FY 2022 Annual Report
United States Department of Education

Miguel A. Cardona, Ed.D. 

Secretary

Federal Student Aid

Richard Cordray

Chief Operating Officer

Finance Directorate

Richard Lucas

Chief Financial Officer

January 23, 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 2022

Annual Report, Washington, D.C., 2022.

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 Twitter at @FAFSA. 

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

public accessibility of the 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 2022 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 2022 Organizational Highlights........................................................... 4

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

Federal Student Aid by the Numbers............................................................................................... 7

Mission and Organizational Structure ................................................................... 9

Mission ............................................................................................................................................. 9

Organizational Structure ................................................................................................................ 10

Mission, Vision, and Core Values .................................................................................................. 11

Federal Student Financial Aid Programs ....................................................................................... 14

Performance Management.................................................................................... 19

Performance Management Processes at Federal Student Aid...................................................... 21

Agency Priority Goals..................................................................................................................... 25

Quality of Performance Data.......................................................................................................... 26

Analysis of Financial Statements......................................................................... 27

Introduction .................................................................................................................................... 27

Balance Sheet................................................................................................................................ 29

Statement of Net Cost.................................................................................................................... 44

Statement of Changes in Net Position........................................................................................... 45

Statement of Budgetary Resources ............................................................................................... 45

Financial Management Highlights.................................................................................................. 46

Analysis of Systems, Controls, and Legal Compliance ..................................... 47

Annual Performance Report (Unaudited) .........................49

Overview of the Annual Performance Report...................................................... 50

Introduction to the Annual Performance Report................................................. 51

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

Understanding the Performance Section....................................................................................... 57

Strategic Goal 1: Empower a High-Performing Organization ........................................................ 58

Strategic Goal 2: Provide World-Class Customer Experience to the Students, Parents, and 

Borrowers We Serve...................................................................................................................... 69

Strategic Goal 3: Increase Partner Engagement and Oversight Effectiveness ............................. 88

Strategic Goal 4: Strengthen Data Protection and Cybersecurity Safeguards .............................. 96

Strategic Goal 5: Enhance the Management and Transparency of the Portfolio ........................ 106

Fiscal Year 2022 Accomplishments of Federal Student Aid............................ 122
ii Fiscal Year 2022 Annual Report | Federal Student Aid

Contents 

Additional Reporting Requirements (Unaudited) ...........133

Overview of Additional Reporting Requirements ............................................. 135

Legislative and Regulatory Recommendations ................................................ 136

Annual Bonus Awards......................................................................................... 137

Report of the Federal Student Aid Ombudsman............................................... 138

Introduction .................................................................................................................................. 138

Overview of All Cases Received in Fiscal Year 2022.................................................................. 138

Activities of the Ombudsman ....................................................................................................... 147

Ombudsman Discussion .............................................................................................................. 149

Financial Section (Fiscal Year 2022 Unaudited) .............157

Overview of the Financial Section...................................................................... 159

Financial Statements........................................................................................... 160

Consolidated Balance Sheets...................................................................................................... 161

Consolidated Statements of Net Cost.......................................................................................... 162

Consolidated Statements of Changes in Net Position ................................................................. 163

Combined Statements of Budgetary Resources.......................................................................... 164

Notes to the Financial Statements ..................................................................... 166

Required Supplementary Information (Unaudited)........................................... 207

Independent Auditors’ Report ............................................................................ 214

Office of Inspector General Audit Transmittal.............................................................................. 214

Independent Auditors’ Report ...................................................................................................... 216

Other Information (Unaudited)......................................231

Other Information................................................................................................. 233

Summary of Financial Statement Audit and Management Assurances ...................................... 233

Management Challenges ............................................................................................................. 233

Payment Integrity ......................................................................................................................... 233

Appendices (Unaudited) ................................................235

Appendix A: Performance Metrics and Target Changes .................................. 237

Appendix B: Data Validation and Verification Matrix........................................ 239

Appendix C: Glossary of Acronyms and Terms................................................ 255

Appendix D: Availability of the FSA Report....................................................... 262
Fiscal Year 2022 Annual Report | Federal Student Aid iii

Introduction 

Introduction (Unaudited)
iv Fiscal Year 2022 Annual Report | Federal Student Aid

Introduction 

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Fiscal Year 2022 Annual Report | Federal Student Aid v

Introduction 

Letter from the Chief Operating Officer of Federal 

Student Aid

Dear Federal Student Aid Community: 

Once again, it is my honor to present the Federal Student 

Aid Fiscal Year (FY) 2022 Annual Report that highlights the 

work of Federal Student Aid (FSA). As part of the U.S. 

Department of Education, we strive to enable the American 

dream for millions of people seeking education and training 

beyond high school. This report spotlights our efforts to 

improve customer service, encourage collaboration among 

stakeholders, drive operational efficiency, and invest in our 

workforce capability.

The Higher Education Act of 1965 empowers the 

Department to provide broad access to higher education. 

Our mission statement at FSA, “Funding America’s Future, 

One Student at a Time,” expresses 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. When I joined 

the great team at FSA in May of 2021, I found them already 

deeply engaged in this important work, and the pace has not slackened since.

In the face of the COVID-19 pandemic, FSA developed and implemented new ways of doing 

business that have yielded efficiencies across physical distance. Throughout FY 2022, FSA 

maintained high productivity by shifting considerable resources and assistance online to serve 

students, families, and schools more effectively. This year, we provided about $111.6 billion in 

federal grants, loans, and work-study funds to more than 9.8 million students at approximately 

5,500 participating postsecondary schools. FSA turned challenges into opportunities, as our 

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

While expanding access to higher education is central to our mission, we also monitor the size 

and complexities of the federal student loan portfolio, which now surpasses $1.6 trillion. This 

debt weighs heavily on millions of people, which obliges us to strengthen our stewardship of our 

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

shapes people’s pathways forward, and our decisions matter greatly to our country’s future.

FSA has collaborated with its student loan servicers to maintain the payment pause on most 

federal student loans for more than two years. We are making sure borrowers have the 

information and resources they need to help them return to repayment. And millions of those 

borrowers who left school during this period will begin repaying their loans for the first time ever. 

They expect and deserve the quality customer service that we aim to provide.

Richard Cordray

Chief Operating Officer
vi Fiscal Year 2022 Annual Report | Federal Student Aid

Introduction 

Right now, FSA is poised to deliver historic student loan debt relief to millions of individuals and 

their families. In August 2022, the Department announced the one-time program, which would 

provide up to $20,000 in relief for low- and middle-income Americans most likely to struggle 

repaying their student loans. Targeted student debt relief addresses the financial harms of the 

pandemic, helps smooth borrowers’ transition back to repayment, and helps borrowers at 

highest risk of delinquencies or default once payments resume. In just two months, ED 

delivered on that promise by launching a simple online application; and in the first few weeks, 

around 26 million people successfully applied, with the process typically taking no more than 5 

minutes from start to finish. In a survey, 97% of those who applied described their experience as 

positive. We are confident that our program is legal and have asked the Supreme Court to allow 

us to move forward with providing debt relief to tens of millions of eligible Americans.

Our support for borrowers reentering repayment also includes those with previously defaulted 

loans. Through the Fresh Start initiative announced in April, FSA restored eligibility for federal 

student aid to more than 7 million borrowers to help them complete their credential or degree. 

We recognize that borrowers who do not complete their program of study are at a higher risk of 

default. The Fresh Start initiative also will eliminate the negative effects of default for borrowers, 

improve their credit status to position them for long-term repayment success, and allow access 

to affordable income-driven repayment plans that facilitate student loan forgiveness. 

FSA has continued to improve customer service with an enhanced user experience, proactive 

partner engagement, and streamlined organizational capabilities. We have also made progress 

on our pledge to fix longstanding flaws in loan forgiveness programs. We have especially 

worked hard to streamline and deliver the loan discharges that borrowers deserve through 

programs such as Total and Permanent Disability and Borrower Defense to Repayment.

We greatly improved the Public Service Loan Forgiveness (PSLF) Program by the terms of the 

limited waiver, which ended on October 31, 2022. It has allowed borrowers to get credit for past 

periods of repayment that would otherwise not qualify under the normal program rules. The 

number of people whom FSA has identified for total forgiveness under the PSLF Program has 

grown dramatically, from only 7,000 in January 2021 to nearly 360,000 borrowers in November 

2022—with more on the way—through the limited PSLF waiver, as more than $24 billion in 

loans have been forgiven. 

We have been moved by borrowers’ stories shared through social media about the life-changing 

effects of student loan forgiveness. Public servants of all kinds – teachers, police officers, social 

workers, firefighters, and other government and non-profit employees – have benefited as the 

program finally began living up to its intended promise. In the coming year, we will take further 

actions to bring borrowers closer to forgiveness on their income-driven repayment plans by 

addressing historical failures in the administration of those plans.

In FY 2022, we homed in on greater accountability within the federal student aid programs. 

Schools that engage in misconduct are being held responsible for their abuses as we rebuild

FSA’s Enforcement Office to strengthen our oversight work and prevent risks to students and 

taxpayers. We are ramping up our program reviews also with stiffer tools to hold schools 

accountable for deceiving and failing students. We also have strengthened our relationships 

with state and federal partners – such as the Federal Trade Commission, Consumer Financial 

Protection Bureau, Department of Veterans Affairs, state attorneys general, and state student 

loan ombuds officers – to identify and take action against schools when they do not put their

students’ interests first.
Fiscal Year 2022 Annual Report | Federal Student Aid vii

Introduction 

By extending Project Success for another three years, FSA will continue to focus on improving 

student retention, graduation, and cohort default rates at 213 Historically Black Colleges and 

Universities (HBCUs), Tribal Colleges and Universities (TCUs), and minority-serving institutions 

(MSIs). FSA does this work in partnership with guaranty agencies at no additional charge to the 

participating schools. The program provides resources to help students boost their financial 

literacy and achieve their higher education goals. Project Success also provides crucial and 

timely help to many students that smooths their path to college completion. In addition, FSA 

devotes many hours even beyond Project Success to provide vigorous regulatory training and 

technical assistance to minority-serving institutions so they can better fulfill their obligations and 

responsibilities under the Federal Student Aid programs. 

And, as always, we have launched a new Free Application for Federal Student Aid® that will 

enable many students to access higher education they otherwise could not afford. The recently 

published Federal Student Aid Strategic Plan for Fiscal Years 2023–27 offers a road map for 

improving our programs, products, services, and operations. We have much to do, and the way 

ahead is clear. We invite you to read this report to know more about the steps we are taking to 

move into the future.

Sincerely,

Richard Cordray

Chief Operating Officer

Federal Student Aid

United States Department of Education

January 23, 2023
viii Fiscal Year 2022 Annual Report | Federal Student Aid

Introduction 

About This Report

FSA, a principal office of the U.S. Department of Education, 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 2022 Annual Report (Annual Report) is a comprehensive document 

that provides an analysis of FSA’s financial and program performance results for FY 2022 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 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 2022 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 2022 Annual Report | Federal Student Aid ix

Introduction 

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, 

performance management details, 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: Strategic Plan, Fiscal Years 2020–24 (FY 2020–24 

Strategic Plan), its strategic objectives, performance metric 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 financial statements and accompanying notes, 

required supplementary information, and the Independent Auditors’ 

Report. 

Other Information 

This section includes 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 2020–

24 Strategic Plan, the data validation and verification of performance 

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

the Annual Report. 
x Fiscal Year 2022 Annual Report | Federal Student Aid

Introduction 

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Fiscal Year 2022 Annual Report | Federal Student Aid 1

Management’s Discussion and Analysis 

Management’s Discussion and Analysis

(Unaudited)
2 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

 

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Fiscal Year 2022 Annual Report | Federal Student Aid 3

Management’s Discussion and Analysis 

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 2022 Organizational Highlights: Fiscal Year 2022 Organizational 

Highlights presents 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 2020–24 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 a discussion 

of 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 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

Fiscal Year 2022 Organizational Highlights

Looking Forward at Federal Student Aid

In FY 2022, FSA adapted to major shifts in administrative priorities while simultaneously 

managing the impact of the national COVID-19 emergency on the programs authorized by Title 

IV of the Higher Education Act of 1965, as amended (Title IV). In response to the 

unprecedented emerging issues, FSA advanced its capabilities to meet the needs of an 

evolving digital environment to improve the future of loan servicing. FSA also established a 

comprehensive return to repayment plan that includes borrower communications, programs to 

reduce delinquency, and increased vendor accountability. In FY 2023, the new Federal Student 

Aid FY 2023-27 Strategic Plan will provide a roadmap to improve access for borrowers and 

provide information they will need to manage their loans, make decisions about repayment 

plans, and participate in loan forgiveness programs. For institutions of higher education, FSA 

will continue to enforce compliance with Title IV program guidelines and protection from 

fraudulent and deceptive practices in the student aid marketplace. 

FY 2023 is guided by the most important aspect of FSA’s mission—the student. FSA is 

determined to raise the standard for excellent customer service by modernizing the loan 

servicing infrastructure, enhancing borrower repayment outcomes, implementing incentives to 

reduce loan defaults, and keeping the promise to improve opportunities for students and 

families to make informed decisions on financial aid for college and student loan repayment. 

In August 2022, the President and the Department announced a plan to help federal student 

loan borrowers transition back to regular payment. This proposed plan will include up to $20,000 

in debt cancellation for existing borrowers who meet certain criteria. Given these unprecedented 

circumstances, return to repayment will be a huge undertaking for FSA. FSA has initiated 

communication campaigns to inform borrowers about the process to restart payments, provide 

resources and incentives to minimize risk of default and delinquency, and educate the borrower 

on repayment options. FSA’s loan servicing partners are integral to the success of the future 

return to repayment plan, but the world of servicing federal student loans is changing rapidly. 

Collaboration with the servicers in the development of detailed outreach strategies will support a 

successful end of the administrative forbearance period.

FSA has also bolstered the complaint management system. The result of these upgrades will be 

increased quality control, more in-depth analysis of customer issues, and the ability to share this 

information with Institutions of Higher Education (IHEs) and vendors. 

FY 2023 continues to bring enhanced loan servicing due to consolidated, integrated, and 

improved customer interaction channels across the student aid lifecycle. FSA will focus on 

continuous improvement of loan servicing which includes expansion of major features and 

services on StudentAid.gov, delivery of critical customer outreach campaigns, and data-driven 

improvements to Business Process Operations (BPO). Leveraging customer feedback can 

improve digital interactions with them across the student aid lifecycle, such as content updates 

or user experience improvements, that can directly address customer pain points. FSA will 

continue to use “Voice of the Customer” feedback sessions and newly implemented surveys to 

measure their satisfaction with the interaction channels.
Fiscal Year 2022 Annual Report | Federal Student Aid 5

Management’s Discussion and Analysis 

FSA’s customer-centric approach will extend initiatives in FY 2023 and beyond. FSA procured a 

new customer feedback management tool and deployed numerous surveys across the digital 

contact center and communications channels beginning in the first quarter of FY 2022. FSA 

teams will have the ability to review open-ended feedback, including survey comments, social 

media mentions, and complaints to identify trends and insights. The organization will use the 

advanced analytics and customer trends to better understand the customer’s experiences and 

interactions with FSA throughout the student loan repayment lifecycle. FSA fully understands 

the necessity for a customer experience that minimizes errors and negative impacts. 

FSA’s responsibility for both collaboration and oversight is not limited to loan servicing partners, 

as it engages IHEs and other financial aid stakeholders on behalf of students, parents, and 

borrowers. In FY 2023, FSA will continue to build its capabilities to strengthen engagement and 

accountability by providing a single point of digital interaction for all participating educational and 

financial institutions. This enhanced capability will allow FSA to improve its relationships with 

participating institutions through targeted and proactive engagement, simplified customer 

service, and increased visibility into financial health using data analytics. 

In FY 2022, FSA established an Office of Enforcement within FSA that will report directly to the 

chief operating officer. It will strengthen the oversight and enforcement actions against schools 

that participate in the federal student loan, grant, and work-study programs. Strengthening 

institutional oversight is aligned with FSA’s commitment to protect borrowers and their families 

from fraudulent and deceptive student aid lending practices. 

Throughout FY 2023, FSA will continue comprehensive compliance reviews, review borrower 

complaints and other risk indicators to identify programs that pose risk to borrowers and 

taxpayers, conduct investigations, and pursue enforcement actions where appropriate. FSA will 

engage with schools to inform, collaborate, and ensure these institutions take the necessary 

actions needed to protect Title IV data. 

The Student Aid & Borrower Eligibility Reengineering (SABER) initiative is the coordinated effort 

to consolidate and align the implementation of two important pieces of legislation: the Fostering 

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

Application for Federal Student Aid (FAFSA®) Simplification Act. The implementation of both the 

FUTURE and FAFSA Simplification Acts will dramatically change the way students and families 

engage with FSA’s financial aid programs. As FSA assists customers in transitioning back into a 

positive repayment posture at the close of the administrative forbearance period, it will be 

imperative that the provisions associated with these Acts become fully implemented. Through 

these efforts loan servicing will be further enhanced as customers experience a highly secure 

system which allows them to automatically share their federal tax information (FTI) in a direct and 

more efficient way. 

As FSA continues to evolve as a more customer-centric and outcome-based organization, it will 

continue to focus on operational and process improvement. Implementation of the new strategic 

plan will require robust internal operations. FSA’s success impinges on attracting, developing, 

and retaining a skilled, agile workforce underpinned by diversity, equity, inclusion, and 

accessibility (DEIA). All of this will be accomplished through a comprehensive human capital 

framework and an organizational training and development plan. FSA will also improve the 
6 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

hiring processes to better recruit needed talent, strategically align skills to organizational 

mission requirements, and analyze human capital systems and processes. FSA will continue to 

strive to be a model for federal management best practices and quality customer service. 
Fiscal Year 2022 Annual Report | Federal Student Aid 7

Management’s Discussion and Analysis 

Federal Student Aid by the Numbers 

Figure 1: FSA Net Outlays1

FY 2018–22

Figure 2: FSA Administrative Budget

FY 2018–22

Figure 3: FSA Student Loan Portfolio2

FY 2018–22

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.

$18.6 $57.3 $147.3 $164.2 

$511.2 

$83.1 $40.1 $(43.0) $(38.7) $(382.4)

2018 2019 2020 2021 2022

Dollars in Billions

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

$1.7 $1.7 

$1.8 

$1.9 $1.9 

2018 2019 2020 2021 2022

Dollars in Billions

$1,439 

$1,510 

$1,566 

$1,611 $1,635 

2018 2019 2020 2021 2022

Dollars in Billions
8 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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

FY 2018–22

Figure 5: Total Federal Student Aid Delivered

FY 2018–22

Figure 6: FSA Federal Employees3

FY 2018–22

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

18.6 18.0 17.8 17.6 16.9

12.7

10.4 10.8 10.1 9.8

2018 2019 2020 2021 2022

in Millions

Total Applications Processed Total Postsecondary Students Receiving Aid

$122.4 $121.8 

$115.6 

$112.0 $111.6 

2018 2019 2020 2021 2022

Dollars in Billions

1,257 1,251

1,462 1,416

1,356

2018 2019 2020 2021 2022
Fiscal Year 2022 Annual Report | Federal Student Aid 9

Management’s Discussion and Analysis 

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 HEA. Specifically, Title IV of the HEA 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, 

• Processing millions of FAFSA forms, 

• 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, 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 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.
10 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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 five 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 

During FY 2022, FSA operated on an annual administrative budget of approximately $1.9 billion. 

As of September 30, 2022, FSA was staffed by 1,356 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

Chief Operating 

Officer

Office of Partner 

Participation and 

Oversight

Office of Student 

Experience and Aid 

Delivery

Office of Strategic 

Measures and 

Outcomes

Office of Strategy 

Innovation and 

Transformation

Principal Deputy 

Chief Operating 

Officer
Fiscal Year 2022 Annual Report | Federal Student Aid 11

Management’s Discussion and Analysis 

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 above other interests and hold everyone 

accountable.

Customer Service Provide accurate and timely information to customers 

throughout the student aid lifecycle. 

Excellence Strive to be the very best in all we do by embracing a 

culture of continuous improvement.

Respect Value individuals by acknowledging the diversity of their 

contributions, ideas, and beliefs.

