high percentage of borrowers in IDR plans has 

made projection of borrower incomes a key input for the estimation process. This uncertainty is 

directly tied to the macroeconomic climate and is another inherent program element that 

displays the interrelated risks facing the Direct Loan Program. The Department utilizes the best 

data available with modeling techniques that have been examined over time by several outside 

entities. Management has confidence over the estimates by using several different tools to 

analyze cost estimates. Re-estimates on the loan portfolio are performed twice a year ensuring 

that the most up to date data and models are used.

Loans written off result from borrowers having died, becoming disabled, or having a loan 

approved for discharge in bankruptcy or other type of discharge, including borrower defense 

discharges. The interest rate re-estimate reflects the cost of finalizing the Treasury borrowing 

 
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rate to be used for borrowings received to fund the disbursed portion of the loan awards 

obligated.

Direct Loan Program Subsidy Expense

(Dollars in Millions)

Subsidy Expense for Direct Loans Disbursed in the Current Year. The two major 

components of the total subsidy expense for direct loans disbursed in the current year (subsidy 

transfers) are Interest Rate Differential and Other components. Interest Rate Differential is 

attributable to the difference between the borrowers’ interest payments due to FSA and FSA’s 

estimated cost to finance the direct loan on a present value basis. The Other component of 

subsidy transfers primarily consists of contract collection costs, program review collections, 

fees, and loan forgiveness.

Loan Modifications. Loan modifications for the Direct Loan Program for FY 2023 included the 

following:

• Loan Deferral Extension. In FY 2023, the administration extended the student loan 

repayment deferrals through August 31, 2023. The extended relief for borrowers resulted 

in an upward modification cost of $23.2 billion. There was a net positive $0.1 billion 

modification adjustment transfer associated with this modification, bringing the total FY 

2023 modification cost for the Direct Loan Program student loan repayment deferrals to 

$23.3 billion.

• Borrower Defense to Repayment and Arbitration. The Department developed 

regulations to create a fair path for borrowers to receive a discharge if their colleges lied 

 
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or took advantage of them. The regulations established a process for group claims 

based on common evidence, to provide for full relief of loans and refund of payments 

made, stop interest accrual within a certain period upon granting a forbearance related 

to a claim, establish timeframes for resolving a claim, and establish a reconsideration 

process for denied borrower defense claims. These changes resulted in an upward 

modification cost of $4.2 billion. There was a net negative $0.1 billion modification 

adjustment transfer associated with this modification, bringing the total modification cost 

to $4.1 billion. 

• PSLF. The PSLF Program removes the burden of student debt on public servants by 

canceling loans after 10 years of public service. The Department updated the PSLF 

application process and expanded the types of payments considered to qualify toward 

loan cancellation and described the types of qualifying employment. The updates 

included features of the limited-time PSLF waiver related to the treatment of specific 

deferments and forbearances and payments made prior to consolidation. A provision 

was included that allows individuals who work as contractors for a qualifying employer in 

a position or providing services that, under applicable State law, cannot be filled or 

provided by a direct employee of the qualifying employer, to receive PSLF. These 

changes resulted in an upward modification cost of $4.0 billion. There was a net positive 

$0.1 billion modification adjustment transfer associated with this modification, bringing 

the total modification cost to $4.1 billion. 

• Total and Permanent Disability Discharges. The Department streamlined the 

application process, eliminated the 3-year post discharge income monitoring period, and 

expanded the Social Security Administration categories that qualify for the discharge. 

These changes resulted in an upward modification cost of $4.3 billion. There was a net 

positive $0.1 billion modification adjustment transfer associated with this modification, 

bringing the total modification cost to $4.4 billion. 

• Closed School Discharge. The Department expanded the automatic discharge process 

for borrowers that attended a college that closed and clarified the treatment for 

borrowers that re-enroll in comparable programs. These changes resulted in an upward 

modification cost of $3.4 billion. There was a net positive $0.3 billion modification 

adjustment transfer associated with this modification, bringing the total modification cost 

to $3.7 billion. 

• Interest Capitalization. Interest capitalization occurs when accrued interest is added to 

the principal balance of the loan, so that future interest accrues on a higher amount. The 

Department eliminated interest capitalization wherever it is not required by statute. This 

change resulted in an upward modification cost of $3.4 billion. There was a net positive 

$0.1 billion modification adjustment transfer associated with this modification, bringing 

the total modification cost to $3.5 billion. 

• IDR Saving on a Valuation Education (SAVE) Plan. The Department published a Final 

Rule to revise the existing Revised Pay-As-You-Earn (REPAYE) repayment plan, which 

may also be referred to as the SAVE plan. These changes resulted in an upward 

modification cost of $70.9 billion. There was a net negative $0.5 billion modification 

adjustment transfer associated with this modification, bringing the total modification cost 

to $70.4 billion. 

• Broad Based Debt Relief Reversal. A downward modification was calculated to 

reverse the inclusion of student loan debt relief from the baseline subsidy cost as a 
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result of the Supreme Court’s ruling on Biden v. Nebraska on June 30, 2023. These 

changes resulted in a downward modification cost of $319.4 billion. There was a net 

negative $0.5 billion modification adjustment transfer associated with this modification, 

bringing the total modification cost (savings) to $319.9 billion.

• Fresh Start/On Ramp. Fresh Start is a one-time temporary program that offers special 

benefits for borrowers with defaulted federal student loans. In addition to Fresh Start, the 

President announced that the Department is instituting a 12-month "on-ramp" to 

repayment, running from October 1, 2023, to September 30, 2024, so that financially 

vulnerable borrowers who miss monthly payments during this period are not considered 

delinquent, reported to credit bureaus, placed in default, or referred to debt collection 

agencies. These actions resulted in an upward modification cost of $2.9 billion. There 

was a net negative $0.7 billion modification adjustment transfer associated with this 

modification, bringing the total modification cost to $2.2 billion. 

Net Upward/Downward Subsidy Re-Estimates for All Prior Year Loan Cohorts. The Direct 

Loan Program subsidy re-estimate increased subsidy expense in FY 2023 by $71.4 billion. Reestimated costs only include cohorts that are 90 percent disbursed (i.e., cohort years 1994–

2022). The re-estimate reflects the assumption updates and other changes described below.

In addition to the major assumption updates described below, the re-estimate reflects several 

other assumption updates, including loan volume, enter repayment rates, and Teacher Loan 

Forgiveness.

• Non-IDR Discharges. The Department updated the assumption to include a standard 

data update with data from NSLDS that included an update to closed school discharges 

and PSLF waiver discharges for borrowers not enrolled in IDR. The primary adjustment 

to the model this cycle was removing adjustments to the rates for total permanent 

disability and projecting those factors from the actuals in the data. The combined effect 

of these updates led to a net upward re-estimate of $29.9 billion.

• IDR Model Changes. The Department completed a standard IDR data update that 

included updates for defaults and collections, updated poverty guidelines, and revised 

inflation rates provided in OMB’s economic assumption package. This cycle also 

featured an update to the deferment and forbearance rates in the IDR model to account 

for updated projections based on servicing guidelines that suggest that there may be 

many fewer forbearances in IDR in the future as well as adjustments for retroactive 

changes implemented regarding past forbearances. The combined effect of these 

updates led to a net upward re-estimate of $26.5 billion.