Stewardship Uphold the sacred trust of taxpayers as we work to support 

the goals of Congress and the Administration.

Teamwork Work in collaboration with our colleagues and partners to 

produce the best possible results.

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 metrics. The realization of these goals will 

enable the organization to accomplish its mission successfully.
12 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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 other 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.

Coronavirus Response and Relief Supplemental 

Appropriations Act, 2021

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, contracted servicers, and 

collection agencies, as well as taxpayers and other federal entities such as Congress and the 

Office of Management and Budget (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 

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

system. 
Fiscal Year 2022 Annual Report | Federal Student Aid 13

Management’s Discussion and Analysis 

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. 
14 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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 2022, FSA processed more than 16.9 million FAFSA forms, resulting in the delivery of 

approximately $111.6 billion in Title IV aid to more than 9.8 million postsecondary students and 

their families. These students attended more than 5,500 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 2022 and FY 2021. A summary discussion of each Title IV program is 

presented in the paragraphs after the table.
Fiscal Year 2022 Annual Report | Federal Student Aid 15

Management’s Discussion and Analysis 

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

(Dollars in Millions) 

Programs

2022 Aid 

Disbursed to 

Students 

2021 Aid 

Disbursed 

to Students

Difference Percentage 

Change

Federal Loan Programs

William D. Ford Federal Direct Loan Program $ 83,450.6 $ 83,279.4 $ 171.2 0.2% 

Federal Grant Programs

Federal Pell Grant Program $ 26,129.5 $ 26,709.8 $ (580.3) (2.2)% 

Federal Supplemental Educational Opportunity 

Grant Program 866.5 868.8 (2.3) (0.3)% 

The Teacher Education Assistance for College and 

Higher Education Grant Program 57.4 75.0 (17.6) (23.5)% 

Other Grant Programs 0.5 0.6 (0.1) (16.7)% 

Subtotal Grant Programs $ 27,053.9 $ 27,654.2 $ (600.3) (2.2)% 

Federal Work-Study Program

Federal Work-Study Program $ 1,106.2 $ 1,052.9 $ 53.3 5.1% 

Grand Total $ 111,610.7 $ 111,986.5 $ (375.8) (0.3)% 

Federal Loan Programs

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

more than $1.6 trillion, representing approximately 219.4 million student loans to more than 

45.7 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.

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.
16 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

• Direct Unsubsidized Loans: Federal loans made to undergraduate students 

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

interest 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, 2022, FSA’s portfolio of Direct Loans included $816.5 trillion in credit 

program receivables, net. In FY 2022, the Department made $83.5 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 $101.8 billion as of September 30, 2022. Of this portfolio, 

$39.8 billion represented FSA’s credit program receivables, net, comprised of $29.9 billion in 

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

authorization and $9.9 billion acquired under the "traditional" (Non-ECASLA) guaranteed loan 

program. In FY 2022, FSA made gross payments of approximately $352.3 million to lenders for 

interest and special allowance subsidies and $4.8 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 

5 Excludes consolidation loans of $39.6 billion.
Fiscal Year 2022 Annual Report | Federal Student Aid 17

Management’s Discussion and Analysis 

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 

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 $398.9 million for FY 2022. 

Federal Grant Programs

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

approximately $27.1 billion in grants to more than 6.0 million recipients. The following provides a 

summary for each grant program, including aid disbursed in FY 2022. 

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 2022, the Department disbursed $26.1 billion in Federal Pell Grants averaging 

approximately $4,350 to approximately 6.0 million students. The maximum Federal Pell Grant 

award was $6,495 in the 2021–22 award year and increased to $6,895 in the 2022–23 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 2022, approximately $866.5 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 2021–22 or 2022–23 TEACH Grant first 
18 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

disbursed on or after October 1, 2021, and before October 1, 2022, the maximum award is 

$3,772. For any award year 2022–23 TEACH Grant first disbursed on or after October 1, 2022, 

and before October 1, 2023, 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 2022, there were 

approximately 2,824 involuntary conversions and 2,199 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 2022, there were 

approximately 786 reinstatements from loan status back to grant status. In FY 2022, the 

Department disbursed more than 22,000 grants totaling $57.4 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, 2021, and before October 1, 2022, the maximum award is approximately $6,125. 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 up to $6,501.99. The

Department disbursed approximately $0.5 million to support fewer than 100 awards in FY 2022. 

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 2022, 

approximately $1.1 billion were disbursed through more than 600,000 campus-based awards. 
Fiscal Year 2022 Annual Report | Federal Student Aid 19

Management’s Discussion and Analysis 

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 trends and conditions for the financial aid 

environment 

Indicate student aid environment within which FSA must 

operate. Listed below are key trends that may affect the 

financial aid environment.

• The size and performance of FSA’s portfolio of loans 

has direct implications for taxpayers. 

• Students are making high impact financial decisions 

without the benefit of adequate financial knowledge. 

• Digital fluency and mobile ubiquity are driving new 

service expectations among customers.

• Increased volume of student data has created new 

opportunities, obligations, and risks. 

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 2022 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. 
20 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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. In this 

way, the key strategic drivers influence the development and implementation of FSA’s strategic 

plan, as well as the development and tracking of performance metrics. The Performance 

Management section illustrates the outcome of this effort by discussing the following:

• FSA’s performance management processes,

• FSA’s FY 2020–24 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.

Figure 9: Strategic Process Building Blocks
Fiscal Year 2022 Annual Report | Federal Student Aid 21

Management’s Discussion and Analysis 

Performance Management Processes at Federal Student Aid

During FY 2022, FSA used a tiered performance management framework to establish goals and

communicate, measure, and report performance:

• FSA FY 2020–24 Strategic Plan

• Weekly Organization Briefings

• Bi-Weekly Performance Accountability Meetings

• Annual Performance Report

• Department’s Quarterly and Annual Performance Reviews

• Agency Priority Goals (APGs)

FSA FY 2020‒24 Strategic Plan

The FY 2020–24 Strategic Plan outlines goals, objectives, and performance metrics 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

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 adequately defined.

Each strategic goal encompasses objectives and identifies performance metrics to measure

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

metric, while falling short of the target indicates that FSA did not attain the performance metric.
22 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

Strategic Framework

The FY 2020–24 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 plan.

Table 6: Strategic Goals and Strategic Objectives for FY 2020‒24

Strategic Goal 1 Strategic Objectives

Empower a High Performing Organization

1.1: Improve employee engagement and workplace inclusion to 

develop and retain talent, improve employee satisfaction, and 

engage in effective succession planning.

1.2: Expand employee skills and capabilities to support Next Gen 

FSA. 

Strategic Goal 2 Strategic Objectives

Provide World-Class Customer 

Experience to the Students, Parents, and 

Borrowers We Serve

2.1: Ensure that all students can easily access information on 

federal student aid, apply for federal student aid, and have 

information on repayment options.

2.2: Provide seamless, easy, personalized digital interactions equal 

with top financial institutions in the delivery of financial aid 

products and services.

2.3: Streamline contact center and back-office operations to improve 

our customers’ integrated experience.

2.4: Simplify the communication and processes associated with 

borrower repayment plans.

Strategic Goal 3 Strategic Objectives

Increase Partner Engagement and 

Oversight Effectiveness

3.1: Provide effective oversight of FSA’s partners utilizing a 

comprehensive suite of monitoring tools.

3.2: Strengthen partner engagement and provide effective outreach 

and assistance. 

Strategic Goal 4 Strategic Objectives

Strengthen Data Protection and 

Cybersecurity Safeguards

4.1: Implement business partner and vendor systems that house, 

manage, and provide systems supporting FSA business 

processes, outreach and awareness focused on oversight, 

enforcement, infrastructure, systems, and data.

4.2: Improve student privacy data and cybersecurity controls of 

Institutions of Higher Education (IHEs) through outreach and 

communication, to mitigate future cyber-incidents and breaches. 

4.3: Build an effective cybersecurity culture through employee 

awareness, training and accountability focused on protecting 

systems and data.

Strategic Goal 5 Strategic Objectives

Enhance the Management and 

Transparency of the Portfolio

5.1: Improve the management and transparency of FSA’s student 

loan portfolio performance.

5.2: Provide analytics and operational support for a customercentric, data-driven, performance-based organization.

5.3: Leverage portfolio analytics to drive improved outcomes for 

customers and taxpayers.

5.4: Increase vendor performance through quality management 

activities centered on customer service and product delivery.
Fiscal Year 2022 Annual Report | Federal Student Aid 23

Management’s Discussion and Analysis 

Weekly Organization Briefings

The Organization Briefings in FY 2022 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, 

contributed to developing the FY 2022 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 2020–24 Strategic Plan. Over the past year, FSA has expanded the 

extensive catalog of presentations from the Organization Briefings, including aligning the 

briefing cadence with strategic goals and priority topics based on all the program offices that 

work to support the efforts of the strategic plan. The frequent data-driven and results-oriented 

analyses offered 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.

Bi-Weekly Performance Accountability Meetings

Throughout FY 2022, FSA measured and analyzed performance based upon performance 

metric results outlined in the FY 2020–24 Strategic Plan, as well as various internal metrics 

used for operational management. The analysis of performance continues to be a transparent 

process within the organization, executed through weekly performance reports shared with the 

FSA leadership and management team. Detailed analyses of specified performance metrics are 

developed and provided to the FSA leadership and management team in the form of 

dashboards.

As of the end of the fiscal year, the organization was updating 22 dashboards on 12 topics, with 

68 visualizations representing approximately 90 metrics on a weekly basis. Areas of focus and 

metrics were added as FSA identified potential concerns or opportunities for improvement. 

These dashboards were used to identify and resolve issues that may be affecting organizational 

performance. 

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.

Department of Education Quarterly and Annual Performance Reviews

The Department conducts quarterly meetings with principal offices on progress towards 

achieving agency priorities, known as Strategic Planning Performance Reviews (SPPR). The 

SPPR is a quarterly discussion-driven performance review led by 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 
24 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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.

FSA’s FY 2020–24 Strategic Plan supports the Department’s overall strategic goals and 

directions, as defined in the Department’s FY 2022–26 Strategic Plan, which was released July 

2022. In the Department’s new plan, FSA tracks the performance of 11 metrics that supports 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.
Fiscal Year 2022 Annual Report | Federal Student Aid 25

Management’s Discussion and Analysis 

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 agency leadership wants to accomplish within approximately 

24 months. In collaboration with OMB, the Department established three APGs for FY 2022 

through FY 2023 that align with the Department’s FY 2022–26 Strategic Plan. FSA is 

responsible for APG-2, and quarterly progress reports are published on Performance.gov. 
26 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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. Specifically, FSA uses this matrix as a tool to validate the completeness and 

reliability of the underlying data gathered and used to calculate each performance metric for the 

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

performance metric, this matrix is used to document the following: data source, availability, 

security procedures, and known limitations; whether data are subject to FSA’s OMB Circular A123 Internal Control Review process; and procedures for accessing the data, calculating the 

performance metric, and validating and verifying the data gathered.

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

Data Validation and Verification subsection, located in the Appendices section.
Fiscal Year 2022 Annual Report | Federal Student Aid 27

Management’s Discussion and Analysis 

Analysis of Financial Statements

Introduction

The Analysis of Financial Statements section provides an overview of FSA’s financial results for 

FY 2022. This section assists readers in understanding FSA’s financial results, position, and 

condition as reflected in the financial statements and notes located in the Financial Section of 

this report. The financial analysis 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 is committed to providing sound management, financial systems, and controls to ensure 

students receive aid and repay loans according to applicable laws and regulations. FSA’s 

comparative financial statements are prepared in accordance with established federal 

accounting standards and reporting requirements. The financial statements are subject to an 

annual independent audit to determine whether FSA’s financial statements present fairly FSA’s 

financial position, net cost, changes in net position, and budgetary resources. This year, FSA 

received a disclaimer of opinion on its FY 2022 financial statements. 

FSA presents its comparative financial statements and notes in the format prescribed by OMB 

Circular A-136. For FY 2022 and FY 2021, the Balance Sheet, Statement of Net Cost, and 

Statement of Changes in Net Position were prepared on a consolidated basis, whereas the 

Statement of Budgetary Resources was prepared on a combined basis. These financial 

statements, along with the Independent Auditors’ Report on these statements, can be found in 

the Financial Section.

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

directly owns and manages approximately $1.5 trillion. The remaining balance represents nondefaulted FFEL Guaranteed loans held by lenders and Federal Perkins loans held by schools, 

as detailed in Note 5. As described in Note 1 and Note 5, FSA reports its portfolio of federal 

student loans on its Balance Sheet, on the line-item Credit Program Receivables, Net. This 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, 2022, FSA reported $858.3 billion in Credit Program Receivables, 

Net after deducting an Allowance for Subsidy of approximately $674.6 billion. Credit Program 

Receivables, Net was 26.3% less than the prior-year amount. This decrease was primarily due 

to the $352.6 billion (109.5%) increase in the FY 2022 Allowance for Subsidy as compared to 

FY 2021. 
28 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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 

Components of subsidy transfers primarily consists of contract collection costs, program review 

collections, fees, and loan forgiveness.

The $352.6 billion increase in the FY 2022 Allowance for Subsidy was due to broad-based debt 

relief. To address the financial harms of the pandemic by smoothing the transition back to 

repayment and helping borrowers at highest risk of delinquencies or default once payments 

resume, the Department provided a plan for broad-based debt relief. Borrowers with loans held 

by the Department who received a Pell Grant in college and meet the specified income limits 

are eligible for up to $20,000 in debt relief, while non-Pell Grant recipients who meet the 

specified income limits are eligible for up to $10,000 in relief. Applications for this debt relief 

launched on October 17, 2022. This action resulted in an upward modification cost of 

$361.0 billion in the Direct Loan Program. There was a net negative $23.7 billion modification 

adjustment transfer associated with this modification, bringing the total FY 2022 modification 

cost for the Direct Loan Broad-Based Debt Relief to $337.3 billion. 

A more detailed discussion of the Allowance for Subsidy estimates is discussed in Note 5. 

The FY 2022 FSA Financial Highlights tables presented on the next page provide a condensed 

summary of the significant balances in FSA’s Balance Sheets and Statements of Net Cost over 

a five-year period, beginning with FY 2018. The tables also show the percentage change 

between the prior and current fiscal years as of September 30, 2021 and 2022, respectively.

The figures and tables presented in this section include rounding adjustments to ensure that the 

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. 
Fiscal Year 2022 Annual Report | Federal Student Aid 29

Management’s Discussion and Analysis 

Table 7: Financial Highlights

Condensed Balance Sheets

(Dollars in millions)

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022 Percentage 

Change6

Assets

Fund Balance with Treasury $ 73,405 $ 62,567 $ 70,266 $ 79,163 $ 118,636 49.9%

Credit Program Receivables, Net 1,209,495 1,202,092 1,169,614 1,164,800 858,277 (26.3)% 

Remaining Assets 2,365 2,217 2,171 2,177 905 (58.4)% 

Total Assets $1,285,265 $1,266,876 $ 1,242,051 $ 1,246,140 $ 977,818 (21.5)%

Liabilities

Debt $1,258,481 $1,287,494 $ 1,249,807 $ 1,221,116 $ 905,006 (25.9)%

Subsidy due to Treasury General 

Fund 7,528 10,302 3,283 1,513 26,965 1,682.2% 

Remaining Liabilities 10,197 13,971 8,350 15,905 18,121 13.9% 

Total Liabilities $1,276,206 $1,311,767 $ 1,261,440 $ 1,238,534 $ 950,092 (23.3)%

Net Position

Unexpended Appropriations $ 32,487 $ 31,400 $ 35,038 $ 36,338 $ 37,259 2.5%

Cumulative Results of Operations (23,428) (76,291) (54,427) (28,732) (9,533) (66.8)% 

Net Position $ 9,059 $ (44,891) $ (19,389) $ 7,606 $ 27,726 264.5% 

Total Liabilities & Net Position $1,285,265 $1,266,876 $ 1,242,051 $ 1,246,140 $ 977,818 (21.5)%

Table 8: Statements of Net Cost

(Summarized) 

(Dollars in millions)

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022 Percentage 

Change7

Gross Cost $ 71,232 $ 144,865 $ 171,245 $ 177,382 $ 502,972 183.6% 

Less: Earned Revenue (36,224) (36,820) (39,384) (39,724) (65,100) 63.9% 

Net Cost of Operations $ 35,008 $ 108,045 $ 131,861 $ 137,658 $ 437,872 218.1%

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. The assets represent resources available for use by FSA to 

pay its liabilities or to satisfy its future service needs. The liabilities are amounts FSA owes, the 

probable and measurable future outflows of its resources arising from past transactions or 

events. The difference between the assets and the liabilities represents FSA’s net position.

The consolidated Balance Sheet shows that FSA had total assets of $977.8 billion as of 

September 30, 2022, a decrease of $268.3 billion, or 21.5% over the September 30, 2021 total 

assets balance of $1,246.1 billion. The difference resulted primarily from a 49.9% increase in 

Fund Balance with Treasury ($39.5 billion), combined with a 26.3% decrease in net Credit 

Program Receivables ($306.5 billion). Together, FSA’s Fund Balance with Treasury and its net 

Credit Program Receivables accounted for approximately 99.9% of Total Assets as of 

September 30, 2022, as illustrated in the Composition of Assets chart (Figure 10). The 

6 The percentage change is calculated as the difference between FY 2021 and FY 2022, divided by the FY 2021 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.

7 Refer to Footnote 6.
30 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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

line items over the past five fiscal years.

Figure 10: Composition of Assets8

Figure 11: Comparison of Assets

(Dollars in Billions)

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

$858.3 billion as of September 30, 2022, represents FSA’s most important asset category and 

accounted for approximately 87.8% of Total Assets. This balance includes $1,532.9 billion in 

principal, interest, and fees, less an allowance for subsidy cost of approximately $674.6 billion 

that adjusted the loan portfolio to its estimated present value. See Note 5 for more detail. FSA 

reports the total amount under the three major program categories Direct Loan, FFEL, and 

Other, as illustrated in Figure 12 below and discussed more fully in the following sections. 

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

amount being reported.

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Credit Program Receivables, Net 94.1% 94.9% 94.2% 93.5% 87.8%

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

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

0%

20%

40%

60%

80%

100%

Composition of 

FSA Assets

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Credit Program Receivables,

Net $1,209.5 $1,202.1 $1,169.6 $1,164.8 $858.3

Fund Balance with Treasury $73.4 $62.6 $70.3 $79.2 $118.6

Remaining Assets $2.4 $2.2 $2.1 $2.1 $0.9

Total Assets $1,285.3 $1,266.9 $1,242.1 $1,246.1 $977.8

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

Assets
Fiscal Year 2022 Annual Report | Federal Student Aid 31

Management’s Discussion and Analysis 

Figure 12: Total Loan Portfolio

Net of Allowance for Subsidy

(Dollars in Billions)

Figure 12 also shows that over the five-year period, FY 2018–22, FSA’s portfolio of FSA net 

credit program receivables decreased by $351.2 billion or 29.0%. The Direct Loan program 

accounted for most of this change and decreased by $298.6 billion (26.8%). The overall 

decrease also included the $53.1 billion (57.2%) reduction of the FFEL Portfolio over the same 

period. 

The directional changes observed 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. 

Consolidation is the process of combining one or more federal student loans into one loan. For 

more information about which federal loans may be eligible for consolidation and other 

requirements, please visit StudentAid.gov/manage-loans/consolidation. Another significant 

factor in FY 2022 was an increase to the allowance for subsidy cost of $352.7 billion (109.5%) 

as compared to FY 2021. The reasons for the adjustment to the subsidy cost estimate are 

explained in Note 5. 

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

continue to be the major component of FSA’s credit program receivable portfolio in FY 2022. As 

of September 30, the $816.5 billion Direct Loan portfolio ending balance comprises 95.1% of 

FSA's total credit program receivables net, compared to the prior year ending balance of 

$1,104.9 billion that represented 94.9%. The FY 2022 Direct Loan ending balance total includes 

$1,428.4 billion in principal, interest, and fees, with an allowance for subsidy cost of 

$611.9 billion. This amount contrasts to the prior year where the subsidy costs were projected at 

$273.8 billion on Direct Loan principal, interest, and fees of $1,378.7 billion. The factors that 

contributed to the variance in subsidy cost at a time when the underlying loan balances 

increased by 3.6% are addressed in Note 5. 

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

 Direct Loans $1,115.1 $1,123.7 $1,100.5 $1,104.9 $816.5

 FFEL $92.9 $76.8 $67.4 $58.2 $39.8

Other Programs $1.5 $1.6 $1.7 $1.7 $2.0

Total $1,209.5 $1,202.1 $1,169.6 $1,164.8 $858.3

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

Credit Program 

Receivables, Net 
32 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

The FY 2022 $49.7 billion increase in Direct Loan Receivables (before subsidy costs) was 

mainly driven by the growth in the outstanding amount owed by borrowers, primarily resulting 

from new loan disbursements ($83.5 billion) and consolidation disbursements ($36.9 billion). 

This increase was offset by reductions to principal due to principal loan payments ($41.3 billion), 

principal loan write-offs ($23.4 billion), and other adjustments ($6.0 billion). 

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. See Note 5 for more 

details.

Figure 13: Components of Direct Loan Receivables, Net9

(Dollars in Billions)

The figure shows the number of recipients corresponding to the outstanding loan portfolio at 

each fiscal year end. Recipients are students that benefit from the federal student loans. In most 

cases, a recipient is the borrower; but for the Parent PLUS loans, the parent is the borrower, 

and the student is the recipient. Figure 13 also shows that Direct Loan recipients grew from 

34.2 million to 37.1 million over the five-year period. As a result, the average debt (principal and 

interest) balance outstanding per Direct Loan recipient increased by 14.5% during this time, 

from $33,626 to $38,504; the higher debt burden per student is likely an indication of increasing 

postsecondary education costs.

Table 9: Components of Direct Loan Credit Program Receivables, Net by Percentage

Direct Loan Component FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Principal 97.2% 103.7% 111.3% 117.0% 164.3%

Accrued Interest 6.5% 7.4% 8.4% 7.8% 10.6%

Allowance for Subsidy (3.7)% (11.1)% (19.7)% (24.8)% (74.9)%

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

9 Recipient numbers come from the FSA Data Center or National Student Loan Data System (NSLDS®) database. For more details, 

refer to Footnote 11. 

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Principal $1,083.7 $1,164.9 $1,224.8 $1,292.2 $1,341.8

Accrued Interest $72.0 $83.3 $92.1 $86.5 $86.6

Allowance for Subsidy $(40.6) $(124.5) $(216.4) $(273.8) $(611.9)

Net Receivable $1,115.1 $1,123.7 $1,100.5 $1,104.9 $816.5

Total Recipients 34.2 35.1 35.9 37.0 37.1

32.5

33.0

33.5

34.0

34.5

35.0

35.5

36.0

36.5

37.0

37.5

($1,000)

($500)

$0

$500

$1,000

$1,500

Recipients in Millions

Direct Loan Credit 

Program Receivables, 

Net
Fiscal Year 2022 Annual Report | Federal Student Aid 33

Management’s Discussion and Analysis 

Table 9 illustrates that accrued interest increased from 6.5% to 10.6% of the net receivable 

amount and outstanding principal increased from 97.2% to 164.3% of the net amount. 

Table 10: Increase in Principal, Interest and Subsidy Components of Direct Loan Credit 

Program Receivables, Net and Recipient Counts

Direct Loan Component FY 2018–19 FY 2019–20 FY 2020–21 FY 2021–22

FY 2018–22

Average Year-toYear Change

Principal 7.5% 5.1% 5.5% 3.8% 5.5%

Accrued Interest 15.7% 10.6% (6.1)% 0.2% 5.1%

Allowance for Subsidy (206.7)% 73.8% 26.5% 123.4% 4.3%

Net Receivable 0.8% (2.1)% 0.4% (26.1)% (6.8)%

Total Recipients 2.6% 2.3% 3.1% 0.3% 2.1%

Table 10 shows that accrued interest increased at a slightly lower average annual rate than 

outstanding principal (5.1% versus 5.5%). The table also shows the increase of Direct Loan 

recipients by 2.1% each year which is well below the rate of increase of principal and interest.

While the Direct Loan portfolio has grown rapidly in recent years, it has also changed in 

character as an increasing proportion of students begin the repayment phase of their loans. 

Under the Title IV regulations, each loan may pass through several distinct statuses as the 

student progresses through the loan life cycle, from borrowing to repaying.

Repayment on most federal student loans is not required while the student recipient is “In 

School” unless they drop below half-time enrollment. However, repayment of Federal PLUS 

Loans to parents begin 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 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. 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”.

10

The status continues to be tracked through the life of the loan until the loan is paid in full or 

otherwise closed out.

The following is the history of the COVID-19 emergency relief flexibilities. 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 CARES Act became law. The CARES Act provided for the above relief 

10 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.
34 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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 emergency relief measures were extended through at least 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, until 

the Department is permitted to implement the debt relief program, or the litigation is resolved. 

Payments will restart 60 days later. If the debt relief program has not been implemented and the 

litigation has not been resolved by June 30, 2023 – payments will resume 60 days after that. 

The Department will notify borrowers before payments restart. 

Figure 1411 divides FSA’s portfolio of Direct Loans into two main categories, based on 

repayment status. For the purpose of this discussion,

12 loans are classified as “In Repayment” 

if, under the terms of the promissory note, the loan is current, delinquent, defaulted, in nondefaulted bankruptcy, or in a disability status. 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.

11 FY 2019 data are taken directly from the NSLDS database. Also, the FY 2018 data published in the FY 2018 Annual Report, 

taken directly from the NSLDS database, have been replaced with data subsequently published by the FSA Data Center.

12 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.
Fiscal Year 2022 Annual Report | Federal Student Aid 35

Management’s Discussion and Analysis 

Figure 14: Direct Loan Portfolio by Repayment Status13

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” classifications. As can be 

seen in Figure 14, although both segments grew during the period FY 2018–19, the “In 

Repayment” segment grew to represent 65.7% of the total principal and interest amount 

outstanding, increasing the need for FSA to facilitate the ability of Direct Loan borrowers to meet 

their repayment obligations timely. During the period FY 2020–21, due to COVID-19 and the 

temporary emergency relief measures extended to student loan borrowers, the “In Repayment” 

segment declined to 11.1% of the total principal and interest amount outstanding while the “Not 

in Repayment” segment increased to represent 88.9%.

The September 30, 2022 balance of loans in repayment of $129.3 billion (9.1% of the total 

Direct Loan portfolio) is comparable to the $138.8 billion (10.1%) as of September 30, 2021. 

The dramatic decline in this segment from FY 2019 reflects the impact of the COVID-19 

emergency and the payment pause, which placed most borrowers into administrative 

forbearance. The student loan payment pause has been extended until the Department is 

permitted to implement the debt relief program or the litigation is resolved. Payments will restart 

60 days later. If the debt relief program has not been implemented and the litigation has not 

been resolved by June 30, 2023 – payments will resume 60 days after that. The Department will 

notify borrowers before payments restart.

In the following Figures 15A and 15B, the Direct Loan portfolio of “In Repayment” principal and 

interest has been subdivided into three categories, “Current”, “Delinquent”, and 

“Default/Bankruptcy/Other”, as those terms are defined above. 

13 Refer to Footnotes 11 and 12 for more details. 

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

In Repayment $738.7 $820.1 $146.6 $138.8 $129.3

Not in Repayment $417.0 $428.0 $1,170.3 $1,239.7 $1,299.2

Total Direct Loan Portfolio $1,155.7 $1,248.1 $1,316.9 $1,378.5 $1,428.5

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

$1,600

Direct Loan Portfolio 

Principal and Interest Outstanding
36 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

Figure 15A: Direct Loan Portfolio Segment in Repayment by Status14

Principal and Interest Only

(Dollars in Billions) 

Figure 15B: Direct Loan Portfolio Segment in Repayment by Status15

Principal and Interest Only 

(Percentage of Total)

Regarding the “In Repayment” segment amounts as of September 30, 2022, there was no 

delinquent loan principal as compared to $90.9 billion as of September 30, 2019. Also, 

14 Refer to Note 10 for more details.

15 Refer to Note 10 for more details.

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Current $531.2 $594.7 $14.7 $16.2 $11.8

Delinquent $92.3 $90.9 $0 $0 $0

Default/Bankruptcy/Other $115.2 $134.5 $131.9 $122.6 $117.5

Totals $738.7 $820.1 $146.6 $138.8 $129.3

$0

$100

$200

$300

$400

$500

$600

$700

$800

$900

Direct Loan Portfolio Segments in 

Repayment

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Current 71.9% 72.5% 10.0% 11.7% 9.1%

Delinquent 12.5% 11.1% 0.0% 0.0% 0.0%

Default/Bankruptcy/Other 15.6% 16.4% 90.0% 88.3% 90.9%

Totals 100% 100% 100% 100% 100%

0%

20%

40%

60%

80%

100%

120%

Direct Loan Portfolio Segments in 

Repayment
Fiscal Year 2022 Annual Report | Federal Student Aid 37

Management’s Discussion and Analysis 

regarding the “In Repayment” segment amounts as of September 30, 2022, $117.5 billion 

(90.9%) in loan principal was in default/bankruptcy/other status compared to $122.6 billion 

(88.3%) as of September 30, 2021. The dramatic changes in these segments from FY 2019 to 

FY 2022 were due to the impact of the CARES Act and Presidential Directives which suspended 

borrower payments. 

The portfolio of Direct Loan principal and interest receivables “Not in Repayment” can also be 

further subdivided based on the reason why the debt is not currently subject to repayment.

Figures 16A and 16B16 subdivide this segment into two such categories, “In School, Grace 

Period, and Education Deferments” and “Forbearance/Noneducation Deferments” as defined 

earlier.

Figure16A shows that the amount of Direct Loan principal and interest categorized as “In 

School, Grace Period, and Education Deferments” has remained relatively consistent, 

$295.5 billion in FY 2018 to $259.5 billion at the end of the current year. This decrease reflects 

a decline in new Direct Loan disbursements over the period, and the aging of the Direct Loan

portfolio of principal and interest receivable, as a greater proportion of debt moved from “In 

School, Grace Period, and Education Deferments” category to the “In Repayment” segment.

Figure 16B indicates that during the three-year period FY 2018–20, the “Forbearance and 

Noneducation Deferments” segment grew from $121.5 billion to $887.5 billion, increasing from 

29.1% to 75.8% of the “Not in Repayment” segment. This segment increased from $967.8 billion 

in FY 2021 (78.1%) to $1,039.7 billion in FY 2022 (80%). These increases were due to the 

Impact of the CARES Act and Presidential Directives. However, during the FY 2018–22 period, 

the “In School, Grace Period, and Education Deferments” declined from $295.5 billion to 

$259.5 billion. Also due to the impact of the CARES Act and Presidential Directives, this 

segment declined from 70.9% to 20.0% of the “Not in Repayment Segment.”

Figures 16A and 16B illustrate the dramatic impact of the CARES Act and Presidential 

Directives. “In School, Grace Period, and Education Deferments” amounts decreased from 

$294.8 billion as of September 30, 2019, to $259.5 billion as of September 30, 2022. However, 

the “Forbearance and Noneducation Deferments” amounts increased from $133.2 billion as of 

September 30, 2019, to $1,039.7 billion as of September 30, 2022. 

16 Please refer to Footnotes 10 and 11 for more details.
38 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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

Principal and Interest Only

(Dollars in Billions)

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

Principal and Interest Only

(Percentage of Total)

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

In School, Grace Period, and

Education Deferments 70.9% 68.9% 24.2% 21.9% 20.0%

Forbearance and Noneducation

Deferments 29.1% 31.1% 75.8% 78.1% 80.0%

Total 100.0% 100.0% 100.0% 100.0% 100.0%

0%

20%

40%

60%

80%

100%

120%

Direct Loan Portfolio 

Segments not 

in Repayment

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

In School, Grace Period, and

Education Deferments $295.5 $294.8 $282.8 $271.9 $259.5

Forbearance and Noneducation

Deferments $121.5 $133.2 $887.5 $967.8 $1,039.7

Totals $417.00 $428.00 $1,170.3 $1,239.7 $1,299.2

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

Direct Loan Portfolio Segments 

not in Repayment
Fiscal Year 2022 Annual Report | Federal Student Aid 39

Management’s Discussion and Analysis 

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) defaulted guaranteed loan programs, known collectively as the “FFEL Guaranteed” 

portfolio segment. Changes in these FFEL loan portfolio segments over the past five fiscal years 

are shown in Figure 17. 

Figure 17: Total FFEL Loan Portfolio17

(Dollars in Billions) 

Figure 17 illustrates that with $29.9 billion outstanding, the FFEL ECASLA portfolio segment 

remains the major component of the FFEL Guaranteed portfolio of net credit program 

receivables as of September 30, 2022. This segment declined from $64.8 billion in FY 2018 to

$29.9 billion in FY 2022, a decline of $34.9 billion (53.9%) during the five-year period shown. 

This decrease was mainly the result of collections of principal and the impact of borrowers 

consolidating their loans under the Direct Loan Program, to take advantage of more favorable 

repayment options available in that program. 

The FFEL ECASLA portfolio declined from $42.1 billion as of September 30, 2021, to 

$29.9 billion as of September 30, 2022. Outstanding principal declined from $45.8 billion to 

$42.7 billion, and the subsidy allowance increased from $12.5 billion to $21.2 billion. Subsidy 

allowance amounts reduce the net receivable balance. The decrease in the interest receivable 

from $8.8 billion to $8.4 billion also reduced the net receivable balance. Despite this decrease, 

the proportion of FFEL ECASLA loans were approximately 75.1% of the total $39.8 billion of 

FFEL loans outstanding as of the current year-end.

Over the five-year period from FY 2018 to FY 2022, the smaller FFEL Guaranteed portfolio 

declined from $28.1 billion as of September 30, 2018, to $9.9 billion as of September 30, 2022

($18.2 billion difference). Outstanding principal increased $1.3 billion to $37.6 billion, and the

subsidy allowance increased by $5.7 billion to $40.9 billion. Subsidy allowance amounts reduce 

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

Loan Program

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

 FFEL Guaranteed $28.1 $23.1 $21.1 $16.1 $9.9

 FFEL ECASLA $64.8 $53.7 $46.3 $42.1 $29.9

Total FFEL $92.9 $76.8 $67.4 $58.2 $39.8

$0

$10

$20

$30

$40

$50

$60

$70

$80

$90

$100

FFEL Credit Program 

Receivables, Net 
40 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

the net receivable balance. There was a decrease in the September 30, 2022, interest 

receivable of $1.8 billion to $13.2 billion.

The overall impact of changes in the principal, accrued interest, and subsidy components of the 

FFEL portfolio are shown below in Figure 18.18 The reduction in FFEL recipients during the 

period FY 2018–22 also demonstrates the impact of debt consolidations and refinancing on the 

outstanding portfolio balance.

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 Receivable, net 

that FSA reports on its balance sheet.

18 Recipients in Millions for FY 2018–19 are based on data published by the FSA Data Center, at StudentAid.gov/portfolio. 

FY 2019 data are taken directly from the NSLDS database. Also, the FY 2018 data published in the FY 2018 Annual Report, taken 

directly from the NSLDS database, have been replaced with data subsequently published by the FSA Data Center.

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Principal $95.1 $90.2 $84.8 $82.0 $80.3

Accrued Interest $21.1 $22.3 $24.1 $23.9 $21.6

Allowance for Subsidy $(23.3) $(35.7) $(41.5) $(47.7) $(62.1)

Total Receivable $92.9 $76.8 $67.4 $58.2 $39.8

Total Recipients 6.6 6.1 5.8 5.6 5.2

 -

 1.0

 2.0

 3.0

 4.0

 5.0

 6.0

 7.0

($80)

($60)

($40)

($20)

$0

$20

$40

$60

$80

$100

$120

Recipients in Millions

Credit Program Receivables, 

Net
Fiscal Year 2022 Annual Report | Federal Student Aid 41

Management’s Discussion and Analysis 

Figure 19: Other Loan Portfolio

(Dollars in Millions)

This segment, known as Other Credit Program Receivables, Net, increased by 31.2% during the 

past five years, but still accounted for only 0.23% of FSA’s total loan portfolio ($858.3 billion) as 

of September 30, 2022. Other Credit Program Receivables, net ended FY 2022 with a balance 

of $1.96 billion, a $258.0 million increase compared to the prior year-end.

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, 2022, FSA 

had total liabilities of $950.1 billion as compared to $1.2 trillion on September 30, 2021, a 

decrease of $288.4 billion or 23.3% less than the September 30, 2021, total. This decrease in 

liabilities is comparable to the 21.5% decrease in FSA’s total assets.

Debt. FSA’s debt associated with loans is the primary component of its liabilities ($950.1 billion), 

accounting for 95.3% of the total. FSA’s debt balance of approximately $905.0 billion as of 

September 30, 2022, is 25.9% less than the prior-year amount. As shown in Figure 20, the 

Direct Loan Program was the principal debt component throughout the FY 2018–22 period and 

ended FY 2022 with a balance of nearly $837.4 billion, 26.7% less than the prior-year amount, 

representing 92.5% of total debt.

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

 TEACH Grant Program $584.1 $616.0 $669.9 $597.9 $496.0

 Perkins Loan Program $551.0 $607.1 $634.3 $692.2 $1,066.0

HEAL $359.9 $394.6 $386.0 $412.9 $399.0

Total $1,495.0 $1,617.7 $1,690.2 $1,703.0 $1,961.0

$0

$500

$1,000

$1,500

$2,000

$2,500

Credit Program Receivables, Net 
42 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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.

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Direct Loan Program $1,061.6 $1,150.6 $1,160.1 $1,142.2 $837.4

FFEL Program $107.3 $94.7 $89.0 $78.2 $67.0

Other Programs (TEACH) $0.6 $0.7 $0.7 $0.7 $0.6

Total Debt $1,258.5 $1,287.5 $1,249.8 $1,221.1 $905.0

$0

$200

$400

$600

$800

$1,000

$1,200

$1,400

Student Aid Debt
Fiscal Year 2022 Annual Report | Federal Student Aid 43

Management’s Discussion and Analysis 

Figure 21: Direct Loan Program Net Financing Activity

(Dollars in Billions)

Direct Loan net financing activity (Figure 21) also accounted for most of the overall increase in 

FSA’s outstanding debt level during the same five years. By comparison, in the absence of any 

borrowing for new loan disbursements (Figure 22), FFEL-related debt decreased consistently 

from FY 2018–22. These changes in net financing activity for Direct Loan and FFEL Programs 

reflect the impact of the SAFRA Act on disbursements, interest rate driven loan consolidations, 

and related changes in estimated subsidy costs.

Figure 22: FFEL Loan Program Net Financing Activity

(Dollars in Billions)

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Borrowing $155.3 $137.6 $116.9 $120.0 $162.8

Repayments $(66.2) $(96.1) $(148.9) $(137.9) $(467.6)

Net Change $89.1 $41.5 $(32.0) $(17.9) $(304.8)

($500)

($400)

($300)

($200)

($100)

$0

$100

$200

Direct Loan 

Financing Activity

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Borrowing $0.2 $- $11.0 $1.6 $3.3

Repayments $(9.3) $(12.6) $(16.7) $(12.4) $(14.5)

Net Change $(9.0) $(12.6) $(5.7) $(10.8) $(11.2)

($20)

($15)

($10)

($5)

$0

$5

$10

$15

FFEL 

Financing Activity
44 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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 (i.e., earned) 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.

Figure 23: Composition of Net Cost

(Dollars in Billions)

As shown in Figure 23, FSA’s earned revenues (mainly interest and fee accruals net of subsidy 

amortization) increased from $36.2 billion in FY 2018 to $65.1 billion in FY 2022, an overall 

increase of 79.8% or about 20.0% annually on average. By comparison, FSA’s gross costs 

fluctuated much more widely over the same period, from $71.2 billion in FY 2018 to 

$503.0 billion in FY 2022, mainly as the result of subsidy-related transactions. As a result, net 

costs fluctuated also, most notably increasing 1,151.1% from $35.0 billion reported in FY 2018 

to $437.9 billion in FY 2022. FSA’s FY 2022 total costs exceeded its earned revenues in both 

FY 2021 and FY 2022, but the margin was greater in FY 2022 by $300.2 billion, of which the 

Direct Loan program increase of $291.7 billion was increased by the $9.6 billion increase in 

FFEL net costs and the $1.0 billion decrease in Non-Credit Programs net costs.