• Deferment and Forbearance. The Department updated deferment and forbearance 

rates for fiscal years 2023 and prior with updated forecasted rates. Economic 

assumptions were updated for unemployment rate, and fiscal years 2020 through 2023 

were updated for actual payments made by students during the repayment deferral 

period using data from FSA. The combined effect of these changes led to a net 

downward re-estimate of $2.3 billion. 

• Collections. The Department updated FY 2023 collection rates to reflect the extension 

of the repayment deferral, along with other technical changes. The combined effect of 

these changes led to a net upward re-estimate of $16.4 billion.
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• Default. The default assumption was updated to include forecasted rates that spread 

future defaults more evenly across future fiscal years at the end of the Fresh Start 

period. The effect of these changes led to a net downward re-estimate of $0.6 billion.

• Repayment Plan Selection. The Department incorporated new repayment plan data 

through FY 2022 and updated the repayment plan assumption for cohorts prior to FY 

2020. This update led to a net upward re-estimate of $6.4 billion.

• 2022 Cohort Assumption Changes. The technical re-estimate cannot reflect the 

impacts of certain assumption changes applicable to the current year loan cohort until 

the following fiscal year per OMB guidance. The current year’s re-estimate includes a 

net upward adjustment of $0.2 billion for these current-year assumption changes 

attributable to the FY 2022 cohort.

• Interest on the Re-Estimate. Interest on re-estimates is the amount of interest that 

would have been earned or paid by each cohort on the subsidy re-estimate if the reestimated subsidy had been included as part of the original subsidy estimate. The 

interest on the re-estimate calculated on the overall subsidy re-estimate resulted in a net 

upward re-estimate of $16.8 billion.

• Interactive Effects. The re-estimate includes a net downward re-estimate of $18.2 

billion attributed to the interactive effects of the assumption changes described above. 

Each assumption described above is run independently. The interactive effect is a result 

of combining all assumptions together to calculate the final re-estimate.

• Discount Rates. The rates are used to calculate the NPV of the cash flows to create 

subsidy rates. Adjustments to the 2021 and 2022 cohorts were calculated. All other 

cohorts are actual. The combined effect of these changes led to a net upward reestimate of $0.8 billion. 

Direct Loan Program Interest Expense and Revenues 

(Dollars in Millions)

 
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Federal Family Education Loan Program. 

Reconciliation of Liabilities for Loan Guarantees

(Dollars in Millions)

Other activity includes negative special allowance collections, collections on defaulted FFEL 

loans, guaranty agency expenses, and loan cancellations due to death, disability, or bankruptcy.

Allowance for Subsidy Reconciliation for Acquired FFEL Loans

(Dollars in Millions)

 

 
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FFEL Program Subsidy Expense

(Dollars in Millions)

Loan Modifications. Loan modifications for the FFEL Loan program for FY 2023 included the 

following:

• Loan Deferral Extension. In FY 2023, the administration extended the student loan 

repayment deferrals through August 31, 2023. The extended relief for borrowers resulted 

in an upward modification cost of $2.6 billion for the FFEL Program student loan 

repayment deferrals.

• Broad Based Debt Relief Reversal. A downward modification was calculated to 

reverse the inclusion of student loan debt relief from the baseline subsidy cost as a 

result of the Supreme Court’s ruling on Biden v. Nebraska on June 30, 2023. These 

changes resulted in a downward modification cost of $13.6 billion. There was a net 

positive $0.7 billion modification adjustment transfer associated with this modification, 

bringing the total modification cost (savings) to $12.9 billion.

• Fresh Start/On Ramp. Fresh Start is a one-time temporary program that offers special 

benefits for borrowers with defaulted federal student loans. In addition to Fresh Start, the 

President announced that the Department is instituting a 12-month "on-ramp" to 

repayment, running from October 1, 2023, to September 30, 2024, so that financially 

vulnerable borrowers who miss monthly payments during this period are not considered 

delinquent, reported to credit bureaus, placed in default, or referred to debt collection 

agencies. These actions resulted in an upward modification cost of $3.2 billion. There 

 
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was a net negative $0.2 billion modification adjustment transfer associated with this 

modification, bringing the total modification cost to $3.0 billion. 

• Support for the Federal Student Loan Reserve Fund. The Department authorized the 

Guaranty Agencies to reimburse themselves from the Federal Fund for lost revenue that 

resulted from the student loan repayment deferrals during the Fresh Start period. The 

reimbursements cover the share of what the Guaranty Agencies would have collected 

during the pandemic but for the suspension. This relief for the Guaranty Agencies 

resulted in an upward modification cost of $0.7 billion.

Net Upward/Downward Subsidy Re-estimates. The total FFEL subsidy re-estimate increased 

subsidy expense in FY 2023 by $11.7 billion. The net upward re-estimates in the FFEL Program 

were due primarily to increased non-IDR discharges in the Loan Purchase Commitment and 

Loan Participation Purchase programs.

Other Credit Programs for Higher Education

TEACH Grant Program. 

Loan Modifications. Loan modifications for the TEACH Program for FY 2023 included the 

following:

• Loan Deferral Extension. In FY 2023, the administration extended the student loan 

repayment deferrals through August 31, 2023. The extended relief for borrowers resulted 

in an upward modification cost of $9.2 million in the TEACH Program. There was a net 

positive $0.1 million modification adjustment transfer associated with this modification, 

bringing the total modification cost to $9.3 million. 

• Broad Based Debt Relief Reversal. A downward modification was calculated to 

reverse the inclusion of student loan debt relief from the baseline subsidy cost as a 

result of the Supreme Court’s ruling on Biden v. Nebraska on June 30, 2023. These 

changes resulted in a downward modification cost of $51.1 billion. There was a net 

positive $1.8 billion modification adjustment transfer associated with this modification, 

bringing the total modification cost (savings) to $49.3 billion.

• Fresh Start/On Ramp. Fresh Start is a one-time temporary program that offers special 

benefits for borrowers with defaulted federal student loans. In addition to Fresh Start, the 

President announced that the Department is instituting a 12-month "on-ramp" to 

repayment, running from October 1, 2023, to September 30, 2024, so that financially 

vulnerable borrowers who miss monthly payments during this period are not considered 

delinquent, reported to credit bureaus, placed in default, or referred to debt collection 

agencies. These actions resulted in an upward modification cost of $1.9 billion. There 

was a net negative $0.4 billion modification adjustment transfer associated with this 

modification, bringing the total modification cost to $1.5 billion. 

• IDR Saving on a Valuation Education (SAVE) Plan. The Department published a Final 

rule to revise the existing Revised Pay-As-You-Earn (REPAYE) plan, which may also be 

referred to as the SAVE plan. The SAVE plan is available to student borrowers with a 

FFEL loan that has been converted into a Direct Consolidation Loan that is in good 

standing. These changes resulted in an upward modification cost of $0.9 billion. 
Fiscal Year 2023 Annual Report | Federal Student Aid 203

Other Information

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HEAL Program.

Loan Modifications. Loan modifications for the HEAL Program for FY 2023 included the 

following:

• Loan Deferral Extension. In FY 2023, the administration extended the student loan 

repayment deferrals through August 31, 2023. The extended relief for borrowers resulted 

in an upward modification cost of $0.9 million in the HEAL Program. 

Note 14. Roll-Forward of Debt Associated with Loans

(Dollars in Millions)

Most of the $445.0 billion new Direct Loan Program borrowing activity for the year was 

designated for funding downward modifications. Principal repayments during FY 2023 for the 

Direct Loan Program totaled $155.5 billion.