For the Direct Loan Program, the $291.7 billion increase in net costs was primarily the result of 

an increase in gross costs ($314.9 billion). Similarly, the $9.6 billion increase in FFEL Program 

net costs was mostly the result of a $11.7 billion increase in gross costs.

Both the FFEL Program and Direct Loan Program are mandatory programs whose costs are

largely driven by Federal borrowing costs, prevailing interest rates, in-school interest benefits for 

borrowers, the costs related to borrower defaults, and loan volume demand. The programs are 

funded by mandatory and indefinite budget authority and therefore do not receive annual 

appropriations. For more details regarding the inherent difficulty of estimating the impact of 

these complex factors, please refer to Note 5. 

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Gross Costs $71.2 $144.9 $171.2 $177.4 $503.0

Earned Revenue $(36.2) $(36.8) $(39.4) $(39.7) $(65.1)

Net Costs $35.0 $108.1 $131.8 $137.7 $437.9

 $(100)

 $-

 $100

 $200

 $300

 $400

 $500

 $600

Cost/(Revenue)
Fiscal Year 2022 Annual Report | Federal Student Aid 45

Management’s Discussion and Analysis 

Statement of Changes in Net Position

The Statement of Changes in Net Position presents those 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, 2022, was $27.7 billion, an increase of $20.1 billion 

compared to the previous September 30, 2021 net position. The difference reflects an increase 

in the cumulative results of operations by the amount of $19.2 billion, from $(28.7) billion in 

FY 2021 to $(9.5) billion in FY 2022, of which $12.1 billion of the increase was related to the 

Direct Loan Program and $7.1 billion was attributable to the FFEL Program. In addition, 

unexpended appropriations increased by $0.9 billion, of which $0.5 billion were attributable to 

the combined Perkins Loan and Grants Programs, with the $0.4 billion increase in Direct Loan 

Program unexpended appropriations accounting for most of the remaining difference.

Statement of Budgetary Resources

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

status or execution of those resources. It also details the composition of the resources and 

shows the amount of 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.

This statement shows that as of September 30, 2022, FSA had $824.4 billion in combined total 

budgetary resources, of which $80.3 billion remained unobligated and unapportioned. This 

compared to $381.0 billion in budgetary resources twelve months earlier of which $39.8 billion 

were unobligated and unapportioned. Overall budgetary resources increased by $443.4 billion 

or 116.3%, primarily as the net result of increases in budgetary resources for the Direct Loan 

Program ($394.4 billion). 

FSA’s Net Outlays after Distributed Offsetting Receipts as of September 30, 2022, were 

$511.2 billion, an increase of $347.0 billion or 211.4% compared to the prior September 30, 

2021 amount of $164.2 billion. The Direct Loan Program accounted for a $320.1 billion 

decrease, with a FFEL increase of $26.3 billion and a $0.6 billion increase attributable to the 

combined Perkins Loan and Grants Programs.

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.
46 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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. This funding expired on September 30, 2021. The Department was able to obligate 

most of the total funding that was provided with approximately $58,000 in an available balance 

that has expired.

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. In FY 2022, FSA obligated 

$16.2 million. This funding expired on September 30, 2022. The Department was able to fully 

obligate the funding that was provided. The American Rescue Plan Act of 2021, which was 

signed into law in March 2021, provided $91.1 million in relief funding. During FY 2022, FSA 

obligated $44.5 million and carried over approximately a remaining $3.7 million of the 

appropriated funds into FY 2023.

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 December 31, 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 is permitted to implement 

the debt relief program or the litigation is resolved. Payments will restart 60 days later. If the 

debt relief program has not been implemented and the litigation has not been resolved by June 

30, 2023 – payments will resume 60 days after that. The Department will notify borrowers 

before payments restart. 
Fiscal Year 2022 Annual Report | Federal Student Aid 47

Management’s Discussion and Analysis 

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 regulations19

FSA is responsible for establishing and maintaining effective internal control over reporting and 

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.

This section also includes information regarding the Department’s compliance with the Debt 

Collection Improvement Act of 1996, as amended by the Digital Accountability and 

Transparency Act of 2014. 

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 2022, 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.

19 Government Accountability Office Standards for Internal Control in the Federal Government, GAO-14-704G, 

September 10, 2014, p.5.
48 Fiscal Year 2022 Annual Report | Federal Student Aid

Management’s Discussion and Analysis 

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 

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. 
Fiscal Year 2022 Annual Report | Federal Student Aid 49

Annual Performance Report 

Annual Performance Report (Unaudited)
50 Fiscal Year 2022 Annual Report | Federal Student Aid

Annual Performance Report 

Overview of the Annual Performance Report

The Annual Performance Report section of the FY 2022 Annual Report provides detailed 

performance information on FSA’s progress in achieving the goals and objectives described in 

the FY 2020–24 Strategic Plan. The subsections of the Annual Performance Report are listed 

and briefly discussed 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 2020–24 Strategic Plan. 

• Performance Results by Strategic Goal: This subsection details the results of 

each overall strategic goal by strategic objective and performance metric. Each

strategic objective provides an overview and a performance summary and 

analysis, including noteworthy progress and focused improvement. Each 

performance metric includes a table that presents five years of data results, 

where available, as well as its current target and results. The performance metric 

section also includes a discussion of the metric definition, data source, and 

performance period. 

• Fiscal Year 2022 Accomplishments of Federal Student Aid: This subsection 

describes additional accomplishments that were not measured by the 

performance metrics 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.
Fiscal Year 2022 Annual Report | Federal Student Aid 51

Annual Performance Report 

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.” Through the 

strategic plan, FSA documents the strategic goals, objectives, and performance metrics of the 

organization. During FY 2022, FSA developed the new FY 2023–27 Strategic Plan to align and 

support the Department’s overall strategic goals and objectives, as defined in the Department’s 

FY 2022–26 Strategic Plan. 

The FSA FY 2022 Annual Report provides a detailed view of the past year’s goals, challenges, 

and accomplishments and serves as a close out of FSA’s FY 2020–24 Strategic Plan. 

The FY 2020-24 strategic goals are: 

• Strategic Goal 1: Empower a High-Performing Organization

• Strategic Goal 2: Provide World-Class Customer Experience to the Students, Parents, 

and Borrowers We Serve

• Strategic Goal 3: Increase Partner Engagement and Oversight Effectiveness

• Strategic Goal 4: Strengthen Data Protection and Cybersecurity Safeguards

• Strategic Goal 5: Enhance the Management and Transparency of the Portfolio

FSA is required, by the PBO-enabling legislation, to report annually its level of performance and 

the associated results. This section, the Annual Performance Report, 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.
52 Fiscal Year 2022 Annual Report | Federal Student Aid

Annual Performance Report 

Performance Results by Strategic Goals, Objectives, 

and Metrics 

In FY 2022, FSA had 38 performance metrics. Of these, 21 metrics were met or exceeded, 9 

metrics performed below the target and 1 metric was baselined or did not have an established 

target. Additionally, 7 metrics were not able to establish a target due to the COVID-19 

administrative forbearance period. 

The following tables present the performance metric results under the applicable FY 2020–24 

Strategic Objective. To read more about performance measurement and metric target changes 

in FY 2022, refer to the Appendices section. 

Table 11: Strategic Goal 1: Empower a High-Performing Organization

Strategic Objective 1.1: Improve employee engagement and workplace inclusion to develop 

and retain talent, improve employee satisfaction, and engage in 

effective succession planning.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

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.

75%-76% 73.0% Not met

Strategic Objective 1.2 Expand employee skills and capabilities to support Next Gen FSA.

Performance Metrics FY 2022

Target

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.

Update and 

maintain Maintained Met

1.2.B Conduct targeted multi-year training based on identified 

workforce needs.

5% increase 

over baseline 

in target 

training

82.0% Met

1.2.C Perform a training analysis at each performance review 

period within the fiscal period.

85.0% average 

course 

satisfaction 

assessment 

rating (SAR) 

per year

97.0% average 

course 

satisfaction 

assessment 

rating (SAR) 

per year

Met
Fiscal Year 2022 Annual Report | Federal Student Aid 53

Annual Performance Report 

Table 12: Strategic Goal 2: Provide a World-Class Customer Experience to the Students, 

Parents, and Borrowers We Serve

Strategic Objective 2.1: Ensure that all students can easily access information on federal 

student aid, apply for federal student aid, and have information on 

repayment options.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

2.1.A Number of visits (sessions) demonstrating adoption of 

the updated StudentAid.gov site. 220.0 million 304.8 million Met

2.1.B Percentage of high school seniors submitting the 

FAFSA. 60.9% 63.0% Met

2.1.C Number of customers submitting the FAFSA via a mobile 

platform—the myStudentAid mobile app or fafsa.gov.

3.0 million 

submissions

2.5 million 

submissions Not met

2.1.D Persistence among first-time filing aid recipients. 81.1% 80.0% Not met

Strategic Objective 2.2: Provide seamless, easy, personalized digital interactions equal with 

top financial institutions in the delivery of financial aid products and 

services.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

2.2.A Number of customers checking loan balances via the 

myStudentAid mobile app. 2.0 million 2.1 million Met

2.2.B Number of borrowers who view their aid summary 

information on StudentAid.gov. 9.2 million 22.6 million Met

2.2.C Number of users of “Aidan”, the StudentAid.gov virtual 

assistant. 1,000,000 1,623,550 Met

2.2.D Transactional email volume for outreach and 

communications to customers. 101.6 million 181.1 million Met

2.2.E Recurring campaign email delivery volume for outreach 

and communications to customers. 35.4 million 49.8 million Met

2.2.F American Customer Satisfaction Index (ACSI) Aid 

Lifecycle Survey score. 72–74 67.8 Not met

2.2.G Customer Satisfaction Survey(s) for StudentAid.gov site 

and associated tools. Baseline 3.6 Baseline
54 Fiscal Year 2022 Annual Report | Federal Student Aid

Annual Performance Report 

Strategic Objective 2.3: Streamline contact center and back-office operations to improve our 

customers’ integrated experience.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

2.3.A Quality Standard for Average Speed to Answer (ASA) at 

all Call Centers.

Equal to or less 

than 60 seconds

334.0

seconds Not met

2.3.B Quality Standard for Abandon Rate (AR) for Incoming 

Calls at all Call Centers.

Equal to or less 

than 2% 10.4% Not met

Strategic Objective 2.4: Simplify the communication and processes associated with borrower 

repayment plans.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

2.4.A Number of borrowers using Make a Payment feature to 

pay student loans. N/A 16,782

payments N/A

2.4.B Percentage of borrowers using auto-debit. N/A N/A N/A

2.4.C Percentage of users who start and complete the Public 

Service Loan Forgiveness (PSLF) Help Tool by 

generating a PSLF form.

34.5% 56.7% Met

Table 13: Strategic Goal 3: Increase Partner Engagement and Oversight Effectiveness

Strategic Objective 3.1: Provide effective oversight of FSA’s partners utilizing a 

comprehensive suite of monitoring tools. 

Performance Metrics FY 2022

Target

FY 2022

Actual Result

3.1.A FSA will annually conduct an Institutional Review for its 

participating partners including schools, third-party 

servicers, and financial institutions.

80.0% 80.0% Met

3.1.B Number of Borrower Defense (BD) applications 

adjudicated (subject to existing BD regulations). 65,000 86,000 Met

Strategic Objective 3.2: Strengthen partner engagement and provide effective outreach and 

assistance.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

3.2.A FSA will measure institutional participation rates in Title 

IV training and specialized technical assistance 

programs.

88.0% 94.0% 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.

10.0% 29.0% Met

3.2.C Ease of doing business with FSA. 75–77% 76.0% Met
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Table 14: Strategic Goal 4: Strengthen Data Protection and Cybersecurity Safeguards

Strategic Objective 4.1: Implement business partner and vendor systems that house, 

manage, and provide systems supporting FSA business processes, 

outreach and awareness focused on oversight, enforcement, 

infrastructure, systems, and data. 

Performance Metrics FY 2022

Target

FY 2022

Actual Result

4.1 Increase partner/vendor cybersecurity effectiveness by 

reducing the total number of FSA system assessment 

findings by 20% per year.

2,240 19,252 Not met

Strategic Objective 4.2: Improve student privacy data and cybersecurity controls of 

Institutions of Higher Education (IHEs) through outreach and 

communication, to mitigate future cyber-incidents and breaches.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

4.2.A Increase Institutions of Higher Education cybersecurity 

effectiveness by reducing GLBA cybersecurity noncompliance by 20% per year.126 94 Met

4.2.B Reduce incident reporting time at Institutions of Higher 

Education. 32.7 days 25.3 days Met

Strategic Objective 4.3: Build an effective cybersecurity culture through employee 

awareness, training and accountability focused on protecting 

systems and data.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

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.

1,152 1,738 Not met

Table 15: Strategic Goal 5: Enhance the Management and Transparency of the Portfolio

Strategic Objective 5.1: Improve the management and transparency of FSA’s student loan 

portfolio performance.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

5.1.A Initiate monthly reporting to the public through the FSA 

data center.

Implement selfservice module 

for reports

Target Not 

met Not met

5.1.B Outstanding Direct Loan Portfolio in Current Repayment 

Status. N/A N/A N/A
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Strategic Objective 5.2: Provide analytics and operational support for a customer-centric, 

data-driven, performance-based organization.

Performance Metrics FY 2022

Target

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 3.0 Met

5.2.B Implementation timeline for FUTURE Act.

Implementation 

of interface 

between IRS and 

FSA, including 

testing and 

performance 

standards

Implemented 

interface 

between IRS 

and FSA; 

development 

ongoing with 

building 5 

new FSA 

systems that 

will receive, 

store, and 

manage FTI

Met

Strategic Objective 5.3: Leverage portfolio analytics to drive improved outcomes for 

customers and taxpayers.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

5.3.A Identify and provide intervention actions for customers at 

risk of default.

Execute default 

prevention 

program—50% 

customer 

engagement

Executed 

default 

prevention 

program at 

full scale

Met

5.3.B Default rate by borrower count. N/A N/A N/A

5.3.C Percent of borrowers > 90 days delinquent. N/A N/A N/A

5.3.D Percentage of borrowers who did not make the first three 

payments. N/A N/A N/A

Strategic Objective 5.4: Increase vendor performance through quality management activities 

centered on customer service and product delivery.

Performance Metrics FY 2022

Target

FY 2022

Actual Result

5.4 Conduct three vendor examinations annually. 3 3 Met
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Understanding the Performance Section

This section presents detailed performance results, which include a thorough discussion of 

progress made to date in achieving the strategic goal and the data used to assess performance.

How to read the performance data included in this section. This section is organized by the 

five strategic goals. For each strategic goal, this section provides an overview of the goal, lists 

the associated objectives that support the strategic goal, and details the metrics used to 

measure performance.

• Table: Identifies the performance metric 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 metric for each fiscal year reported. The 

following is the legend for the performance result indicator included in the table.

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 metric is a new or revised metric and prior year results are not available. – 

Performance result is not applicable. N/A

The performance metric results reported are as of fiscal year-end, September 30, 2022, unless 

otherwise noted. If the required data as of fiscal year-end are not available in time for inclusion 

in this report, data as of the most recent period available are used. Data as of fiscal year-end 

may not be available in some instances, where the required data are obtained from external 

sources including state and private nonprofit GAs, lenders and loan servicers, and grant and 

loan recipients.

• Notes: Identifies trends and data availability.

• Metric Definition: Provides a brief explanation of the metric.

• Data Source: Provides the source of data required to calculate the actual result 

for the performance metric and any calculation required to determine the actual 

result.

• Period of Performance: Indicates the time period of the data reference.
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Strategic Goal 1: Empower a High-Performing Organization

Goal Leader: Director, Executive Services

Table 17: Goal Objectives

Strategic Goal 1: Empower a High-Performing Organization.

Strategic Objective No. Strategic Objective

Strategic Objective 1.1

Improve employee engagement and workplace inclusion to develop 

and retain talent, improve employee satisfaction, and engage in 

effective succession planning.

Strategic Objective 1.2 Expand employee skills and capabilities to support Next Gen FSA.

Goal Spotlight 

For FSA to continue to excel as a high-performing organization and meet the challenges of the 

current environment, it must invest in the knowledge, skills, and abilities of its employees. To 

meet the expectations outlined in the FY 2020–24 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.

FSA has assessed its progress in preparing its workforce using four related metrics under 

Strategic Goal 1. The first metric is derived from the Office of Personnel Management (OPM)

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. FSA focuses 

on key questions centered on employees’ intrinsic work experience, and their relationship with 

supervisors and organizational leaders. These questions are specifically in the Employee 

Engagement Index (EEI) within the FEVS. 

At the onset of the FY 2020-24 Strategic Plan implementation, FSA launched an organizational 

workforce requirements study to provide FSA with the ability to better forecast human capital 

needs and inform planning for staff training, transfers, promotions, and talent acquisition. The 

study, completed in FY 2021, illustrated the connectivity between the competencies for specific 

positions throughout FSA, and the competencies that are available with the individuals in each 

job. By working to close the competency gaps both identified in the study, and through other 

internal observations, FSA has targeted ways to expand organizational skills and capabilities in 

each business area during FY 2021 and beyond. FSA has been successful in supporting 

employee growth through a diverse range of development initiatives and training opportunities. 

In this way, FSA has committed to increase employee performance, engagement, and retention 

using various learning modalities.

To ensure that the commitment to training and development has been beneficial to both the 

organization and the employees throughout FY 2022, FSA measured the effectiveness of this 

work through detailed analysis and evaluation of participants. This analysis has begun to assist
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FSA in measuring organizational capability and performance potential. In addition, the relevant 

existing data has supported internal requests for developmental resources and has allowed 

leadership to evaluate the return on investment these training initiatives have had on the 

organization.
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Strategic Objective 1.1

Improve employee engagement and workplace inclusion to develop and 

retain talent, improve employee satisfaction, and engage in effective 

succession planning.

Overview

FSA remains committed to enabling its organizational success by working towards 

improvements in the provision of resources, staffing, training, and employee work-life balance. 

In conjunction with creating an environment with the appropriate tools and programs for staff, 

FSA is also striving to foster and support a diverse workforce where all employees feel included, 

connected, and engaged in its mission. In FY 2022, FSA completed the FY 2022 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 equity, productivity, and inclusion based on 

the FY 2021 FEVS results. 

The FEVS is a key tool for measuring employee engagement throughout the federal 

government and within FSA. The FY 2021 FEVS results were made available in March 2022 

and FSA Directorates used the data to develop and execute FY 2022 FEVS Employee 

Engagement action plans to engage employees.

FSA employees have utilized enhanced telework, since March 2020, due to the COVID-19 

national emergency. In this remote work setting, FSA has focused on strengthening employee 

communication channels that provide information and promoting connections with colleagues 

and leadership. Communication channels 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’s quarterly 

recognition awards, Public Service Recognition Day, FSA Day, and observances such as 

Constitution Day provided opportunities for employees across the nation to be recognized and 

connected. Additionally, listening sessions provided situational opportunities for employees to 

share concerns, views, and suggestions on time sensitive topics that impact wellness such as 

clarity around telework policy, and civil/racial unrest.

As stated, the leadership within FSA believes that workplace diversity, inclusion, and 

accessibility are necessary for any organization to reach its full potential. FSA has implemented 

programming that is aligned with the President's Executive Order 13985 on Advancing Racial 

Equity and Support for Underserved Communities Through the Federal Government, by hosting 

cultural and diversity observances (e.g., Asian Pacific Islander, Pride Month, COO’s Fitness 

Challenge, Wellness events, etc.) and discussing diversity, inclusion, and accessibility 

strategies in The Source employee newsletter. FSA also again actively participated in the ED 

In Action Annual Summit, sponsored by the ED Diversity and Inclusion Council.

FY 2022 Performance Summary and Analysis

There is one performance metric for this strategic objective. The FY 2022 FEVS survey score 

data, received in December 2022, will be used towards the FY 2023 FEVS Employee 

Engagement Action Plan due to the Department at the end of January 2023. The overall 
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FY 2022 FSA Employee Engagement Index was 73% which is 1% below the FY 2021 FEVS, 

which was received in the second quarter of FY 2022. The goal for Strategic Objective 1.1 is an 

increase in the employee engagement score by 1–2% from the previous FEVS EEI.

Key Successes and Opportunities

To achieve this objective, FSA first implemented an enhanced communication campaign to 

increase employee participation in the FEVS survey. While the participation rate for the 

FY 2021 FEVS survey declined 17 percentage points, from 72% to 55%, versus the FY 2020 

FEVS survey, the EEI strengthened. The COVID-related delay of FY 2021 FEVS 

(November/December, during FSA’s conference and annual holiday season) likely impacted 

participation, as many employees were busy with the FSA Conference and/or took leave during 

the first quarter. The FY 2022 FEVS employee participation rate increased from 55% to 67.9%.

Based on data collected from previous years’ FEVS surveys, focus groups held July through

October, and current year employee engagement action plans, led to notable solutions to 

employee engagement challenges. This data led to the creation of the Leadership Conversation 

series, a redesign of the new employee Onboarding program, monthly employee 

communication with The Source newsletter, and weekly communication with the “In Case You 

Missed It” email campaign. Building on these successful outcomes, and FEVS 2021 data, FSA 

enhanced its employee engagement and communication strategy, adding informal 

conversational opportunities such as fireside chats, virtual team hours, team chats, office hours, 

and Connections Matter.

Succession Planning

FSA launched its first risk-based succession management pilot. FSA, as an organization has an 

over 30% retirement eligibility rate, and this effort was undertaken to set the stage for full 

integration of succession management across FSA in FY 2023. Key objectives of the pilot were 

to:

• Understand the evolving internal and external factors that are driving the rapid 

change in the work environment. 

• Help leadership understand the data analytics associated with workforce 

competency gaps, diversity & inclusion data profile, succession planning, and 

their impact on overall performance.

• Develop action learning plans that address identified skill and competency gaps.

• Create a repeatable process that supervisors and managers can use to evaluate 

talent and enable the development of appropriate contingency, transitional, and 

succession planning strategies.

• Automate initiative processes and develop a web-based platform that allows user 

interface and knowledge management capabilities.

As this was a baseline year for the pilot launch, no data was available, but FSA can report 

success in the following areas: 
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• Successfully educated across the pilot groups management level on what, how, 

and impact of proper succession management, 

• Received complete buy-in from the pilot group’s leadership and management, 

and 

• Successfully integrated human capital data in the pilot group’s decision making 

aiding the business unit in how it views, understands, and makes human capital

decisions.
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Performance Metric 

Performance Metric 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. 

Table 18: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 62.0% 61.0% 70.0% 74.0% 75%–76% 73.0%

Performance Result Not met Met Met Met Not met

Metric Definition: OPM FEVS measures employees' perceptions of whether, and to what extent, 

conditions and characteristics of successful organizations are present in their agencies. The Engagement 

Index 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.

Data Source: FY 2022 FEVS survey.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 1.2

Expand employee skills and capabilities to support Next Gen FSA.

Overview

FY 2021 set the baseline for Strategic Objective 1.2. As a result, FY 2022 was the true litmus 

test for the targets set for various strategic objectives.

For FY 2022, FSA exceeded the 5% increase target set for the fiscal year by training 82% of the 

workforce through internal and external virtual instructor-led, online self-paced, and hybrid 

learning and development initiatives and trainings. Through continued collaborative efforts with 

internal FSA and Department stakeholders and external vendors through learning subscriptions 

and contractual resources, FSA was able to develop the workforce and exceed the FY 2022 

Strategic Objective 1.2 B target by approximately 22% over the outlined target of 67%. In 

addition, out of the 82% of the workforce trained, 22% of those trained were managers. FSA 

also had an average 96% completion rate for Department required trainings for FY 2022 (ED 

Internal Controls, Information Management Requirements, and Cybersecurity and Privacy 

Awareness Training Courses 1-3). Finally, FSA continued to refine its strategic evaluation 

program to analyze the quality and benefits of the developmental opportunities. FSA’s overall 

Satisfaction Assessment Rating (SAR) exceeded the baseline target of 85% for the second year 

in a row by approximately 12% (97.0%).

FY 2022 Performance Summary and Analysis

There are three performance metrics for this strategic objective. All performance metric targets 

were met.

Key Successes and Opportunities

FSA once again capitalized on the virtual instructor-led, online self-paced, and hybrid learning 

formats and delivery methods. According to the data, virtual instructor-led (52%) and online selfpaced training (42%) remained the predominate modalities in which the workforce engaged for 

their learning. For online learning, the workforce engaged in self-paced courses offered in 

FedTalent, the Department’s learning management system (LMS) and online learning 

subscriptions. The courses accessed in FedTalent ranged from FSA recorded or developed 

training to pre-loaded Skillsoft courses offered through the LMS. Regarding virtual instructor-led 

learning, FSA was able to deliver reoccurring and new course offerings. A few new course 

offerings to note are business writing which received funding in FY 2022 after last being offered 

in FY 2018, the A Day in the Life of the Supervisor course which was one of the last classroombased courses to be adapted for the virtual environment, FSA Leadership Institute’s new 

Innovative Leadership course, and the mandatory FSA Merit Systems Principles and Prohibited

Personnel Practices Training for managers (virtual instructor-led and online self-paced).

To better understand FSA’s learning and development needs and provide a more efficient and 

seamless mechanism to gather and analysis data, FSA developed the FSA Training Database. 

Through this vehicle, FSA is now able to further dissect its training data and identify trends to

inform and drive discussions around learning opportunities, including resources, for future fiscal 
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years. It also provides a platform to help enhance FSA’s training evaluation program to continue 

to understand how learning is being assessed and its impact on employee performance.

FSA continued to train its managers and exceeded the number of managers trained by 22% 

over the FY 2021’s percentage. Managers took advantage of both the virtual instructor-led and 

self-paced online trainings. Some of the competency areas that managers focused on in 

FY 2022 were around retirement, financial management, acquisition type topics, professional 

development, compliance, and supervisory courses. Many of the courses or programs delivered 

provided supervisory training credit to assist FSA managers in meeting the Department’s New 

and Experienced Supervisory Requirement Training as per the Department’s Human Capital 

Policy 412-1.

FSA held its third annual Employee Learning Week May 16-20, 2022. The theme for this year’s 

initiative was “The Many Facets of Diversity, Equity, Inclusion and Accessibility” in support of the 

Department’s and FSA’s strategic plan aligned to the President's Executive Order 14035. To 

deliver this major undertaking, FSA collaborated with a wide range of Department and FSA 

stakeholders to educate the workforce on Executive Order 14035 and specific DEIA topics and 

opportunities to improve awareness and workforce performance. The initiative was tremendous 

success, with more than 88 FSA employees participating and 56% being FSA managers. The 

Employee Learning Week also contributed to 18% of FSA’s second quarter training total.

FSA also delivered two non-supervisory leadership development programs in Quarter 2 and 

Quarter 3. In February 2022, FSA graduated 14 participants from the Foundations of Leadership 

Program. This intensive competency-based development program provides high-performing GS 

11-13 or equivalent non-supervisory employees with an opportunity to build self-awareness, 

increase knowledge of FSA programs, engage in problem solving projects and activities, and 

improve competencies necessary for employees to be successful in leadership roles. The 

overall program satisfaction rating was 97%. In April/May 2022, Workforce Development 

Division relaunched the A Day in the Life of a Supervisor course in virtual instructor-led format. 

This highly experiential non-supervisory employee course was one of the last classroom-based 

courses adapted over into the virtual format. A total of 11 employees completed the course and 

the overall course satisfaction rating was 96%.

The Human Capital Group strategized the implementation of strategic workforce planning and 

management as a practice in FSA to allow and ensure that organization has the right people, 

with the right skills, in the right place, and at the right time. The goal of this plan was to 

• Increase of Workforce Planning Maturity for FSA to address short and long-term 

staffing needs, be able to identify and quickly place talent in critical mission 

areas, and to expand staff skills to ensure they can support FSA mission 

requirements.

The Human Capital Group has used this time to develop a baseline that would allow FSA in 

FY 2023 to have a greater use case for increased workforce planning and management 

maturity. This will include: 

• Two-to-three-year workforce plan based on organization’s strategic vision and 

business needs
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• Staffing plan aligned to business strategy and performance goals including 

forecasting needs and active involvement in recruitment

• Identified and developed talent pool for key positions/roles

• Competency-based training and development plan that support mission 

objectives, working with the Workforce Development Division to accomplish

• Continued proactive use of workforce analytics to identify business problems and 

develop mitigation strategies. 
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Performance Metrics

Performance Metric 1.2.A. Identification, validation, assessment, and prioritization of skill 

competencies, required grades, and strategic alignment in accordance with the workforce 

requirements study results.

Table 19: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 58.2% 100.0% Update and

maintain Maintained

Performance Result – – Met Met Met

Note: Data not available prior to FY 2020.

Metric Definition: FSA worked with a consultant to conduct a workforce requirements study of the 

process and drivers (input and output measures) that influence organizational staffing needs. Data was

collected through questionnaires and follow-up interviews with managers and subject matter experts of 

various FSA processes. The study was completed in FY 2021 and illustrated the connectivity between the 

competencies needed for specific positions throughout FSA, and the competencies that are available with 

the individuals in each job. By working to close the competency gaps both identified in the study, and 

through other internal observations, FSA has targeted ways to expand organizational skills and 

capabilities in each business area during FY 2021 and beyond

Data Source: U.S. Department of Interior Business Center Payroll/Personnel Data, qualitative interview, 

and resource information from internal FSA sources.

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 1.2.B. Conduct targeted multi-year training based on identified workforce 

needs.

Table 20: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – – 62.0%

5% increase 

over baseline in 

target training

82.0% 

Performance Result – – – Baseline Met

Note: Data not available prior to FY 2021. This performance metric was revised in FY 2021.

Metric Definition: The metric measures the outcome of the targeted training initiatives launched in 

FY 2021. 

Data Source: FedTalent system, FSA staffing reports, training data reports, participant feedback, course 

attendance and FSA Training Database.

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 1.2.C. Perform a training analysis at each performance review period 

within the fiscal period.

Table 21: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – – 

96.0% average 

course 

satisfaction 

assessment 

rating (SAR) 

per year

85.0% average 

course 

satisfaction 

assessment 

rating (SAR) 

per year

97.0% average 

course 

satisfaction 

assessment 

rating (SAR) 

per year

Performance Result – – – Met Met

Note: Data not available prior to FY 2021. 

Metric Definition: This metric measures average course SAR of attended trainings, to analyze the 

effectiveness of the training or developmental program conducted. 

Data Source: Course evaluations, facilitator observations, FSA’s Training Database, and Momentive 

(formerly called SurveyMonkey).

FY 2022 Period of Performance: October 2021 through September 2022. 
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Strategic Goal 2: Provide World-Class Customer Experience to 

the Students, Parents, and Borrowers We 

Serve

Goal Leader: Deputy Chief Operating Officer, Office of Student Experience and Aid Delivery

Table 22: Goal Objectives

Strategic Goal 2: Provide World-Class Customer Experience to the Students, Parents, 

and Borrowers We Serve.

Strategic Objective No. Strategic Objective

Strategic Objective 2.1

Ensure that all students can easily access information on federal 

student aid, apply for federal student aid, and have information on 

repayment options.

Strategic Objective 2.2

Provide seamless, easy, personalized digital interactions equal with 

top financial institutions in the delivery of financial aid products and 

services. 

Strategic Objective 2.3

Streamline contact center and back-office operations to improve our 

customers’ integrated experience.

Strategic Objective 2.4 Simplify the communication and processes associated with borrower 

repayment plans. 

Goal Spotlight 

Digital and Customer Care (DCC) is a key initiative to drive performance towards achieving the 

strategic goal. Seven significant releases in FY 2022 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 American Customer Satisfaction Index (ACSI) 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 included:

• Redesigned loan entrance and exit counseling, 

• Expanded the Aidan virtual assistant’s availability to the newly integrated FAFSA 

form, enabling users on the FAFSA form to ask Aidan questions, 

• Updated TEACH products and release of new TEACH Grant Conversion 

Counseling based on new regulations,

• Integrated the 2021–22 FAFSA form into StudentAid.gov, and

• Released the 2022–23 FAFSA form.

FSA implemented several key communications within the Marketing Communications Platform 

(MCP). These communications enabled the organization to provide important information to its 
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customers, such as filling out their FAFSA forms and identifying resources within 

StudentAid.gov. 

Strategic Objective 2.1 

Ensure that all students can easily access information on federal student 

aid, apply for federal student aid, and have information on repayment 

options.

Overview

Prior to the DCC and Digital Platform efforts, customers had to navigate numerous FSA 

websites resulting in a disjointed and siloed experience. Leveraging a collaborative approach 

with a focus on human-centered design, the Digital Platform launched an integrated and 

improved StudentAid.gov website in December 2019. StudentAid.gov is FSA's primary 

customer-facing digital front door for students, parents, and borrowers who need be informed 

about, apply for, and manage their federal student aid. For this reason, StudentAid.gov plays a 

critical role in supporting the Department’s and FSA’s strategic goals and priorities. There were 

multiple technology releases in FY 2022 that expanded and improved the features and 

capabilities of StudentAid.gov. While delivering on planned releases and maintaining overall 

site operations, FSA also managed evolving administrative priorities which impacted information 

to be provided to customers while delivering on planned releases and maintaining overall site 

operations. 

Getting students, parents, and counselors around the country focused on increasing 

completions of the FAFSA form for the 2022–23 academic year remains a top priority. 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 America. FSA encouraged high-school seniors and their 

families to complete the 2022–23 FAFSA form. FSA worked with individual states, counselors, 

mentors, and college access professionals on initiatives to improve FAFSA completion rates. 

The organization 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. It is probable that the 

outreach efforts made by FSA and by colleges and universities to students in their freshman 

year were more successful due to COVID-19, as students were more of a captive audience than 

in previous years. 

FY 2022 Performance Summary and Analysis

There are four performance metrics for this strategic objective. Two metrics met the annual 

target, while two metrics did not meet their targets in FY 2022. The 2.1.C metric target was not 

met. Failure to meet this metric target may be attributed, in part, to the retirement of the 

myStudentAid mobile app on June 30, 2022. After June 30, 2022, customers could only 

complete their FAFSA forms via the web, which may have contributed to fewer forms being 

submitted via a mobile platform. 

The 2.1.D metric target was not met. COVID-19 pandemic effects, a tight labor market, rising 

wages, and continued concern over the cost of college and student loan debt are all 
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outweighing efforts by FSA, the Department, and outside organizations to promote persistence. 

These issues, among others, negatively impacted our ability to meet this metric. This past year, 

FSA conducted additional email outreach to first-time FAFSA filers who had not returned to file 

a FAFSA form for the fall of 2022. This outreach was effective and resulted in an increase in 

returning student FAFSA filing. However, the increase was not enough to allow FSA to reach its 

goal, likely due to the impact of the external factors listed above.

Key Successes and Opportunities

Prior to the DCC and Digital Platform, FSA customers had to visit multiple, disconnected 

websites requiring multiple logins to get the information they needed. Inconsistent branding, a 

disjointed user experience, and information siloes made it difficult and confusing for customers 

to find what they were looking for and to take action. To improve customer experience, FSA 

initiated a human-centered focus to understand customer needs through field research, cocreation, and usability testing to inform its Digital Platform launch and continuous improvement. 

This initiative achieved the goal of one holistic DCC Design System with shared components to 

create a consistent user experience across web applications. 

StudentAid.gov supports customers and lets them act throughout the student aid lifecycle.

Because StudentAid.gov is FSA’s primary customer website, it must frequently be adapted to 

meet changing or new priorities. FSA successfully managed these changes and delivered on 

overall site improvements. The releases in FY 2022 have expanded specific capabilities of the 

website. The following are several highlights offered to assist borrowers:

• Integration of the FAFSA form 

• Implementation of the Income-driven Repayment Self Certification flow

To engage with FAFSA filers effectively, FSA sends out emails each year to FAFSA filers who 

filed an application the year before. This year, 49.8 million emails were sent out to filers to 

remind them to file a renewal FAFSA form. These strategies enhanced outreach to local media 

outlets and to key states about the importance of FAFSA filing which positively impacted 

increases in the FAFSA filing results in these areas. Social media outreach continued to be a 

promising method for raising awareness as well. For much of this cycle, FAFSA filing by 

returning filers exceeded rates of filing for this population when compared to the previous year. 
72 Fiscal Year 2022 Annual Report | Federal Student Aid

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Performance Metrics

Performance Metric 2.1.A. Number of visits (sessions) demonstrating adoption of the updated 

StudentAid.gov site.

Table 23: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 44.5 million 183.7 million 217 million 241 million 220.0 million 304.8 million

Performance Result Met Met Met Met Met

Metric Definition: StudentAid.gov is FSA's primary customer-facing digital front door for students, 

parents, and borrowers who need be informed about, apply for, and manage their federal student aid. By 

focusing on total customer visits, this performance metric helps gauge the success of FSA’s efforts to 

become the most trusted and reliable source for accurate student aid information for Americans 

nationwide and engage customers in completing critical tasks related to federal student aid. 

Data Source: FSA’s online platform analytics. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 2.1.B. Percentage of high school seniors submitting the FAFSA.

Table 24: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 67.4% 65.9% 63.8% 60.87% 60.9% 63.0% 

Performance Result Met Not met Not met Not met Met

Metric Definition: A primary goal of FSA is to encourage FAFSA completion among high school seniors.

Data Source: FSA’s online platform analytics.

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 2.1.C. Number of customers submitting the FAFSA via a mobile 

platform—the myStudentAid mobile app or fafsa.gov.

Table 25: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 2.5 million 

submissions

2.5 million 

submissions

3.0 million 

submissions

2.5 million 

submissions

Performance Result – – Met Not met Not met

Note: Data not available prior to FY 2020. The myStudentAid app was retired on June 30, 2022. Data 

related to the mobile app was collected only through this date. 

Metric Definition: This metric measures FAFSA submissions via a mobile device either through the 

FAFSA website or the mobile app to help determine customer interest and engagement in using mobile 

technology to complete online forms. 

Data Source: FSA’s online platform analytics. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 2.1.D. Persistence among first-time filing aid recipients.

Table 26: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 82.5% 82.8% 81.0% 81.1% 81.1% 80.0% 

Performance Result Met Met Not met Met Not met

Note: Formerly 5.1.E in FSA FY 2020 Annual Report.

Metric Definition: This metric helps track performance across one of the desired outcomes of federal 

student aid and its impact on program completion. By following first-time filing aid recipients—such as 

college freshmen or non-traditional students, into their second year—it is possible to see whether FSA is 

making improvements in how applicants are translating the aid that they receive into educational 

persistence 

Data Source: Enterprise Data Warehouse and Analytics (EDWA).

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 2.2 

Provide seamless, easy, personalized digital interactions equal with top 

financial institutions in the delivery of financial aid products and services.

Overview

FSA has been working to continuously improve its digital interactions with customers since it 

initiated this strategic plan, and FY 2022 was a further step in that direction. Aidan, the 

StudentAid.gov virtual assistant, was added to the FAFSA form experience in October 2021. 

Customers can engage with Aidan within the FAFSA form, finding answers to common 

troubleshooting questions, help finding next steps after submission, and help with creating a 

new account on StudentAid.gov. 

As discussed earlier in this report, FSA onboarded several key communications within the MCP

as part of the DCC initiative. These communications enabled FSA to provide important 

information to its customers, such as filling out their FAFSA forms and resources within 

StudentAid.gov. In FY 2022, FSA communicated with its customers via over 230.8 million 

transactional and recurring emails. As a result, FSA believes its customers are more informed

and engaged with the organization. FSA conducted monthly customer listening sessions to 

gather, analyze and report on customer behavior, issues, and feedback, where the organization 

heard directly from customers to inform its work. 

Feedback reviewed came from the following channels: web analytics, complaints, social media,

virtual assistant, knowledge, contact center, outreach, and customer experience surveys. 