During FY 2023, TEACH net borrowing was used for the advance of new grants and 

repayments of principal made to Treasury.

 
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Other Information

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Note 15. Net Cost

Gross Costs and Exchange Revenue by Program

(Dollars in Millions)
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Other Information

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Credit Program Interest Expense and Revenues

(Dollars in Millions)

Interest expense equals interest revenue plus administrative fees accrued for all credit 

programs due to subsidy amortization. Subsidy amortization is required by the FCRA and 

accounts for the difference between interest expense and revenue cash flows. For direct loans, 

the allowance for subsidy is adjusted with the offset to interest revenue. For guaranteed loans, 

the liability for loan guarantees is adjusted with the offset to interest expense.

Due to the COVID-19 relief actions to suspend nearly all required federal student loan payments 

and set borrower interest rates to zero percent until August 31, 2023, new interest revenues were 

only recognized for part of FY 2023. Interest adjustments and reapplication activities are also 

included in the current year’s other than intragovernmental interest in the schedule above. 

Adjustments and reapplications cause loan activity during the period between the original 

effective date and the new processing date to be reversed and reposted. As a result, interest 

accrued in a prior year is reversed and typically reposted. The amount of interest reposted can 

be different than the original amount depending on the purpose of the adjustment and whether 

the adjustment or reapplication caused an increase or decrease to the principal balance as of 

the original effective date. These adjustments and reapplications resulted in net negative FY 

2023 interest revenue for the FFEL Program.

Grant Expenses

(Dollars in Millions)

Pell Grants – Provides need-based grants to students to promote access to postsecondary 

education. Grant amounts are dependent on the student’s expected family contribution, the cost 

of attendance (as determined by the institution), the student’s enrollment status (full-time or 

part-time), and whether the student attends for a full academic year or less. Pell Grants are the 

single largest source of grant aid for postsecondary education.

 

 
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Federal Work-Study Program – Provides funds by formula to enable eligible institutions to offer 

employment to students based on financial needs. The program is available to full-time or parttime students and encourages community service work. The work is often related to the 

student’s course of study. Hourly earnings under this program must be at least the federal 

minimum wage. Federal funding, in most cases, pays 75 percent of a student’s hourly wage, 

with the remaining 25 percent paid by the employer.

Federal Supplemental Education Opportunity Grants – Provides funds by formula to enable 

eligible institutions to offer grants to students based on need. Federal grants distributed under 

this program are administered directly by the financial aid office at each participating school.

Note 16. COVID-19 Activity 

(Dollars in Millions)

The COVID-19 relief legislation and administrative actions provided support for student loan 

borrowers during FY 2023 by suspending nearly all federal student loan payments through 

August 31, 2023, interest free. Funding for these actions was provided through indefinite 

appropriations, and the cost impacts were recorded as loan modifications. These COVID-19 

loan modifications are a component of a subsidy expense that reduced the overall credit 

program loan receivable balances. (See Notes 5 and 13)

Note 17. Statements of Budgetary Resources

The SBR compares budgetary resources with the status of those resources. As of September 

30, 2023, budgetary resources were $787.4 billion and net agency outlays were $158.8 billion.

 
Fiscal Year 2023 Annual Report | Federal Student Aid 207

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Net Adjustments to Unobligated Balances Brought Forward

(Dollars in Millions)

During the year ended September 30, 2023, certain adjustments were made to the balance of 

unobligated budgetary resources available as of October 1, 2022. These adjustments included, 

among other things, recoveries of prior year unpaid obligations that resulted from downward 

adjustments of undelivered orders that were obligated in a prior fiscal year.

Unused Borrowing Authority

(Dollars in Millions)

FSA is given authority to draw funds from Treasury to finance the Direct Loan, FFEL, and other 

loan programs. Unused borrowing authority is a budgetary resource and is available to support 

obligations for these programs. FSA periodically reviews its borrowing authority balances in 

relation to its obligations resulting in the withdrawal of unused amounts.

Undelivered Orders at the End of the Period

(Dollars in Millions)

 

 

 
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Undelivered orders represent the amount of goods and/or services ordered that have not been 

actually or constructively received. Paid amounts include any orders that may have been 

prepaid or advanced but for which delivery or performance has not yet occurred.

Distributed Offsetting Receipts

(Dollars in Millions)

Distributed offsetting receipts are amounts that FSA collects that are used to offset or reduce 

FSA’s budget outlays. FSA’s outlays are measured on both a gross and net basis, with net 

outlays being reduced by offsetting receipts.

Most of the distributed offsetting receipts line item on the SBR represents amounts paid from 

the Direct Loan Program and FFEL Program financing accounts to Treasury General Fund 

receipt accounts for downward current fiscal year executed subsidy re-estimates, downward 

modifications, and negative subsidies.

Reconciliation of the SBR to the Budget of the United States Government

(Dollars in Millions)

The FY 2025 President’s Budget, which presents the actual amounts for the year ending 

September 30, 2023, has not been published as of the issue date of these financial statements. 

The FY 2025 President’s Budget is scheduled for release in February 2024 and will be made 

available on OMB’s website. The table above reconciles the FY 2022 SBR to the FY 2024 

President’s Budget (FY 2022 actual amounts) for budgetary resources, new obligations and 

upward adjustments, distributed offsetting receipts, and net outlays.

Reconciling differences exist because the President’s Budget excludes expired funds. 

Additionally, the President’s Budget includes a public enterprise fund that reflects the gross 

 

 
Fiscal Year 2023 Annual Report | Federal Student Aid 209

Other Information

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obligations by the FFEL Program for the estimated activity of the consolidated federal fund of 

the guaranty agencies. Ownership by the federal government is independent of the actual 

control of the assets. Since the actual operation of the federal fund is independent from FSA’s 

direct control, budgetary resources and new obligations and upward adjustments are estimated 

and disclosed in the President’s Budget to approximate the gross activities of the combined 

federal fund. Amounts reported on the SBR for the federal fund are compiled by combining all 

guaranty agencies’ annual reports to determine a net valuation amount for the federal fund.

Budgetary Status of Fund Balance with Treasury

(Dollars in Millions)

Available unobligated balances represent amounts that are apportioned for obligation in the 

current fiscal year. Unavailable unobligated balances represent amounts that are not 

apportioned for obligation during the current fiscal year and expired appropriations no longer 

available to incur new obligations.

 
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Note 18. Reconciliation of Net Cost to Net Outlays

(Dollars in Millions)

This reconciliation explains the relationship between FSA’s net cost and its net outlays. 

Reconciling items result from transactions that did not result in a current period outlay but did 

result in a current period cost, and current period outlays that did not result in a current period 

cost.

Disbursements for new FCRA loans and collections of principal and interest on existing FCRA 

loans are recorded in nonbudgetary credit reform financing accounts. These disbursements and 

collections are reported on the Statement of Budgetary Resources as disbursements, net, and 

not as agency outlays, net. Since these disbursements and collections affect neither net cost of 

 
Fiscal Year 2023 Annual Report | Federal Student Aid 211

Other Information

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operations nor agency outlays, net, they are excluded from this reconciliation as are any 

increases or decreases in the FCRA loan receivable balances.

The two major reconciling differences, both associated with FSA’s FCRA loan programs, are for 

Year-End Credit Reform Subsidy Accrual Re-estimates (current-year subsidy accrual costs) and 

Effect of Prior-Year Credit Reform Subsidy Re-estimates (current-year budget subsidy costs).

• Current-year subsidy accrual costs are the portion of the current-year loan subsidy reestimates not impacting the current year outlays.

• Current-year budget subsidy costs are current year indirect appropriations provided to 

fund subsidy costs accrued in the prior year. This includes the portion of the current 

year’s executed President’s Budget re-estimates not included in this year’s net cost 

subsidy expense. 

Note 19. Other Matters

Some portion of the current-year financial assistance expenses (grants) may include funded 

recipient expenditures that are subsequently disallowed through program review or audit 

processes. In the opinion of management, the ultimate disposition of these matters will not have 

a material effect on the FSA’s financial position.
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Other Information

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Summary of the Financial Statement Audit

The following table provides a summarized report of FSA’s financial statement audit.

Audit Opinion: Disclaimer 

Restatement: No

Table 55: Summary of Financial Statement Audit 

Material Weaknesses Beginning 

Balance New Resolved Consolidated Ending Balance

Total Material Weaknesses 1 1 0 1 1 

Management Assurances

For details on the management assurances related to the FSA programs, please refer to the 

Analysis of Systems, Controls and Legal Compliance discussion in the Management’s 

Discussion and Analysis section of this document as well as the Summary of Financial 

Statement Audit and Management Assurances located in the Other Information section of 

the Department’s AFR.

Management Challenges

For details on FSA Management Challenges, please refer to the Office of Inspector General’s 

Management and Performance Challenges for Fiscal Year 2024 Executive Summary found

in the Other Information section located within the Department’s AFR.

Payment Integrity

Payment Integrity Information Act Reporting

The Payment Integrity Information Act of 2019 (Pub. L. 116-117) requires federal agencies to 

report information annually on improper payments and unknown payments to the President and 

Congress. For improper payment and unknown payment information, FSA’s activities are part of 

an overall Departmental integrated reporting effort and reported on paymentaccuracy.gov. 

Additional information on the Department’s payment integrity program can be found in the 

Department’s AFR.

In FY 2023, the Federal Pell Grant and Direct Loan Programs are the FSA programs identified 

as susceptible to significant improper payments and OMB designated high priority programs. 

FSA continues to place additional emphasis on these important programs as required by OMB 

guidance to ensure payment integrity and minimize improper payments and unknown payments. 

The methodologies used to estimate Federal Pell Grant and Direct Loan improper payments
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and unknown payments are described on the Department’s improper payments website. 

Details on FSA’s Federal Pell Grant and Direct Loan sampling and estimation methodologies, 

improper payment and unknown payment estimates, root causes, and corrective actions can be 

found at paymentaccuracy.gov. 
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Appendices (Unaudited)
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Appendix A: Performance Metrics and Target 

Changes

Appendix A includes any modifications made to the strategic plan. These modifications include 

revisions or discontinuation of performance metrics, as well as changes to the performance 

indicator targets that were made during the strategic plan annual update. 

In FY 2023, FSA closed out the FY 2020–24 Strategic Plan and implemented the new FY 2023–

27 Strategic Plan. Performance metrics, now referred to as performance indicators that were 

continued to be tracked using the same methodology in the current Strategic Plan are listed in 

the Annual Performance Report. The performance metrics that are no longer tracked are listed 

below with the final results. 

Table 56: FY 2020-24 Strategic Plan Performance Metrics and Results

Performance Metrics FY 2022

Actual Result

1.2.A Identification, validation, assessment, and prioritization of skill 

competencies, required grades, and strategic alignment in accordance 

with the workforce requirements study results.

Maintained Met

1.2.B Conduct targeted multi-year training based on identified workforce 

needs. 82.0% Met

1.2.C Perform a training analysis at each performance review period within the 

fiscal period.

97.0% average 

course 

satisfaction 

assessment 

rating (SAR) 

per year

Met

2.1.A Number of visits (sessions) demonstrating adoption of the updated 

StudentAid.gov site. 304.8 million Met

2.1.B Percentage of high school seniors submitting the FAFSA. 63.0% Met

2.1.C Number of customers submitting the FAFSA via a mobile platform—the 

myStudentAid mobile app or fafsa.gov.

2.5 million 

submissions Not met

2.1.D Persistence among first-time filing aid recipients. 80.0% Not met

2.2.A Number of customers checking loan balances via the myStudentAid 

mobile app. 2.1 million Met

2.2.B Number of borrowers who view their aid summary information on 

StudentAid.gov. 22.6 million Met

2.2.C Number of users of “Aidan”, the StudentAid.gov virtual assistant. 1,623,550 Met

2.2.D Transactional email volume for outreach and communications to 

customers. 181.1 million Met

2.2.E Recurring campaign email delivery volume for outreach and 

communications to customers. 49.8 million Met
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Performance Metrics FY 2022

Actual Result

2.2.F American Customer Satisfaction Index (ACSI) Aid Lifecycle Survey 

score.

67.8 Not met

2.2.G Customer Satisfaction Survey(s) for StudentAid.gov site and associated 

tools. 3.6 Baseline

2.3.A Quality Standard for Average Speed to Answer (ASA) at all Call Centers. 334.0 seconds Not met

2.3.B Quality Standard for Abandon Rate (AR) for Incoming Calls at all Call 

Centers. 10.4% Not met

2.4.A Number of borrowers using Make a Payment feature to pay student 

loans.

16,782 

payments N/A

3.1.B Number of Borrower Defense (BD) applications adjudicated (subject to 

existing BD regulations). 86,000 Met

3.2.B FSA will enhance the self-service training resource and informational 

platform to improve communication with participating partners, including 

schools, third-party servicers, and financial institutions.

29.0% Met

3.2.C Ease of doing business with FSA. 76.0% Met

4.1 Increase partner/vendor cybersecurity effectiveness by reducing the total 

number of FSA system assessment findings by 20% per year. 19,252 Not met

4.2.A Increase Institutions of Higher Education cybersecurity effectiveness by 

reducing GLBA cybersecurity non-compliance by 20% per year. 94 Met

4.2.B Reduce incident reporting time at Institutions of Higher Education. 25.3 days Met

4.3 Decrease the number of employee-related cybersecurity events 

associated with inappropriate use, distribution, or storage of Personally 

Identifiable Information (PII) and financial information by 20% a year.

1,738 Not met

5.1.A Initiate monthly reporting to the public through the FSA Data Center. Target Not met Not met

5.1.B Outstanding Direct Loan Portfolio in Current Repayment Status. N/A N/A
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Performance Metrics FY 2022

Actual Result

5.2.A Using the Enterprise Risk Management (ERM) Maturity Model, move the 

organization towards a “Risk Intelligent” position. The model defines 

organizational progress in the following way: 

1 = Initial; 

2 = Fragmented; 

3 = Integrated; 

4 = Risk Intelligent.

3.0 Met

5.2.B Implementation timeline for FUTURE Act.

Implemented 

interface 

between IRS 

and FSA; 

development 

ongoing with 

building 5 new 

FSA systems 

that will 

receive, store, 

and manage 

FTI

Met

5.3.A Identify and provide intervention actions for customers at risk of default.