Attendees from across the organization participated in monthly customer listening meetings, 

which helps to build understanding and facilitate improvements in response to findings. As a 

result of this effort, dozens of improvement tickets were created, and business process 

improvements were made in response to customer listening findings. FSA also implemented a

customer feedback management tool during FY 2022. This new tool provides multiple new 

sources of customer feedback via surveys on StudentAid.gov, after interacting with a BPO call 

center, and within our email campaigns. The tool includes robust reporting and artificial 

intelligence-driven text analytics, which allows FSA to better analyze customer feedback and 

information to improve processes in expedited timeframes

FY 2022 Performance Summary and Analysis

There are seven performance metrics for this strategic objective. Five metrics met their annual 

targets, one metric was baselined, and one metric did not meet its annual target in FY 2022. 

The target for the metric 2.2.F was not met. The contributing factor for the target not being met 

is mostly attributed to the score drop to the borrowers surveyed as part of the Multiple Servicer 

Survey (MSS) associated with loan servicers. Some reasons for the MSS survey score drop 

include large-scale loan transfers between servicers, the survey including previously excluded 

borrowers, and the uncertainty around the loan payment pause and widescale loan forgiveness. 

The MSS survey accounts for a major part of FSA’s weighted ACSI, so if that score drops, it 

impacts FSA’s ACSI score. The FAFSA survey and In-School survey (drawn from federal 

student aid recipients) are also calculated within the ACSI score. The FAFSA survey dropped a 

few points from FY 2021, and the In-School survey had a steady score, but these surveys 

account for less of the total weighted ACSI score.
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Key Successes and Opportunities

FSA launched the myStudentAid mobile app in October 2018 to provide students and families 

with another option to submit the FAFSA form. However, customers have demonstrated that 

they prefer to go to StudentAid.gov on a mobile device rather than use the myStudentAid 

mobile app. Additionally, FSA saw a continuing trend with students and parents visiting 

StudentAid.gov on a phone, instead of a desktop computer. The website is mobile-responsive, 

so the site’s webpages fit the screen size and shape of any device, including desktop or laptop 

computers and mobile devices (e.g., phones and tablets). As a result, the mobile app was 

retired on June 30, 2022.

StudentAid.gov is FSA's primary customer-facing digital front door for students, parents, and 

borrowers who need to be informed about, apply for, and manage their federal student aid. FSA 

has continued to see steady growth in customers viewing their aid information on 

StudentAid.gov. When the administrative forbearance period ends, and the Administration’s 

Student Loan Debt Relief Plan was enacted, FSA anticipates an increase in customers logging 

in to view their aid information, and borrower exploration of repayment options.

Aidan, the StudentAid.gov virtual assistant, was added to the FAFSA form experience in 

October 2022. Customers can engage with Aidan within the FAFSA form. With these new users 

generating additional data, the strategy to continue analyzing customer data to drive 

improvements with content directly based on customer feedback.

The Annual Student Loan Acknowledgment (the Acknowledgment) was developed to provide 

customers who are planning to accept a federal student loan with important information on 

borrowing, and their responsibility to repay the loan. The borrowers’ experience is customized 

based on whether they are a new borrower or have current loans. In May 2021, FSA redesigned 

the Acknowledgment to improve the customer experience based on user feedback and best 

practices. A new landing page provides customers with three options for a more personalized 

experience: (1) undergraduate student, (2) graduate student, and (3) parent of an 

undergraduate student. It was redesigned to present information in smaller, easy-to-understand 

learning modules. Additionally, the Acknowledgment was made available on the myStudentAid 

mobile app.

The MCP, as previously discussed, sent over 230.8 million emails in FY 2022 to students, 

parents, and borrowers. Delivery rates and brand recognition/authority continue to be key pillars 

that FSA looks out for as it continues to scale and deliver more emails via the tool. FSA is 

ensuring that data integrations and loading processes, as well as the internet protocol (IP) 

addresses for sending emails, are performing at optimal levels. As part of the DCC initiative, 

FSA has continued to onboard several key communications within the MCP. These 

communications are critical for users as they contain information related to important actions the 

users need to take on FSA products. Examples of communications that we have onboarded 

include FAFSA and the PSLF Help Tool. 

In the last six months, FSA has focused on continuing to update existing communications and 

onboarding new communications within our platform. We have updated FAFSA communications 

and have added new communications and functionality related to Multi-Factor Authentication, 

which allows users to secure their account. We have also worked on onboarding 

communications related to Third Party Debt Relief (TPDR), allowing us to provide targeted 

communications related to suspicious activity on users’ accounts and giving users notice to 
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update their login info for increased security. These communications enabled FSA to provide 

important information to its customers, such as filling out their FAFSA forms and resources 

within StudentAid.gov. These campaigns included FAFSA renewal campaigns (Winter and 

Fall), as well as upcoming communications that are automated based on certain behavioral 

criteria determined by FSA and resources. The biggest challenges were the number of email 

campaigns FSA was sending during the fiscal year along with increasing capacity on the 

platform. Thus, FSA increased the number of servers available for the platform which in turn 

increased the number of emails it can send out.

FSA conducted several improvements to include revamping email templates, improving data 

integrations between MCP and systems, as well as testing and optimization efforts to 

continuously improve its email communications for its borrowers. The testing and optimization 

efforts, and revamped template designs, have led to notable improvements to FSA’s 

engagement such as higher open and click rates. In addition, we have ramped up and stood up 

efforts with Medallia, a survey platform which allows us to receive real time feedback on our 

email communications. We have created a module for Medallia and have begun to incorporate 

this into our communications. This real time feedback provides us with the insights to 

continuously improve our communications and help to prioritize work related to improvements. 

The revamped templates allowed the emails to match the brand and styling of StudentAid.gov

and FSA, which enabled more trust and consistency as a trusted source of information. FSA’s 

priority is to continue onboarded communications within the MCP for transactional and recurring 

campaigns, update data integrations within the MCP to ensure faster data loading and 

execution, and additional data analysis to evaluate and improve communications based on past 

performance and industry benchmarks.

FSA recognized that more external communication is preferable so that its customers are up to 

date with clear and actionable next steps. Several processes are in place to ensure that the 

organization is sending all emails in an efficient manner:

• Monitoring of the data files, via internal alerts, within the system to make sure 

FSA is receiving the correct files for its transactional and campaign data loads.

• A team set up to monitor the IPs to make sure that FSA is aware of them being 

blacklisted to ensure that the organization solves it as soon as possible.

• Ramp-up plans for high volume campaigns to warm the IPs up for delivery and 

reduce volume load on the servers. 

Proactive monitoring of high priority campaigns, as well as the development of a health 

dashboard for the transactional campaigns are some ways of reducing risk from a delivery 

perspective. Continuing to develop and improve emails based on industry best standards and 

design best practices ensure that the organization is reducing the risk on its brand integrity for 

its communications.

The implementation of a customer feedback management software platform and OMB Circular 

A-11 compliant surveys were key organizational initiatives that supported this strategic objective 

in FY 2022. The customer feedback management platform and Circular A-11 surveys were 

implemented in November 2021. Results are available in real-time and deep dive analyses of 

survey data are done quarterly for each channel. The platform includes artificial intelligencedriven text analytics that allows FSA to more easily mine feedback for trends and escalate any 
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feedback that warrants action. The procurement of a customer feedback management software 

platform greatly expands FSA’s capacity to both offer surveys across channels, and better 

analyze structured and unstructured feedback from customers. By putting in this work up-front 

and dedicating resources to improve it over time, FSA will be automating the analysis of 

unstructured feedback to get deeper, more relevant insight on customer sentiment, desires, and 

pain points from their open-ended survey feedback.
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Performance Metrics

Performance Metric 2.2.A. Number of customers checking loan balances via the myStudentAid 

mobile app.

Table 27: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 133,417 1.6 million 2.0 million 2.1 million

Performance Result – – Met Met Met

Note: Data not available prior to FY 2020. The myStudentAid mobile app was retired on June 30, 2022. 

Data related to the mobile app was collected only through this date.

Metric Definition: This metric gauges customer engagement in using the myStudentAid app to view their 

current aid information. With the improved myStudentAid app, customers can view their loan 

information within the mobile app.

Data Source: FSA’s online platform analytics.

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 2.2.B. Number of borrowers who view their aid summary information on 

StudentAid.gov.

Table 28: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 7.6 million 13.10 million 9.2 million 22.6 million

Performance Result – – Baseline Met Met

Note: Data not available prior to FY 2020. 

Metric Definition: This metric gauges customer engagement in using StudentAid.gov to view their 

current aid information. In February 2020, the Aid Summary feature was delivered on StudentAid.gov

providing customers with access to summary and detailed aid information such as loan balances or Pell 

Grant dollars received. 

Data Source: FSA’s online platform analytics.

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 2.2.C. Number of users of “Aidan”, the StudentAid.gov virtual assistant.

Table 29: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 545,763 1,566,488 1,000,000 1,623,550 

Performance 

Result – – Met Met Met

Note: Data not available prior to FY 2020. 

Metric Definition: To provide increased self-service options for students, families, and borrowers, this 

metric helps tracks Aidan’s usage. Aidan is a virtual assistant that uses advanced technology—artificial 

intelligence and natural language processing—to answer the most common questions on federal student 

aid. Whether customers want to find out about their current loan account balances, learn more about 

grants, make a payment (pilot), or get help contacting their loan servicer, Aidan is available to help them 

find an answer.

Data Source: FSA’s online platform analytics. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 2.2.D. Transactional email volume for outreach and communications to 

customers.

Table 30: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 92.2 million 189.7 million 101.6 million 181.1 million

Performance Result – – Baseline Met Met

Note: Data not available prior to FY 2020. This performance metric was revised in FY 2021. 

Metric Definition: This metric measures the transactional emails that are delivered through the internal 

communications tool. These emails are vital for students, parents, and borrowers to understand updates 

and notifications regarding their FAFSA application and other important information that needs to be 

acted on. This metric helps to gauge the health of the email communications and platform in terms of 

volume and reach. 

Data Source: MCP.

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 2.2.E. Recurring campaign email delivery volume for outreach and 

communications to customers.

Table 31: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 32.2 million 41.7 million 35.4 million 49.8 million

Performance Result – – Baseline Met Met

Note: Data not available prior to FY 2020. This performance metric was revised in FY 2021. 

Metric Definition: This metric measures the recurring emails that are delivered through the internal 

communications tool. Recurring campaigns are defined as communications that FSA sends on a 

consistent cadence that are not tied to immediate transactional interactions and have a yearly 

precedence, such as the Renewal campaign reminders. This metric helps to gauge the commitment to 

consistent and proactive communications. 

Data Source: MCP. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 2.2.F. American Customer Satisfaction Index (ACSI) Aid Lifecycle Survey 

score.

Table 32: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 70.6 70.0 73.5 71.4 72–74 67.8

Performance Result Met Met Met Not met Not met

Metric Definition: This metric provides a measure of the customer experience across the student aid 

lifecycle, by accessing customer satisfaction scores from FAFSA filers, from persons enrolled in or 

attending a post-secondary educational institution, and from borrowers repaying their loans. 

Data Source: MSS, FAFSA.gov (housed on StudentAid.gov), and (federal student aid recipients) InSchool customer satisfaction survey. 

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 2.2.G. Customer Satisfaction Survey(s) for StudentAid.gov site and 

associated tools.

Table 33: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – No survey 

developed

Developed 

Survey Baseline 3.6

Performance Result – – Not met Not met Baseline

Note: Data not available prior to FY 2020. 

Metric Definition: This metric intends to measure customer satisfaction with the StudentAid.gov

website. These customer satisfaction surveys will assist FSA in developing additional tools and offering 

website improvements based on customer feedback.

Data Source: FSA customer feedback system.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 2.3 

Streamline contact center and back-office operations to improve our 

customers’ integrated experience.

Overview

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 and loan servicing 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 first step 

towards positive outcomes in this area is for loan servicers to provide prompt responses to 

incoming calls and expedited resolutions of questions. In FY 2022, FSA focused on mitigating 

risks for servicer operations, as it prepares to return millions of borrowers to repayment. This 

planning has led to the development of call center tools, technologies, and training to support 

the efficient management of future call volume. As programmatic and policy decisions are made 

and impact on this objective becomes clear, FSA will direct operational measures to 

continuously improve call center performance.

FY 2022 Performance Summary and Analysis

There are two performance metrics for this strategic objective. Neither metric was met. In 

FY 2022, loan servicers reacted to numerous programmatic changes while posturing for the 

return of borrowers to repayment. Multiple extensions of the payment pause, coupled with 

several major student loan program announcements, forced loan servicers to pay careful 

attention to call center performance to meet expected customer service levels. In addition to 

extensions of the payment pause in FY 2022, announcements of the Limited PSLF Waiver in 

October 2021, and of Student Loan Debt Relief in August 2022, caused significant disruption in 

call volume, impacting overall performance. Without these two programs, servicer performance 

was in line with stated performance metrics.

Key Successes and Opportunities

Initiatives continue in supporting these performance metrics heading into FY 2023 that were put 

in place in FY 2022. One specific area is that FSA loan servicers are now contractually required 

to achieve a 4% abandon rate. Additionally, FSA continues to analyze loan servicer capabilities, 

identify areas for improvement, and work with servicers to implement action plans to address 

areas of concern. Broadly, since March 2020, call volumes have been significantly lower across 

most loan servicers due to the payment pause except for call volumes that impact the servicer 

who handles the PSLF program or that volume that results based upon large programmatic 

announcements. In FY 2023, FSA will take positive action in preparing loan servicers for the 

expected increase in incoming calls based upon impact of debt relief and the return to 

repayment.
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Performance Metrics

Performance Metric 2.3.A. Quality Standard for Average Speed to Answer (ASA) at all Call 

Centers.

Table 34: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 59.0 24.0 

seconds

Equal to or 

less than 

60 seconds

334.0

seconds

Performance Result – – Met Met Not met

Note: Data not available prior to FY 2020. 

Metric Definition: The goal of this metric is to ensure FSA’s loan servicing vendors (Not-For-Profits 

(NFPs) and Title IV Additional Servicers (TIVAS)) are providing the best customer service to FSA’s 

borrowers. One way that this is measured is through the Average Speed to Answer rate. This is the 

average number of seconds it takes a borrower to speak with a customer service representative from the 

moment a borrower calls to the time a customer service representative answers the call. A higher ASA 

indicates a longer wait time and may result in a higher call abandon rate or increased call frustration.

Data Source: Federal servicers’ quarterly reports. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 2.3.B. Quality Standard for Abandon Rate (AR) for Incoming Calls at all 

Call Centers.

Table 35: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 3.6% 0.9% Equal to or 

less than 2% 10.4% 

Performance Result – – Not met Met Not met

Note: Data not available prior to FY 2020.

Metric Definition: The goal of this metric is to ensure the loan servicing vendors (NFPs and TIVAS) are 

providing the best customer service to borrowers. One way that this is measured is through the Annual 

Report. This is the average number of calls in which a borrower hangs up (abandons) the call before they 

speak with a customer service representative. The higher the rate the more borrowers are abandoning a 

call and likely not getting the information/answers they need. 

Data Source: Federal servicers’ quarterly reports.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 2.4 

Simplify the communication and processes associated with borrower

repayment plans.

Overview

The DCC initiative is the foundational plan for simplifying communication and processes

associated with borrower repayment plans and supports the performance metrics utilized for this

strategic objective.

FY 2022 Performance Summary and Analysis

There are three performance metrics for this strategic objective. One metric did not have a

target due to the administrative forbearance period and a second metric did not have data at the 

time of publication. The third metric met its target.

The 2.4.B metric which captures the percentage of borrowers using the auto-debit feature for

loan repayment could not be measured due to the CARES Act, which required the Department

to automatically suspend payments on eligible student loans since March 13, 2020. FSA, as

well as its Loan Servicers, will continue to promote auto-debit and other benefits (i.e., Income

Driven Repayment) through its various methods of borrower communications as customers

move out of the CARES Act forbearance status and back into repayment.

Key Successes and Opportunities

Due to the unpredictability of the borrowers in repayment that continued to be impacted by the 

administrative forbearance, no formal target for the Make a Payment metric was set for

FY 2022.

The administrative forbearance period has changed borrower behavior and may impact them in 

using auto-debit to make payments in the future. To respond to this potential behavioral change 

and to confirm that existing auto debit customers want to continue with automatic payments,

FSA and its loan servicers have launched a coordinated engagement plan to encourage

borrowers to sign-up or retain auto-debit arrangements. 

Limited PSLF Waiver: In early October 2021, the Department announced a change to the 

PSLF program rules for a limited time. Utilizing the Health and Economic Recovery Omnibus

Emergency Solution Act (HEROES Act), the “limited PSLF waiver” refers to the time-limited

policy changes to PSLF Program rules that allow borrowers to receive credit for past periods of

repayment that would otherwise not qualify for PSLF. After the announcement in October 2021,

FSA worked across the organization and with its PSLF servicer, FedLoan Servicing and later,

MOHELA, to implement these policy changes throughout FY 2022. Additionally, FSA was able 

to quickly update the PSLF Help Tool in November 2021, to support the flexibilities offered

under the limited PSLF waiver. As of mid-August 2022, approximately $15 billion has been

forgiven under the limited PSLF waiver for more than 233,000 borrowers. There has also been

more than $394 million issued in refunds of borrower payments. In addition to borrowers who 

have received forgiveness, more than 1 million borrower accounts have received payment count

increases. 
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Further, in FY 2022, FSA engaged in a multi-channel communications campaign with targeted

emails, organic social media, paid digital ads, webinars, and SMS messages. 

Reconsideration Request Process: On October 13, 2021, the Department entered into a 

settlement agreement with the American Federation of Teachers AFL-CIO, which included a

requirement for the Department to establish an interim reconsideration process for PSLF by

April 2022. FSA did not previously have a PSLF reconsideration process until April 2022. The

Department has formalized the permanent reconsideration process in the final regulations

published on November 1, 2022. 

In March 2022, FSA released an online tool for borrowers to submit reconsideration requests for

PSLF and Temporary Expanded PSLF (TEPSLF) to support the interim reconsideration 

process. Additionally, FSA developed standard operating procedures, implemented a customer

relationship management tool, and cross-trained FSA staff to review and process the

reconsideration requests. 

PSLF Employer Search: As part of the DCC Release 5.7, FSA released the PSLF Employer 

Search in July 2022. This look-up functionality allows borrowers to search employers to verify

eligibility for PSLF and does not require login with an FSAID. The PSLF Employer Search also 

helps support borrowers who may benefit from the Limited PSLF Waiver by providing them with 

the ability to review their employer’s eligibility prior to taking steps to consolidate their loans or

complete a Public Service Loan Forgiveness (PSLF) & Temporary Expanded PSLF (TEPSLF)

Certification & Application (PSLF form).
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Performance Metrics

Performance Metric 2.4.A. Number of borrowers using Make a Payment feature to pay student 

loans.

Table 36: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 12,245 

payments

22,366 

payments N/A 16,782

payments

Performance Result – – Met N/A N/A

Note: Data not available prior to FY 2020. 

Metric Definition: This metric gauges customer interest and engagement in using StudentAid.gov to 

make a student loan payment. In February 2020, the Make a Payment pilot was delivered on 

StudentAid.gov providing customers with loans serviced by Great Lakes or Nelnet (both FSA loan 

servicers) with the ability to make a standard loan payment on StudentAid.gov.

Data Source: DCC Web Logs. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 2.4.B. Percentage of borrowers using auto-debit.

Table 37: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 24.8% N/A N/A N/A

Performance Result – – Baseline N/A N/A

Note: Data not available prior to FY 2020.

Metric Definition: This metric measures the volume of borrowers that are enrolled in auto-debit. Autodebit allows borrowers to pay their student loan payments without any effort since the payment is 

extracted from the borrower's financial institution each time a payment is due, allowing borrowers to make 

payments in full and on time with minimal effort required. Borrowers who enroll in auto-debit are given a 

0.25% reduction on their interest rate.

Data Source: National Student Loan Data System (NSLDS®) database. 

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 2.4.C. Percentage of users who start and complete the Public Service 

Loan Forgiveness (PSLF) Help Tool by generating a PSLF form.

Table 38: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – – 34.5% 34.5% 56.7% 

Performance Result – – – Baseline Met

Note: Data not available prior to FY 2021. This performance metric was revised in FY 2021.

Metric Definition: The metric tracks borrowers who begin the process of the PSLF Help Tool and start a 

PSLF form and compares it to those who complete the process by generating a PDF of the PSLF form.