Executed 

default 

prevention 

program at full 

scale 

Met

5.3.B Default rate by borrower count. N/A N/A

5.3.C Percent of borrowers > 90 days delinquent. N/A N/A

5.3.D Percentage of borrowers who did not make the first three payments. N/A N/A

5.4 Conduct three vendor examinations annually. 3 Met
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Appendix B: Data Validation and Verification Matrix

Appendix B provides data validation and verification information for all performance indicators

included within the five Strategic Goals of the current FSA strategic plan.

Strategic Goal 1: Improve Customer Service and Outcomes for Students and Borrowers

Table 57: Performance Data Validation and Verification for Metric 1.1.A

Performance Indicator 1.1.A Number of borrowers that received loan forgiveness. 

Data Source Enterprise Data Warehouse Analytics (EDWA).

Data Validation and Verification

Measured by the total number of borrowers approved to receive loan 

forgiveness, which includes TPD, PSLF, and IDR adjustments.

Validation to be conducted via the FSA Data Request Team process 

with verification conducted by the PSLF program team. The indicator

leverages two reports that are used for several other purposes, 

including the public-facing FSA Data Center. The report methodology 

was validated through FSA’s Data Request Team in 2015. This 

experience helps facilitate spotting anomalies. FSA also continues to 

monitor overall performance of the federal loan servicers to identify any 

areas where reporting errors have occurred and notifies servicers of 

results and corrective actions as needed. By design, the data office is 

separated from the servicers' staff and systems, so there is currently no 

systematic way to verify servicer reporting. For this reason, the data 

directorate partners with the servicer monitoring team to investigate, 

identify and solution, if possible, any reporting issues identified. 

Table 58: Performance Data Validation and Verification for Metric 1.1.B

Performance Metric 1.1.B Percentage of borrowers using auto-debit. 

Data Source National Student Loan Data System (NSLDS)

Data Validation and Verification

Enrollment in auto debit is reported by federal loan servicers to the 

NSLDS. Accuracy of that data is validated by FSA using NSLDS 

monitoring techniques. NSLDS queries will provide the volume of 

borrowers enrolled in Automatic Direct Debit (auto debit) and the total 

volume of borrowers in repayment. The auto debit volume will be 

divided by the total borrowers in repayment volume and rounded to 

1/10th percent to calculate auto debit percentage.
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Table 59: Performance Data Validation and Verification for Metric 1.1.C 

Performance Metric 1.1.C

Percentage of users who start and complete the Public 

Service Loan Forgiveness (PSLF) Help Tool by generating a 

PSLF form.

Data Source COD Portal

Data Validation and Verification

The source of the data is on the COD Portal and provided by an FSA 

contract resource. The contractor assists with the monitoring of PSLF 

Help Tool usage and which form is generated based on customer 

interaction with the PSLF Help Tool.

Table 60: Performance Data Validation and Verification for Metric 1.2.A

Performance Metric 1.2.A Percentage of contractor interactions reviewed that 

received a passing score.

Data Source FSA Vendor Management/Vendor Oversight and Program 

Accountability (VOPA)

Data Validation and Verification

Measured by the percentage of contractor interactions reviewed that 

received a passing score. Validation and verification to be conducted 

by different FSA Customer Analytics Group members.

Table 61: Performance Data Validation and Verification for Metric 1.3.A

Performance Metric 1.3.A Surveys to third-party stakeholders.

Data Source Forthcoming survey 

Data Validation and Verification TBD

Table 62: Performance Data Validation and Verification for Indicator 1.4.A

Performance Indicator 1.4.A Timeliness of case handling

Data Source Salesforce (Feedback Dispute Management System (FDMS))

Data Validation and Verification

The data for this performance indicator is provided by the Ombudsman 

office and validated by the Office of Strategic Measures and Outcomes 

(SMO) Enterprise Performance Intelligence and Collaboration team.
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Table 63: Performance Data Validation and Verification for Indicator 1.4.B

Performance Indicator 1.4.B Accuracy of business process operations

Data Source Salesforce

Data Validation and Verification

The data for this performance indicator is provided by Salesforce and 

analyzed by the Ombudsman office. Data will be verified by the BPO 

team in accordance with applicable SLAs.

Table 64: Performance Data Validation and Verification for Indicator 1.4.C

Performance Indicator 1.4.C Accuracy of first-level complaint response

Data Source Responses uploaded into Salesforce

Data Validation and Verification

Quality reviews will be conducted by the Ombudsman office, in 

conjunction with the BPO team and Vendor Oversight Group. Data will 

be verified by the BPO team and Vendor Oversight in accordance with 

applicable SLA.

Strategic Goal 2: Advance Equity and Access to Student Financial Assistance 

Table 65: Performance Data Validation and Verification for Metric 2.1.A

Performance Metric 2.1.A Overall borrower satisfaction score for online counseling

Data Source Medallia

Data Validation and Verification

The data for this performance indicator is pulled from Medallia data 

portal using a standardized query. The Customer Analytics Group staff 

member pulls the data, and another Customer Analytics Groups staff 

member validates the data.
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Table 66: Performance Data Validation and Verification for Metric 2.2.A

Performance Metric 2.2.A Customer satisfaction survey score associated with 

completing the FAFSA. 

Data Source

Free Application for Federal Student Aid® customer satisfaction survey 

currently administered by FSA’s Customer Analytics Group and CFI 

Group (Independent Research Firm)

Data Validation and Verification

The data for this performance indicator is provided by the contractor 

and is verified by the Free Application for Federal Student Aid® product 

team.

Table 67: Performance Data Validation and Verification for Indicator 2.3.A

Performance Indicator 2.3.A StudentAid.gov Digital Satisfaction

Data Source Medallia

Data Validation and Verification

The data for this performance indicator is pulled from Medallia data 

portal using a standardized query. The Customer Analytics Group staff 

member pulls the data, and another Customer Analytics Groups staff 

member validates the data.

Table 68: Performance Data Validation and Verification for Indicator 2.3.B

Performance Indicator 2.3.B StudentAid.gov Post-transaction Satisfaction

Data Source Medallia

Data Validation and Verification

The data for this performance indicator is pulled from Medallia data 

portal using a standardized query. The Customer Analytics Group staff 

member pulls the data, and another Customer Analytics Groups staff 

member validates the data.

Table 69: Performance Data Validation and Verification for Indicator 2.3.C

Performance Indicator 2.3.C Contact Center Customer Satisfaction

Data Source Medallia

Data Validation and Verification

The data for this performance indicator is pulled from Medallia data 

portal using a standardized query. The Customer Analytics Group staff 

member pulls the data, and another Customer Analytics Groups staff 

member validates the data.
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Table 70: Performance Data Validation and Verification for Metric 2.3.D

Performance Metric 2.3.D Email Campaign helpfulness

Data Source Medallia

Data Validation and Verification

The data for this performance indicator is pulled from Medallia data 

portal using a standardized query. The Customer Analytics Group staff 

member pulls the data, and another Customer Analytics Groups staff 

member validates the data. 

Strategic Goal 3: Strengthen Engagement and Accountability for Educational and 

Financial Institutions

Table 71: Performance Data Validation and Verification for Metric 3.1.A

Performance Metric 3.1.A Review for participating partners that have been 

provisionally certified

Data Source Postsecondary Education Participants System and the Partner Connect 

system. 

Data Validation and Verification

Metric calculations are based on data extracts from the data system. 

The data extracts are subject to quality checks and validation. After 

data are compiled, a staff member reviews the queries and formulas to 

ensure proper functioning and correct counting reviews/schools. Since 

Office of Partner Participation and Oversight (PPO) may perform more 

than one compliance review of an institution during a fiscal year, the 

data are de-duplicated to ensure an institution is counted only once. 

The count of unduplicated institutions for whom Office of Partner 

Participation and Oversight (PPO) performed a compliance review is 

compared with an unduplicated count of participating institutions to 

calculate the actual percentage for this performance indicator. 

Table 72: Performance Data Validation and Verification for Metric 3.2.A

Performance Metric 3.2.A

Build and implement an FSA Enforcement Strategy that 

incorporates a risk model for identifying schools that pose 

risk to students and taxpayers

Data Source Internal Enforcement Strategic Plan

Data Validation and Verification The progress will be measured internally through the Enforcement 

Strategic Plan.
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Table 73: Performance Data Validation and Verification for Metric 3.3.A

Performance Metric 3.3.A institutional participation rates in Title IV training and 

specialized technical assistance programs

Data Source

FSA Training Center, Postsecondary Education Participation System, 

Salesforce, Federal Student Aid Training Center (FSATC) registration, 

and the FSA Data Center.

Data Validation and Verification

Office of Postsecondary Education Identification (OPEID) is selfreported by users of the Learning Management System. Reports run in 

the Learning Management System (fsatraining.ed.gov) identify 

individual users of the site. Technical assistance participation is 

determined through the Salesforce tool used by PTAG, MSURSD and 

Partner Engagement & Relationship Management Group (PERM). 

Escalated technical assistance requests are tracked manually through 

the Ask A Fed Mailbox. Federal Student Aid Training Conference 

registrant data is also received from the (Registration system) used 

across FSA.

The combined reports are exported to Excel and manipulated to 

remove users without an Office of Postsecondary Education 

Identification (OPEID) and duplicate Office of Postsecondary Education 

Identification (OPEID)s. All data is merged with the Learning 

Management System data to produce a list of Office of Postsecondary 

Education Identification (OPEID)s who have received training. The 

quality of the data is impacted because not all instances of technical 

assistance and support have been tracked historically by FSA. Data 

collection from multiple systems using differing demographic points 

(e.g., user reported school name variances, branch campus Office of 

Postsecondary Education Identification (OPEID) v Main Campus) and 

manual counts of user emails can affect the consistency of the 

information used for analysis.

Strategic Goal 4: Increase Workforce and Workplace Capabilities

Table 74: Performance Data Validation and Verification for Metric 4.1.A

Performance Metric 4.1.A Federal Employee Viewpoint Survey Diversity, Equity, 

Inclusion, and Accessibility (DEIA) Index

Data Source Federal Employee Viewpoint Survey New Inclusion Quotient Index

Data Validation and Verification

The data will come from Federal Employee Viewpoint Survey results 

conducted by U.S. Office of Personnel Management (OPM) since 2002. 

OPM maintains a 100 percent accuracy rate for employee security and 

data integrity.
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Table 75: Performance Data Validation and Verification for Metric 4.1.B

Performance Metric 4.1.B Percent of underrepresented workforce population from 

qualified candidates resulting in new hires and backfills.

Data Source Monster, Oracle Business Intelligence Enterprise Edition (OBIEE), and 

LinkedIn

Data Validation and Verification

Acquisition and development indicators will come from the Human 

Capital Group, specifically the Office of Strategy, Planning, and 

Transformation and the Operations Team. HCG will track data and 

provide educational awareness from a HCM/WFP perspective on how 

the targets may be addressed.

Table 76: Performance Data Validation and Verification for Metric 4.1.C

Performance Metric 4.1.C

Percentage of underrepresented populations denoted in 

organizational talent acquisition, promotion, and 

development/training activities.

Data Source Monster, Oracle Business Intelligence Enterprise Edition (OBIEE), and 

FedTalent

Data Validation and Verification

Acquisition and development indicators will come from the Human 

Capital Group, specifically the Office of Strategy, Planning, and 

Transformation, Workforce Development Division, Executive Services, 

and the Operations Team. HCG will track data and provide educational 

awareness from a HCM/WFP perspective on how the targets may be 

addressed.

Table 77: Performance Data Validation and Verification for Metric 4.1.D

Performance Metric 4.1.D Percentage of employees engaged annually in formal 

Diversity, Equity, Inclusion, and Accessibility efforts.

Data Source FSA First Class 1 (mailbox) and attendance number captured via 

Microsoft Teams or roster

Data Validation and Verification

Diversity, Equity, Inclusion, and Accessibility participation results will 

come from Organization Development and Executive Services Group 

(counting unique participants)
232 Fiscal Year 2023 Annual Report | Federal Student Aid

Other Information

(Unaudited)

Table 78: Performance Data Validation and Verification for Indicator 4.2.A

Performance Indicator 4.2.A Federal Employee Viewpoint Survey: Intrinsic Work 

Experience 

Data Source Federal Employee Viewpoint Survey Employee Engagement Index, 

Workforce Transformation Tracking System (WTTS) and F (FPPS)

Data Validation and Verification

The data for the Workforce planning Maturity Model and U.S. Office of 

Personnel Management (OPM) Annual Time to Hire Metrics will come 

from the Human Capital Group, specifically the Office of Strategy, 

Planning, and Transformation and the Operations Team.

Table 79: Performance Data Validation and Verification for Indicator 4.3.A

Performance Indicator 4.3.A Federal Employee Viewpoint Survey: Employee 

Engagement Index

Data Source Federal Employee Viewpoint Survey Employee Engagement Index

Data Validation and Verification

The data will come from Federal Employee Viewpoint Survey results 

conducted by U.S. Office of Personnel Management (OPM) since 

2002.OPM maintains a 100 percent accuracy rate for employee security 

and data integrity.

Table 80: Performance Data Validation and Verification for Indicator 4.3.B

Performance Indicator 4.3.B Federal Employee Viewpoint Survey: Leaders Lead

Data Source The average of questions for communications from the FEVS OPM 

survey. 

Data Validation and Verification

The data will come from Federal Employee Viewpoint Survey results 

conducted by U.S. Office of Personnel Management (OPM) since 2002. 

OPM maintains a 100 percent accuracy rate for employee security and 

data integrity. 

The validation of data should be a second entity to review the FEVS 

source for the questions relating to communications and averaging the 

scores. 
Fiscal Year 2023 Annual Report | Federal Student Aid 233

Other Information

(Unaudited)

Table 81: Performance Data Validation and Verification for Indicator 4.3.C

Performance Indicator 4.3.C Federal Employee Viewpoint Survey: Supervisors

Data Source Federal Employee Viewpoint Survey Employee Engagement Index 

score and subfactor score for Supervisors.

Data Validation and Verification

The data will come from Federal Employee Viewpoint Survey results 

conducted by U.S. Office of Personnel Management (OPM) since 

2002.OPM maintains a 100 percent accuracy rate for employee security 

and data integrity.

Strategic Goal 5: Enhance the Management and Transparency of the Portfolio

Table 82: Performance Data Validation and Verification for Metric 5.1.A

Performance Metric 5.1.A The Sum of Annual Data Maturity Assessment (DMA) for 

DMA Processing Areas.

Data Source Annual Data Maturity Assessment

Data Validation and Verification

The data for this performance indicator is provided by an FSA selfassessment which is reviewed, modified, and certified by the US 

Department of Education Office of the Chief Data Officer (OCDO).