Data Source: Common Origination and Disbursement (COD) Portal.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Goal 3: Increase Partner Engagement and Oversight 

Effectiveness

Goal Leader: Deputy Chief Operating Officer, Office of Partner Participation and Oversight

Table 39: Goal Objectives

Strategic Goal 3: Increase Partner Engagement and Oversight Effectiveness.

Strategic Objective No. Strategic Objective

Strategic Objective 3.1 Provide effective oversight of FSA’s partners utilizing a

comprehensive suite of monitoring tools.

Strategic Objective 3.2 Strengthen partner engagement and provide effective outreach and 

assistance.

Goal Spotlight 

Strategic Goal 3 is focused on how FSA will assist schools, third-party servicers, and financial 

institutions to deliver federal student aid, collect borrower payments seamlessly, and safeguard 

data integrity through oversight and monitoring. FSA will also ensure these institutions 

understand and comply with Title IV requirements and other relevant laws, policies, and 

procedures.

FSA has gauged its performance in these areas using five metrics. The Office of Partner 

Participation and Oversight (PPO) uses a comprehensive suite of monitoring tools to ensure 

schools appropriately administer Title IV student financial aid by conducting comprehensive 

compliance reviews for certification actions, deficient audit resolutions, flagged financial 

statements, program reviews, method of payment actions, and technical assistance. 

Additionally, FSA is committed to continued enhancements in oversight and improving the 

borrower experience by reducing institutional fraud. An outcome of this effort is demonstrated by 

the tactical approach for application processing FSA has taken in borrower defense, which has 

afforded the organization significant progress in resolving the outstanding applications.

Strategic Goal 3 also highlights FSA’s responsibility for providing high quality training products 

and technical assistance services to IHEs, third-party servicers, auditors and participating 

school business officers through a comprehensive online training system, the FSA Training 

Center (fsatraining.ed.gov). FSA also supports training, outreach, and executive engagement 

through national, regional, and state level conferences along with focused support for MSIs and 

under-resourced institutions. 

FSA has been responsive in relief efforts for schools through its communications, such as postdisaster emails, which offered key reminders and information on the special resources available 

to schools and individuals that were impacted by natural disasters. 
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Strategic Objective 3.1 

Provide effective oversight of FSA’s partners utilizing a comprehensive 

suite of monitoring tools.

Overview

PPO performs oversight using a holistic suite of monitoring tools, including comprehensive 

compliance reviews to ensure a case management approach. FSA is also proactively working to 

prevent and address institutional fraud through oversight, compliance, and enforcement actions, 

including through the establishment of a stand-alone Office of Enforcement, which includes the 

Borrower Defense Group (BDG), Investigations Group, Administrative Actions and Appeals 

Service Group, and the Resolution and Referral Management Group.

PPO continues to mature existing performance reporting dashboards and develop new data 

dashboards to empower employees, managers, and senior leaders to make data-driven 

decisions. During the COVID-19 national emergency, PPO had to adapt the compliance review 

process to be conducted virtually. These adapted processes and innovations will be assessed 

for future incorporation and to improve efficiency.

Borrower defense is a type of loan discharge based on a determination that the borrower’s 

school engaged in certain acts or omissions, generally misrepresentations, fraud, or breach of 

contract that unlawfully caused the borrower to enroll or continue enrollment at the school. FSA 

is committed to protecting students and borrowers by forgiving of their student loan obligations 

after conducing legal research and analysis of borrower defense claims. FSA is managing the 

borrower defense application process and successfully rebuilt and substantially improved 

collaboration with external partners to support the borrower defense fact-finding process. 

Process and technology enhancements have also led to improved information sharing with 

borrower defense applicants, and FSA continues to look for improvements to the borrower 

defense process.

FY 2022 Performance Summary and Analysis

There are two performance metrics for this strategic objective. Both performance metric targets 

were met. 

Key Successes and Opportunities

PPO has successfully and consistently met and exceeded annual target goals for Strategic 

Objective 3.1.A. At the end of FY 2022, the School Eligibility and Oversight Service Group 

(SEOSG) completed 4,819 comprehensive compliance reviews for 6,020 Title IV participating 

partners (80.0%); meeting the annual target goal of 80%. PPO looks forwards to maintaining its 

record of success in achieving new strategic objectives upon the release of a new five-year 

performance plan for FY 2023–27 replacing the current FY 2020–24 Strategic Plan. 

The targets associated with borrower defense were met due to improved collaboration with 

external partners to support the fact-finding process and a commitment by FSA leadership to 

establish group findings where possible. BDG’s workflow is heavily influenced by external 
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factors including pending litigation, a shifting regulatory framework, and policy implementations. 

However, the staff continues to adapt to and overcome these factors. 

In FY 2022, BDG finalized additional findings of fact and conclusions of law and successfully 

proposed multiple groups of borrowers for group discharge while simultaneously adjudicating 

individual cases in a timely manner. As a result, FSA was able to adjudicate over 86,000

individual applications since October 1, 2021 — exceeding the goal of 65,000.
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Performance Metrics

Performance Metric 3.1.A. FSA will annually conduct an Institutional Review for its 

participating partners including schools, third-party servicers, and financial institutions.

Table 40: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 

51% of 

partners 

reviewed

62.6% 80.0% 80.0% 

Performance Result – – Met Met Met

Note: Data not available prior to FY 2020.

Metric Definition: This metric measures the performance of holistic comprehensive compliance reviews 

of institutions relating to certification actions, deficient audit resolutions, flagged financial statements, 

program reviews, method of payment actions, and technical assistance

Data Source: Postsecondary Education Participants System (PEPS).

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 3.1.B. Number of Borrower Defense (BD) applications adjudicated 

(subject to existing BD regulations).

Table 41: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 160,000 65,500 65,000 86,000

Performance Result – – Met Met Met

Note: Data not available prior to FY 2020.

Metric Definition: Borrower defense is a type of federal student loan forgiveness where borrowers may 

be eligible for forgiveness of their federal student loans if the relevant school attended misled the 

borrower or engaged in other misconduct in violation of certain laws. FY 2022 actual adjudications include 

claims approved through individual adjudication or as part of an approved group claim where the 

Department had received an individual application from a borrower for the school for which the borrower 

received the discharge. FY 2022 actual adjudications does not include applications adjudicated through 

the group process for Westwood borrowers who submitted an application against Westwood. The 

numbers also don’t include discharges provided by the Department using its settlement and compromise 

authority but based on information gathered through the borrower defense process such as Corinthian. 

The Department is currently in the process of identifying these borrowers, and this data will be included in 

FY 2023. 

Data Source: Customer Engagement Management System

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 3.2 

Strengthen partner engagement and provide effective outreach and 

assistance.

Overview

FSA has experienced an unprecedented demand for training and support resources due to 

legislatively driven regulatory and policy changes. FSA provides 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 2022 saw a small 

return to in-person technical assistance site visits and a significantly increased use of webinars 

and training delivered via the FSA Training Center (fsatraining.ed.gov). 

Additional training and outreach resources are focused on MSIs and under-resourced 

institutions and IHE Presidential leadership events. Technical assistance is also provided 

through the Ask-a-Fed service, Partner Connect/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 or staffing to attend the FSATC, state and regional conferences, and the 

statutorily mandated Fundamentals of Title IV Training. In the virtual environment, the 

attendance at FSA events increased significantly. This metric is highlighted particularly in the 

number of FSA Training Center users, which was 20,749 unique users, and in the 2021 FSATC

(FY 2022 Q1), which hosted more than 15,000 participants in its second virtual session and 

resolved more than 2,000 individual technical assistance inquiries.

FSA conducted its annual “Ease of Doing Business” survey with its Title IV eligible school 

partners, which is also tracked under this objective. The FY 2022 Ease of Doing Business score 

is an overall measure of post-secondary educational institution financial aid administrators’ 

assessment of their recent experience interacting with FSA (and its contractors). These 

interactions include telephone, email, chat, and fax communication regarding FSA’s systems 

and products, and interactions with FSA’s policy, training, compliance, and operations staff. The 

survey is conducted by CFI Group, an independent third-party survey company, and the results 

are provided to the Department and FSA.

FY 2022 Performance Summary and Analysis

There are three performance metrics for this strategic objective. All performance metric annual 

targets were met. 

Key Successes and Opportunities

In FY 2022, 94% of all Title IV eligible institutions participated in training programs or technical 

assistance. The increase in participation is the result of the methodology used to provide 

information. Information was provided through training and technical assistance, delivered in a

virtual format. The virtual environment continues to allow efficiencies in cost and time, and 
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alleviates staffing barriers to institutional participation in training. The flexibility that the virtual 

engagement provided FSA is illustrated in the following accomplishments:

• The FSA Training Center (fsatraining.ed.gov) provided training and technical 

assistance to 20,000 unique users. The Ease of Doing Business Survey 

respondents rated the ease of using the FSA Training center at 76 in its first 

appearance on the survey.

• The Training and Information Services Group (TISG) provided training to over 

15,000 school partners via the Wednesday Webinar series, Regional 

Conferences, congressionally-mandated Fundamentals of Title IV training 

sessions and other outreach events.

• The Conference Management Group conducted FSA’s second FSATC with over 

15,000 participants in attendance.

Despites the staffing shortfall, FY 2022 showed improved success over FY 2021.

At the end of FY 2022, there were 413 modules, which was 29% more than FY 2021. The 

courses focused on the proper administration of Title IV programs with offerings that addressed

the learning needs of new financial aid office staff through senior institutional leadership.
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Performance Metrics 

Performance Metric 3.2.A. FSA will measure institutional participation rates in Title IV training 

and specialized technical assistance programs.

Table 42: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – – 88.0% 88.0% 94.0% 

Performance Result – – – Baseline Met

Note: Data not available prior to FY 2021. This performance metric was revised in FY 2021.

Metric Definition: Training and technical assistance for this metric is provided and tracked at the 

individual learner level and tied to their school’s Office of Postsecondary Education Identification number 

(OPEID). As a target, professionals (individual learners) from participating schools will receive outreach 

and assistance, through self-directed learning modules on the FSA Training Center (fsatraining.ed.gov), 

congressionally-mandated training, the annual FSATC, monthly FSA-led Webinars, regional professional 

association conferences, Ask-a-Fed queries for individualized technical assistance, and systems-oriented 

job aids. For the performance period, the majority of training and outreach activities were conducted 

virtually using Webinar technology as well as via the FSA Training Center.

Data Source: FSA Learning Management System (LMS), PEPS, eZ-Audit, PCnet, FSA Data Center, and 

NSLDS database.

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 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.

Table 43: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 62.0% 18.0% 10.0% 29.0% 

Performance Result – – Baseline Met Met

Note: Data not available prior to FY 2020.

Metric Definition: This metric represents enhancements to the FSA LMS—specifically, additional 

courses created in FY 2022. It is not only a percentage of self-service courses available— for example, in 

FY 2021, FSA had 320 modules of training content available. At end of FY 2022, there are 413 modules, 

which is 29% more than FY 2021. The courses focus on the proper administration of Title IV programs 

with offerings that address the learning needs of new financial aid office staff through senior institutional 

leadership.

Data Source: FSA LMS.

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 3.2.C. Ease of doing business with FSA.

Table 44: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 74.5% 74.0% 71.0% 75.0% 75.0–77.0% 76.0% 

Performance Result Met Met Not met Met Met

Metric Definition: FSA conducts an annual “Ease of Doing Business” survey with its Title IV eligible 

school partners. The survey is conducted by CFI Group, an independent third-party survey company, and 

the results are provided to the Department and FSA. The FY 2022 Ease of Doing Business Score is an 

overall measure of post-secondary educational institution financial aid administrators’ assessment of their 

recent experience interacting with FSA (and its contractors). These interactions include telephone, email, 

chat, and fax communication regarding FSA’s systems and products, and interactions with FSA’s policy, 

training, compliance, and operations staff.

Data Source: FY 2022 Schools Partners Survey.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Goal 4: Strengthen Data Protection and Cybersecurity 

Safeguards

Goal Leader: Chief Information Officer, Enterprise Technology Directorate

Table 45: Goal Objectives

Strategic Goal 4: Strengthen Data Protection and Cybersecurity Safeguards.

Strategic Objective No. Strategic Objective

Strategic Objective 4.1

Implement business partner and vendor systems that house, 

manage, and provide systems supporting FSA business processes, 

outreach and awareness focused on oversight, enforcement, 

infrastructure, systems, and data.

Strategic Objective 4.2

Improve student privacy data and cybersecurity controls of 

Institutions of Higher Education (IHEs) through outreach and 

communication, to mitigate future cyber-incidents and breaches.

Strategic Objective 4.3

Build an effective cybersecurity culture through employee 

awareness, training and accountability focused on protecting 

systems and data.

Goal Spotlight 

FSA is committed to continuous cybersecurity improvement through active partner, employee, 

and IHE, engagement. This has led to process improvements in FY 2022 that provide more 

visibility into identified cybersecurity and vulnerability risks for each of these systems. This 

allows FSA management the ability to view and assess system cybersecurity risks on a near 

real-time basis.

Throughout the fiscal year, FSA engaged with 400 schools to inform, collaborate, and improve 

the security for the protection of Title IV data, to ensure these institutions took the necessary 

actions needed to protect this shared information. This engagement has led to improvements in 

outcomes, reduction of risk, and impacted cybersecurity and student data privacy. This 

highlights FSA’s focus on improving the protection of Title IV data through increased

collaboration with all Title IV participating institutions and third-party servicers.
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Strategic Objective 4.1 

Implement business partner and vendor systems that house, manage, and 

provide systems supporting FSA business processes, outreach and 

awareness focused on oversight, enforcement, infrastructure, systems, 

and data.

Overview

The focus of this strategic objective is on FSA's efforts to increase support for partner 

institutions and coordination with vendors to provide improved cybersecurity services. This 

metric measures how well information systems are securely maintained, and how risks 

associated with compromises and breaches of sensitive information are controlled. This 

includes systems and services provided by the loan servicers — TIVAS and NFPs, ongoing 

Next Gen FSA initiative, and the existing legacy information systems.

While the Department’s vulnerability management policy allows vulnerabilities to be closed 

within a specified timeframe based on the criticality of the vulnerability before a Plan of Action 

and Milestones (POAMs) is required, FSA implemented a more stringent process that requires 

all known vulnerabilities and findings be documented as POAMs immediately upon 

identification. This approach ensures visibility of the true security posture and risks associated 

with it across all levels of FSA management. It also encourages vendors to complete fixes in a 

timely manner due to more oversight from all levels of FSA management. This helps to ensure 

that FSA systems become more secure in a timelier manner.

FY 2022 Performance Summary and Analysis

There is one performance measure for this strategic objective. Due to increased Federal 

mandates (Executive Orders and Binding Operational Directives) and new information systems, 

FSA did not meet its annual target on this metric. In FY 2022 there were an increased number 

of business and partner systems enrolled in programs that provided a more real-time view of 

ongoing system security postures, i.e., Continuous Diagnostics and Mitigation (CDM), and 

ongoing security authorizations). Subsequently, FSA discovered a higher number of security 

findings with systems leading to a higher number of plans of action and milestone being 

created. Although the target was not met, the immediate identification of these issues affords 

FSA the opportunity to develop strategies to resolve them, and not allow any system to go 

unfixed and be susceptible to a potential breach in the future. This strategic objective received 

significant attention and the systems are safer, but the metric was not an effective measure 

based on the unanticipated actions and systems development that occurred during the year. 

Key Successes and Opportunities

The performance measure under this strategic objective is to increase partner/vendor 

cybersecurity effectiveness by reducing the total number of FSA system assessment findings by 

20% per year. The increased number of systems enrolled and participating in the Ongoing 

Security Authorization program ensured that FSA had a closer to real time view of the 

maintenance of cybersecurity requirements implemented at the systems. The Ongoing Security 

Authorization is an assessment program that supports the Authorities to Operate (ATO). 
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Additionally, for new systems being developed, ATOs were being granted for shorter durations 

and with strict stipulations that must be met to maintain that ATO in the future.

The key challenges facing this objective were to address the barriers to fully implement 

mitigating strategies and achieve expected targets, including updating contract language, 

communicating new or evolving cybersecurity laws and federal requirements, and creating more 

visibility into the real-time security posture of third-party service providers. FSA launched the 

following initiatives to respond to these challenges: 

• New cybersecurity standards and regulatory compliance requirements increased 

the scope of the threat landscape and the compliance requirements. 

• Enrolled third party service providers in the CDM program, 

• Added specific cybersecurity requirements language in contracts for all new 

systems and updated language in contracts for existing systems, and

• Ensured the appropriate number of subject matter experts support the 

cybersecurity of FSA systems.

All activities were completed in accordance with the requirements of Executive Order 14028, 

Improving the Nation’s Cybersecurity. The success of the information systems to manage risk is 

reflected in the Department's Cybersecurity Risk Framework Scorecard.
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Performance Metric

Performance Metric 4.1. Increase partner/vendor cybersecurity effectiveness by reducing the 

total number of FSA system assessment findings by 20% per year.

Table 46: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 3,561 3,976 2,240 19,252

Performance Result – – Not met Not met Not met

Note: Data not available prior to FY 2020.

Metric Definition: This metric measures the number of findings discovered during security control 

assessments, including ongoing security authorization activities, that are indicative of potential cyber 

security issues leading to a breach of privacy information or the potential compromise of an information 

system.

Data Source: FSA Enterprise Cybersecurity Group, Department Cybersecurity Assessment and 

Management Shared Service.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 4.2 

Improve student privacy data and cybersecurity controls of Institutions of 

Higher Education (IHEs) through outreach and communication, to mitigate 

future cyber-incidents and breaches.

Overview

To improve student privacy data and cybersecurity controls of IHEs, FSA’s strategy for 2022 

was contacting IHEs and working with them to establish Corrective Action Plans (CAPs) to 

ensure compliance objectives were achieved. FSA’s strategy and operations have proven 

effective and have led to notable improvements in outcomes and risk reductions, which will 

impact cybersecurity and student data privacy now and in the future. 

Faster remediation reduces the scope of the incident, improves student privacy and 

cybersecurity controls, demonstrating stronger data protection and cybersecurity safeguards. To 

support faster remediation, FSA provided Electronic Announcements and collaborated with 

IHEs to promote the protection of student data and ensure schools appropriately safeguard 

information. FSA implemented several actions to effectively communicate cybersecurity 

information for IHEs to enhance their cybersecurity posture, resulting in improved relationships 

with IHEs, support their efforts to safeguard information, and a better understanding of the 

overall cybersecurity posture of IHEs within the education sector. 

FSA’s future improvements to the current strategies include: 

• Deployment of information technology systems to improve interaction with IHEs. 

These improvements will provide better quality of service, enhance metrics, 

support trend analysis, and facilitate more effective communications. 

• Compliance with the Federal Trade Commission’s “Final Rule” amending the 

Standards for Safeguarding Customer Information, through formulating strategic 

and operational improvements to the Gramm-Leach-Bliley Act (GLBA) program 

in FY 2023. 

• Work with OGC and OUS to determine appropriate guidance for IHEs to support 

safeguarding of Federal Tax Information disseminated to IHEs as a result of the 

FUTURE Act. 

Collaboration with industry partners, Cybersecurity and Infrastructure Security Agency, and 

IHEs to assist IHEs in improving their cybersecurity posture. 

FY 2022 Performance Summary and Analysis

There are two performance metrics for this strategic objective. Both metrics met their annual 

targets in FY 2022.

Key Successes and Opportunities

FSA collaborates with IHEs to ensure CAPs are in place to address GLBA Audit noncompliance and encourage IHEs to resolve compliance objectives. FSA’s strategy for 2022 was 
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to contact schools, inform them of the GLBA requirements, and track their progress as FSA 

collaborates with them on CAPs. Risk has been reduced with each cybersecurity requirement 

met and each CAP achieved. Since October 2022, FSA has worked through the backlog of past 

year’s audits and collaborated with 282 schools to bring into compliance.

FSA’s strategy and operations have proven effective and have led to notable improvements in 

outcomes and risk reductions, which will impact cybersecurity and student data privacy now and 

in the future. The well-known increase in cybersecurity breaches, ransomware attacks, and 

supply-chain attacks are external factors beyond the scope of agency efforts which significantly 

increased the magnitude of the problem being addressed. 