Table 83: Performance Data Validation and Verification for Indicator 5.1.B

Performance Indicator 5.1.B Successful maintenance and use of statistical models in 

Title IV operations 

Data Source Enterprise Data Warehouse and Analytics (EDWA)

Data Validation and Verification The data for this performance indicator is provided by the Statistical 

Research and Modeling Office in FSA’s Enterprise Data Office.

Table 84: Performance Data Validation and Verification for Indicator 5.1.C

Performance Indicator 5.1.C Implement new statistical modeling initiatives 

Data Source Enterprise Data Warehouse and Analytics (EDWA)

Data Validation and Verification The data for this performance indicator is provided by the Statistical 

Research and Modeling Office in FSA’s Enterprise Data Office.
234 Fiscal Year 2023 Annual Report | Federal Student Aid

Other Information

(Unaudited)

Table 85: Performance Data Validation and Verification for Metric 5.2.A

Performance Metric 5.2.A Operational performance. 

Data Source

From Finance for FSA Spend Plan: IAC scoring workbook, IAC 

communications, IAC meeting minutes, IAC/IRB/LC presentation 

materials, COO decision memoranda. 

From SMO Project Management or Project Investment Owners for 

Portfolio Performance - TBD 

Data Validation and Verification

Measured by the results of the Investment Advisory Committee (IAC) 

FY 2022 Investment prioritization exercise to finalize an FSA spend 

plan. IAC members independently reviewed more than 200 project 

initiatives (known as Budget Initiative Requests) across the FSA 

enterprise and ranked using a scoring methodology based on 4 key 

organizational drivers. The FY 2022 ranking was used as a baseline to 

align the FY 2023 Investment portfolio to 3 potential funding scenarios 

(straight-line, and with 2 funding increases) to have a final 

recommendation on budgetary items in preparation for an enacted 

FY 2023 appropriation. New FY 2023 project initiatives were evaluated 

and scored using the established methodology and factored into the 

overall Investment portfolio ranking. The final FY 2023 Investment 

portfolio was approved in March 2023 to align with the FY23 enacted 

appropriation. Validation and verification can be confirmed through the 

various FY 2023 portfolio prioritization process artifacts. Performance of 

the Investment portfolio to reach FY 2023 target measured by: TBD

Table 86: Performance Data Validation and Verification for Metric 5.3.A 

Performance Metric 5.3.A Prepare time-duration estimates for procurement-related 

tasks for use in Program Schedules.

Data Source FSA Acquisitions Directorate

Data Validation and Verification Federal Procurement Data System – Next Generation (FPDS-NG)

Table 87: Performance Data Validation and Verification for Metric 5.3.B

Performance Metric 5.3.B

Plan, develop and implement a new investment 

management process aligning acquisitions, budget, and 

human capital with program planning

Data Source FSA’s Acquisitions Directorate, Finance Directorate, and other 

Business Units

Data Validation and Verification Strategic Measures and Outcomes (Enterprise Program Management 

Office)
Fiscal Year 2023 Annual Report | Federal Student Aid 235

Other Information

(Unaudited)

Table 88: Performance Data Validation and Verification for Metric 5.4.A

Performance Metric 5.4.A Cybersecurity Maturity-Level (OIG Maturity Levels)

Data Source Yearly Inspector General FISMA Reporting Metrics and Quarterly SelfAssessments 

Data Validation and Verification Comparison of Current Yearly Inspector General FISMA Reporting 

Metrics with prior year and the results of the self-assessments. 
236 Fiscal Year 2023 Annual Report | Federal Student Aid

Other Information

(Unaudited)

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Fiscal Year 2023 Annual Report | Federal Student Aid 237

Appendices

(Unaudited)

Appendix C: Glossary of Acronyms and Terms

Acronym Description 

A

AAASG Administrative Actions and Appeals Service Group

AAG Advanced Analysis Group

ABCP Conduit Asset-Backed Commercial Paper Conduit

ACERS Analytics, Compliance, Evaluation, and Remediation System

ACICS Accrediting Council for Independent Colleges and Schools

ACS American Community Survey

ACSI American Customer Satisfaction Index

AFR U.S. Department of Education FY 2023 Agency Financial Report

Annual Report Federal Student Aid Fiscal Year (FY) 2023 Annual Report

APG Agency Priority Goal

AR Abandon Rate

ASA Average Speed to Answer

ASLA Annual Student Loan Acknowledgment

ATO Authorities to Operate

B

Baseline Performance result is baselined. Baseline data will provide a 

historical point of reference to inform program planning such as 

target setting

BD Borrower Defense 

BDG Borrower Defense Group

Borrower Defense Borrower Defense to Repayment

BPO Business Process Operations

C

CAP Corrective Action Plan

CARES Act Coronavirus Aid, Relief, and Economic Security Act

CDR Cohort Default Rate

Clery Act Jeanne Clery Disclosure of Campus Security Policy and Campus 

Crime Statistics Act
238 Fiscal Year 2023 Annual Report | Federal Student Aid

Appendices

(Unaudited)

Acronym Description 

COD Common Origination and Disbursement

Congress U.S. Congress

COO Chief Operating Officer

COVID-19 Coronavirus Disease 2019

CR Change Request

CRI Common Review Initiative

CSRS Civil Service Retirement System

D

DCC Digital Customer Care

D2D Direct to Discharge

DEIA Diversity, Equity, Inclusion, and Accessibility

the Department U.S. Department of Education

DFSCA Drug-Free Schools and Communities Act Amendments of 1989

Direct Loan William D. Ford Federal Direct Loan

DMA Data Maturity Assessment

DMCS Debt Management and Collection System

DNP Do Not Pay

DOL U.S. Department of Labor

E

ECASLA Ensuring Continued Access to Student Loans Act of 2008

EDMAPS Enterprise Data Management Analytics Platform Services

EDWA Enterprise Data Warehouse and Analytics

EEI Employee Engagement Index

Enforcement Enforcement Office

e-signature Electronic signature

Executive Order 13607 Executive Order 13607, Establishing Principles of Excellence for 

Educational Institutions Serving Service Members, Veterans, 

Spouses, and Other Family Members 

Executive Order 14028 Executive Order 14028, Improving the Nation’s Cybersecurity 

Executive Order 14035 Executive Order 14035, Diversity, Equity, Inclusion, and 

Accessibility in the Federal Workforce
Fiscal Year 2023 Annual Report | Federal Student Aid 239

Appendices

(Unaudited)

Acronym Description 

F

FAFSA® Free Application for Federal Student Aid®

FAFSA Simplification 

Act 

Free Application for Federal Student Aid (FAFSA) Simplification Act

FASAB Financial Accounting Standards Advisory Board

FCRA Federal Credit Reform Act of 1990

FDMS Feedback and Dispute Management System

FECA Federal Employees’ Compensation Act

Federal Fund Federal Student Loan Reserve Fund

FERS Federal Employees Retirement System

FEVS Federal Employee Viewpoint Survey

FFEL Federal Family Education Loan 

FIOS Financial Institution Oversight Service 

FISMA Federal Information Security Modernization Act of 2014

FMS Financial Management System

FPS Federal Processing System

FSA Federal Student Aid

FSATC Federal Student Aid Training Conference

FSEOG Federal Supplemental Educational Opportunity Grant

FTI Federal Tax Information

FUTURE Act Fostering Undergraduate Talent by Unlocking Resources for 

Education Act

FY Fiscal Year

FY 2022–26 Strategic 

Plan 

Department of Education Strategic Plan for Fiscal Year 2022–26

FY 2020–24 Strategic 

Plan 

Federal Student Aid: Strategic Plan Fiscal Years 2020–24 

FY 2023–27 Strategic 

Plan 

Federal Student Aid Five-Year Strategic Plan for Fiscal Years 

2023–27 

G

GA Guaranty Agency

GAAP Generally Accepted Accounting Principles

GAO Government Accountability Office
240 Fiscal Year 2023 Annual Report | Federal Student Aid

Appendices

(Unaudited)

Acronym Description 

GLBA Gramm-Leach-Bliley Act

GPRA Modernization 

Act 

Government Performance and Results Modernization Act of 2010

H

HBCU Historically Black College or University

HCEI Human Capital and Employee Initiatives Team

HCERA Health Care and Education Reconciliation Act of 2010

HCG Human Capital Group

HCM Human Capital Management

HEA Higher Education Act of 1965, as amended

HEAL Health Education Assistance Loan

HOPS Heal Online Processing System

HR Human Resources

I

IDR Income Driven Repayment

IHE Institution of Higher Education

Investigations Investigations Group

IP Internet Protocol

IRS Internal Revenue Service

IT Information Technology

L

LIBOR London Inter-Bank Offered Rate

M

MCP Marketing Communications Platform

Met Performance result met or exceeded target

MSI Minority-Serving Institution

MSURSD Minority-Serving Under-Resourced Schools Division

N

NASFAA National Association of Student Financial Aid Administrators

N/A Performance result is not applicable because the performance 

indicator was not developed, the performance indicator was not 
Fiscal Year 2023 Annual Report | Federal Student Aid 241

Appendices

(Unaudited)

Acronym Description 

implemented, or the required data were not available in time for 

inclusion.

Next Gen FSA Next Gen Federal Student Aid 

NFP Not-For-Profit 

Not met Performance result did not meet target

NSLDS® National Student Loan Data System

O

OIG Office of Inspector General

OMB U.S. Office of Management and Budget

OMB Circular A-11 OMB Circular A-11, Preparation, Submission and Execution of the 

Budget, Part 6, Section 260

OMB Circular A-123 OMB Circular A-123, Management’s Responsibility for Enterprise 

Risk Management and Internal Control

OMB Circular A-123, 

Appendix A

OMB Circular A-123, Appendix A, Management of Reporting and 

Data Integrity Risk

OMB Circular A-136 OMB Circular A-136, Financial Reporting Requirements

OPEID Office of Postsecondary Education Identification

OPM U.S. Office of Personnel Management

P

Partner Connect FSA Partner Connect

PMSS Partner Management and Support Services

PBO Performance-Based Organization

PCA Private Collection Agency

PCI Performance Confidence Index

PULSE Power Users Learning Series for Employees

Pell Grant Federal Pell Grant Program

PEOSD Partner Eligibility and Oversight Services Directorate

PEPS Postsecondary Education Participants System

PII Personally Identifiable Information

PLUS Parent Loan for Undergraduate Students

PMG Performance Management Group

PMSS Partner Management and Support Services
242 Fiscal Year 2023 Annual Report | Federal Student Aid

Appendices

(Unaudited)

Acronym Description 

PPO Office of Partner Participation and Oversight

President’s Budget Budget of the United States Government

PS Project Success

PTAG Partner Technical Assistance Group

Pub. L Public Law

PSLF Public Service Loan Forgiveness

Q

QM Quality Management

S

SABER Student Aid and Borrower Eligibility Reform

SAR Student Aid Report

SAVE Saving on A Valuable Education

SBR Statement of Budgetary Resources

SEAD Office of Student Experience and Aid Delivery

Secretary Secretary of Education

SecOps Security Operations

SEG Stakeholder Engagement Group

SEOSG School Eligibility and Oversight Service Group

SES Senior Executive Service

SLA Service Level Agreement

SMA Special Mandatory Assignment

SMS Short Message Service

SOC Security Operations Center

SOFR Secured Oversight Financing Rate

SPPR Strategic Planning Performance Review

STOP Act Stop Student Debt Relief Scams Act of 2019

Sweet Settlement Sweet v. Cardona Settlement

T

TCU Tribal Colleges and Universities

TEACH Grant Teacher Education Assistance for College and Higher Education 

Grant
Fiscal Year 2023 Annual Report | Federal Student Aid 243

Appendices

(Unaudited)

Acronym Description 

TEDI Targeted Early Delinquency Intervention

TEPSLF Temporarily Expanded Public Service Loan Forgiveness

TISG Training and Information Services Group

Title IV Title IV of the Higher Education Act of 1965, as amended

TIVAS Title IV Additional Servicers

TIVOD Title IV Origination & Disbursement 

TPD Total and Permanent Disability

TPDR Third Party Debt Relief

Treasury U.S. Department of the Treasury

TROR Treasury Report on Receivables

U

U.S. United States

USDS Unified Servicing and Data Solution

V

VAWA The Violence Against Women Act

VAWA 2022 VAWA Reauthorization Act of 2022

VOG Vendor Oversight Group
244 Fiscal Year 2023 Annual Report | Federal Student Aid

Appendices

(Unaudited)

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Fiscal Year 2023 Annual Report | Federal Student Aid 245

Appendices

(Unaudited)

Appendix D: Availability of the FSA Report

The Federal Student Aid Fiscal Year 2023 Annual Report and the Annual Reports from prior

years are available on the following websites:

• FSA: StudentAid.gov

• The Department: ed.gov/about/reports

The Federal Student Aid: Strategic Plan, Fiscal Years 2023–27 and prior years’ strategic plans 

are also available at StudentAid.gov.

Stay connected to Federal Student Aid through social media: 

• Visit the FSA website: StudentAid.gov

• Like FSA on Facebook: Facebook.com/federalstudentaid

• Follow FSA on X: @FAFSA

• Follow FSA on Instagram: instagram.com/federalstudentaid

• Follow FSA on LinkedIn: linkedin.com/company/federal-student-aid

• Find FSA on YouTube: YouTube.com/user/federalstudentaid
246 Fiscal Year 2023 Annual Report | Federal Student Aid

Acknowledgments

The FSA FY 2023 Annual Report was prepared with the energies and talents of many Federal 

Student Aid employees. To these dedicated individuals, the Chief Operating Officer and Chief 

Financial Officer would like to offer their sincere appreciation and recognition.

In particular, we would like to recognize the following Federal Student Aid offices for their 

contributions:

• Finance Directorate. 

• Strategic Planning and Reporting Directorate. 

• Office of the Ombudsman. 

• Office of Strategic Communications. 

• COO Front Office. 

We also offer our sincerest thanks and acknowledgement to the staff of the following other 

offices within the Department of Education for their contributions: 

• Office of Finance and Operations. 

• Budget Service. 

• Office of the Secretary. 

• Office of Legislation and Congressional Affairs. 

• Office of Chief Information Officer. 

We would also like to acknowledge the Office of Inspector General and KPMG LLP for the 

professional manner in which they conducted the audit of the FY 2023 Financial Statements. 

The Federal Student Aid FY 2023 Annual Report

Federal Student Aid

A Principal Office of the U.S. Department of Education

Finance Directorate

November 2023