The goal of performance metric 4.2.B is to reduce incident reporting time at IHEs. FSA provides 

Electronic Announcements and collaborates with IHEs to promote the protection of student data 

and ensure schools appropriately safeguard information. Topics include ransomware, 

compromised credentials, and data sanitization practices. In FY 2022, FSA implemented 

several actions to effectively communicate cybersecurity information for IHEs to enhance their 

cybersecurity posture, as follows:

• Published six Electronic Announcements to the Partner Connect Knowledge 

Center informing institutions of cybersecurity advisories and announcements

• Provided technical assistance to 49 IHEs in response to breach incidents to 

cybersecurity safeguards

• Conducted 21 outreach engagements and activities regarding data privacy and 

information technology security guidance for IHEs

• Launched 2 cyber threat alert campaigns targeting 64 Title IV institutions 

• Established new Quarterly Cybersecurity Newsletter

As a result, FSA improved relationships with IHEs, supported their efforts to safeguard 

information, and gained a better understanding of the overall cybersecurity posture of IHEs 

within the education sector. To improve outcomes and communication, FSA is growing its 

contact database of IHE Chief Information Officers, Chief Information Security Officers, 

Information Technology (IT) Directors, and Compliance Officers through internal and external 

list acquisition.
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Performance Metrics

Performance Metric 4.2.A. Increase Institutions of Higher Education cybersecurity 

effectiveness by reducing GLBA cybersecurity non-compliance by 20% per year.

Table 47: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 177 126 126 94

Performance Result – – Baseline Met Met

Note: Data not available prior to FY 2020.

Metric Definition: This performance metric measures FSA’s effectiveness in reducing GLBA 

cybersecurity non-compliance at IHEs. FY 2020 was the first year that IHEs were required to comply with 

cybersecurity metrics as part of GLBA annual audits of institutions.

Data Source: The record of GLBA Audits managed by Partner Connect.

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 4.2.B. Reduce incident reporting time at Institutions of Higher Education.

Table 48: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 87.5 days 32.7 days 32.7 days 25.3 days

Performance Result – – Baseline Met Met

Note: Data not available prior to FY 2020.

Metric Definition: The target is an indicator of a school's ability to discover potential privacy breaches or 

cybersecurity incidents, which may impact Title IV student or financial information, and report them as 

required per their agreements. 

Data Source: Self-reports from the schools, discovery through media reports, and information derived 

from internet research activities.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 4.3 

Build an effective cybersecurity culture through employee awareness, 

training and accountability focused on protecting systems and data.

Overview

As cybercrime becomes more lucrative, the probability of cyber-attacks against FSA assets and 

employees will increase. It is important to understand the short-term and long-term effects 

cyberattacks can have against FSA’s business and develop a proactive strategy to deal with 

threat actors. FSA’s goal is to promote strong cybersecurity awareness among its employees 

and contractors, as well as provide information on how to avoid phishing emails and other scam 

tactics. In FY 2022 FSA educated staff on cyber threats faced and the importance of following 

procedures correctly. 

In addition, FSA and the Department invested in situational awareness training. Overall, 

employees are becoming more aware when dealing with situations related to cybersecurity. PII 

incidents between FY 2021 and 2022 while still not meeting objectives the results are showing 

improvement of awareness. While training helps to mitigate some threats, human error is also a 

factor needing mitigation. Human errors can be reduced by consistently improving safety nets 

through well documented processes and investing in comprehensive Data Leakage Prevention 

(DLP) security strategy and solutions.

FY 2022 Performance Summary and Analysis

FSA did not meet its annual FY 2022 target because the original reference set in FY 2020 was 

not based on actual data. Per prior recommendations FSA must adjust its target now that we 

have a baseline. The metric includes DLP of PII leakage blocked by automation, and Security 

Operations (SecOps) tickets due to employees failing to properly handle PII information. In 

FY 2022, the number of DLP incidents dropped 34% as compared to prior year. This drop is a 

significant improvement and positive indicator that FSA users are becoming more aware of 

cybersecurity and steps they can take to avoid becoming the weakest link. FSA plans to revise 

its measurement to introduce a more realistic approach to track this strategic objective. This 

revised approach is to reflect ongoing changes in the environment, deployment of new tools to 

detect issues with PII, and the need to fine tune policies defining configuration of those tools.

Key Successes and Opportunities

FSA collaborated with the Department to ensure Cybersecurity Awareness Training was 

provided to FSA. The collaboration extended into tracking employee performance during 

phishing exercises, and monitoring DLP metrics and Sec Ops tickets related to PII. FSA 

continuously promoted a culture of cybersecurity in its workplace, including training employees 

about safe online computing, emphasizing strong passwords, and placing a particular emphasis 

on tricks related to social engineering. In addition to the 34% drop in DLP incidents as 

compared to prior year, the organization demonstrated positive resilience in multiple phishing 

exercises, which means more users consistently reported the phishing as compared to 

susceptible users. For example, simulated phishing exercise number 6 was sent to 2,196 FSA 

users email accounts belonging to the Department. These email addresses included 1,355
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employees and 841 contractors. 2,091 of 2,196 (95.2%) network users successfully passed the 

exercise run in August 2022; FSA’s target was 90% pass or higher. 

In addition, situational awareness was emphasized across the employee base to minimize 

cybersecurity incidents. Throughout FY 2023 FSA will continue sending out helpful articles 

covering the latest type of threat, results of phishing exercises, useful tips, and discussing 

cybersecurity during all-employee meetings. FSA will also remind employees they are the first 

line of cyber defense and that they are essential to ensuring the confidentiality of sensitive 

business data. Overall, employees are becoming more aware when dealing with situations 

related to cybersecurity, and the approach to strengthening employee decision-making will 

expand through similar efforts in the next fiscal year.
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Performance Metrics 

Performance Metric 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.

Table 49: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 1,713 2,642 1,152 1,738

Performance Result – – Met Not met Not met

Note: Data not available prior to FY 2020.

Metric Definition: The target is an indicator of employees’ ability to properly oversee, store and distribute 

sensitive privacy and financial information. The actual result includes DLP of PII leakage, and SecOps 

tickets due to employee failing to properly handle PII information.

Data Source: FSA SecOps, email reports, phishing exercise results, and Office of the Chief Information 

Officer (OCIO) Data Loss Prevention (DLP) metrics.

FY 2022 Period of Performance: October 2021 through August 2022.
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Strategic Goal 5: Enhance the Management and Transparency 

of the Portfolio

Goal Leader: Deputy Chief Operating Officer, Office of Strategic Measures and Outcomes

Table 50: Goal Objectives

Strategic Goal 5: Enhance the Management and Transparency of the Portfolio.

Strategic Objective No. Strategic Objective

Strategic Objective 5.1 Improve the management and transparency of FSA’s student loan 

portfolio performance.

Strategic Objective 5.2 Provide analytics and operational support for a customer-centric, 

data-driven, performance-based organization.

Strategic Objective 5.3 Leverage portfolio analytics to drive improved outcomes for 

customers and taxpayers.

Strategic Objective 5.4 Increase vendor performance through quality management activities 

centered on customer service and product delivery.

Goal Spotlight 

The COVID-19 emergency and the relief efforts that FSA immediately implemented have made

a significant impact on FSA’s business partners, customers, and the overall student loan

program. During FY 2022 FSA has worked to interpret the changes in the environment and their

effects on the performance measurements within Goal 5. With the federal student loan portfolio

currently surpassing $1.6 trillion, FSA fully understands its fiduciary responsibility to effectively 

manage the successful student loan debt relief for the millions of borrowers it serves.

FSA has been consistent in its evolution to become a customer-centric and outcome-based

organization. FSA will be successful by aiding borrowers in making informed decisions that

lessen the burden of debt associated with their education, while maintaining the appropriate

access to aid for students and families. This effort has required enhanced analytic, risk

management, performance management, and quality management capabilities to provide better

outcomes for students and greater value to taxpayers. 

The insights gained from the work performed in these areas over the past year will help FSA

inform policymakers and taxpayers about the risks and opportunities in the portfolio. This

information is also helping to direct both operational and stakeholder interventions, support

resource allocation, guide customer-centric decisions, and inform legislative or regulatory

changes that will allow for better overall portfolio performance.
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Strategic Objective 5.1

Improve the management and transparency of FSA’s student loan portfolio 

performance.

Overview

The FSA Data Center, launched in FY 2009, is the public, online repository of information about 

the federal student aid programs. The FSA Data Center regularly publishes more than 70 data 

sets to help internal and external stakeholders understand the impact of the Title IV programs. 

These efforts offer stakeholders timely, accurate and repeatable data reporting which are 

updated on a monthly, quarterly, or annual basis. By proactively offering access to the 

information on-line, the FSA Data Center provides transparency into the FSA student portfolio 

while offering stakeholders the opportunity to self-serve to data about the Title IV programs. 

Over the last few years, the FSA Data Center has initiated an effort to foster even greater 

transparency on its website: by replacing static, discrete Excel spreadsheets with a more 

interactive tool that allows for greater customization for stakeholders looking to interact with 

FSA’s data. This year, FSA deployed new data visualization software in its internal environment 

to support these efforts.

In addition to the proactive data posted to the FSA Data Center, FSA also receives hundreds of 

specific data requests each year from interested stakeholders. These requests come from a 

variety of sources, including media, congressional, researchers, and other stakeholders. Since 

FY 2013, FSA has utilized a cross-organizational team of data subject matter experts to fulfill 

and independently validate these requests. FSA expects that some of these annual data 

requests can potentially be addressed with the implementation of an interactive, self-service 

dashboard. FSA utilizes these requests to inform future releases to the FSA Data Center. For 

example, with the introduction of the limited PSLF waiver this year, FSA started publishing a 

new monthly report on the FSA Data Center to track how many borrowers had been approved 

for PSLF under the limited waiver.

The ongoing impact of the COVID emergency continued to present challenges in meeting the 

metrics set forth in this objective. For example, the mandatory administrative forbearance 

associated with the CARES Act legislation, also referred to as the payment pause, was again 

extended several times during the fiscal year. As a result, most borrowers who were actively 

repaying their loans have had their loans in a forbearance status since March 2020. As the 

return to repayment is initiated in FY 2023, FSA will continue to monitor changes in borrower 

behavior and repayment trends to support the Department with data and analysis to manage the 

student loan programs in the most efficient manner. Additionally, FSA has developed dedicated 

methods to monitor the unique circumstances of the early months when the return to repayment 

program begins. 

FY 2022 Performance Summary and Analysis

There are two performance metrics for this strategic objective. One metric did not meet its 

annual target while the other metric could not provide representative data. Metric 5.1.A did not 

meet its target to release a self-service module on the FSA Data Center website due to delays

in implementing the data visualization software in its warehouse environment. Metric, 5.1.B has 
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an actual result of 100% because it focuses on active repayment. However, during the COVID19 emergency, this metric has not generated representative or useful results, as the data is 

inconsequential due to the millions of borrowers currently in an administrative forbearance 

status. While this metric showed seven years of improvement prior to the pandemic, it will need 

to undergo a baseline assessment during FY 2023 and/or FY 2024, which will be used to set 

targets for future years.

Key Successes and Opportunities

In 2022, the Enterprise Data Directorate (EDD) within FSA deployed a new data visualization 

software in its enterprise data warehouse in preparation for launching a more robust self-service 

module to continue to expand and improve the FSA Data Center in alignment with stakeholder 

needs. Since the deployment of the visualization software in August 2022, FSA staff has been 

testing the self-service module and assessing the necessary steps to deploy the module on the 

website. In addition to continuing ongoing testing, FSA must secure funding for enterprise 

licensing to deploy the tool on the website.

While preparing the self-service module for external release, FSA has simultaneously taken 

steps to train FSA staff to assist with the FSA Data Center reporting to reduce the timeline it 

takes for creating the monthly and quarterly reports. As a result, subject matter experts within 

FSA have more time to analyze and understand the impact of the data prior to submitting the 

data reports to agency clearance, and reports get published on the website more quickly.

During FY 2022, EDD participated in implementing the PSLF Limited Waiver, Income-Driven 

Repayment (IDR) Waiver, debt relief, bulk BD discharges, and closed school discharges by 

identifying borrowers and calculating impacts. This work included participating in scoping the 

borrower outreach as well as modeling options for implementation. EDD also refined the reports 

that will be run each month for return to repayment that it had begun developing during 

FY 2020–21 and partnered with other FSA offices and external vendors on leveraging data for 

borrower outreach campaigns. Additionally, EDD is participating operationally via FSA’s 

targeted early delinquency intervention and always-on outreach campaigns. Transitioning 

28 million forbearance borrowers into Active Repayment during the January 2023 timeframe will 

pose a significant operational and logistical challenge to FSA and, from a data standpoint, it will 

increase the difficulty to forecast expectations associated with the current performance metrics 

under this strategic objective.

To mitigate the impact of these changes on the analysis of performance, EDD consults with 

teams such as FSA Risk Management and the Loan Servicing to incorporate operational 

timelines and enhancements into analysis of the data These collaboration efforts will also help 

FSA to re-baseline metrics related to repayment, delinquency, and default after the return to 

repayment period begins. Several offices, including EDD, will have additional temporary metrics 

monitoring the return to repayment that can provide additional perspective for metrics such as 

5.1.B Outstanding Direct Loan Portfolio in Current Repayment Status. 
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Performance Metrics

Performance Metric 5.1.A. Initiate monthly reporting to the public through the FSA data center.

Table 51: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 56

Reports 

Standardized 

and Pilot 

Completed

Implement 

self-service 

module for 

reports

Target not met

Performance Result – – Met Met Not met

Note: Data not available prior to FY 2020.

Metric Definition: This metric has a target to implement a self-service module for reports on the FSA 

Data Center website in FY 2022. While the self-service module was deployed internally in FSA’s 

environment in August 2022, this delay in implementation had an impact on the external rollout of the selfservice module. Following the internal implementation, FSA staff began conducting extensive testing of 

the self-service module which must occur prior to public release. Following the internal deployment, FSA 

also must now take additional steps to secure funding to support enterprise licensing for use of the 

module on the FSA Data Center website. These additional steps could not be completed by the 

September 2022 deadline. 

Data Source: FSA data request process and queries. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 5.1.B. Outstanding Direct Loan Portfolio in Current Repayment Status.

Table 52: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 86.5% 86.7% 93.7% 100.0% N/A N/A

Performance Result Met Met Baseline N/A N/A

Metric Definition: During the COVID-19 emergency, this metric has not generated representative or 

useful results, as the data is inconsequential due to the millions of borrowers currently in an 

administrative forbearance status. This metric demonstrates an increase or decrease in the percentage of 

FSA loan portfolio dollars in a current repayment status. Current Repayment is defined as the percentage 

of Direct Loan principal and interest identified as being in an “active repayment” status. For this metric, 

loans are defined as being in “active repayment status” if they are current repayment or delinquent and 

being serviced by a non-default servicer. Active Repayment does not include periods when payments are 

temporarily suspended (in school/grace or deferment/forbearance), and if they have not been identified as 

being in non-defaulted bankruptcy, at the default servicer or otherwise excluded (e.g., due to a TPD 

determination). Direct Loans are further categorized as being “Current” if no more than 30 days have 

passed since the last payment due date.

Data Source: NSLDS database. 

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 5.2 

Provide analytics and operational support for a customer-centric, datadriven, performance-based organization.

Overview

FSA has been consistent in its evolution to become a customer-centric and outcome-based

organization. FSA will be successful by aiding borrowers in making informed decisions that

lessen the burden of debt associated with their education while maintaining the appropriate

access to aid for students and families. This effort has required enhanced analytic, risk

management, performance management, and quality management capabilities to provide better

outcomes for students and greater value to taxpayers.

The insights gained from the work performed in these areas over the past year will help FSA 

inform policymakers and taxpayers about the risks and opportunities in the portfolio. This 

information is also helping to direct both operational and stakeholder interventions, support

resource allocation, guide customer-centric decisions, and inform legislative or regulatory 

changes that will allow for better overall portfolio performance.

FY 2022 Performance Summary and Analysis

There are two performance metrics for this strategic objective. Both performance metrics met 

their annual indicator targets.

Key Successes and Opportunities

FSA’s goal is to continually evolve the organization to be risk intelligent, where leadership 

continually demonstrates a strong commitment to risk management and uses risk in decisionmaking. Additionally, a risk-intelligent organization uses risk identification and assessment 

methodologies, tools, and templates that are standardized, understood, and used throughout 

the organization. Inclusive within this framework, performance is measured against strategic 

goals and linked to risk and key risk indicators. In FY 2022, the ERM team continued to provide 

enhanced training, tools, templates, and reports to increase the connection between risk, 

strategy, and performance. These enhanced products helped FSA to better manage risk across 

the enterprise and continue to move toward becoming a more risk-intelligent organization. Some 

specific examples of ERM’s accomplishments in support of this performance metric include:

• Reconstituted the Enterprise Risk Management Committee representing 

collaboration across FSA to understand its enterprise risks. Reestablished 

Enterprise Risk Portfolio reporting and monitoring of FSA’s highest risks. 

• Completed risk assessments, risk-based decision documents, and risk alerts to 

assist FSA in better understanding and managing risk to implement significant 

initiatives (e.g., FUTURE Act, FAFSA Simplification Act, Next Gen, Return to 

Repayment, Debt Relief).

• Worked with key stakeholders across FSA to identify key risks and mitigation 

activities for all five of FSA’s strategic objectives, identified key risk indicators, 
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and created corresponding dashboard reports to show both qualitative and 

quantitative risk information.

• Worked collaboratively with FSA and Department stakeholders during the 

conduct of more than 20 FSA audits and 9 non-FSA audits. Tracked and 

managed closing evidence for 16 audits across FSA. 

• Successfully transitioned the OIG fraud referral process to BPO vendors 
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Performance Metrics 

Performance Metric 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.

Table 53: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 1.6 2.5 3.0 3.0

Performance Result – – Met Met Met

Note: Data not available prior to FY 2020.

Metric Definition: The overall target for FY 2022 is to move the organization from Fragmented to a more 

Integrated organization where leadership understands the importance of risk management and considers 

it in decision-making. In addition, the metric will move in a positive direction as risk discussions are more 

structured and occur at varying degrees relating to strategy setting. In an integrated organization, most 

risks are aligned to strategies, and risk appetite is formally defined and discussed as part of daily 

decision-making by senior leadership.

Data Source: Stakeholders surveys and ERM Maturity Matrix. 

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 5.2.B. Implementation timeline for FUTURE Act. 

Table 54: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – N/A

Developed 

FAFSA & 

TPD 

Simulators, 

and the FADDX 

interface

connection 

with the IRS

Implementation 

of interface 

between IRS 

and FSA, 

including testing 

and 

performance 

standards

Implemented 

interface 

between IRS 

and FSA; 

development 

ongoing with 

building 5 

new FSA 

systems that 

will receive, 

store, and 

manage FTI

Performance Result – – N/A Met Met

Note: Data not available prior to FY 2020.

Metric Definition: The FUTURE Act was enacted on December 19, 2019. This law allows the Internal 

Revenue Service (IRS) to disclose certain FTI to the Department for the purposes of providing 

recertification of income for income-contingent or income-based repayments of student loans; 

determining discharges of loans based on TPD; and determining the amount of student financial aid 

under the HEA. 

The implementation of the FUTURE Act requires numerous systems changes and security upgrades in 

FSA to comply with both IRS security requirements and the provisions of the Act itself. FSA is working 

closely with more than 100 stakeholders and 15 offices from the Department, the IRS, and Treasury to 

implement the FUTURE Act. 

In addition to implementing the FUTURE Act Direct Data Exchange (FA-DDX) interface with the IRS, FSA 

is in the process of developing new applications and infrastructure that will manage and store FTI. These 

new systems include 

• the FTI Infrastructure, a secure cloud environment that will host the applications that 

manage and store FTI; 

• the FTI Module, an application that will leverage FTI to determine continued eligibility for 

TPD, calculate IDR monthly payment amounts, and calculate the Student Aid Index;

• the FTI Data Mart, an application that will leverage FTI to conduct analyses and forecasts 

related to the TPD, IDR, and FSA programs;

• the FTI Student Aid Internet Gateway, a mailbox that will securely deliver Institutional 

Student Information Records to more than 5,000 schools, state agencies, and 

scholarship organizations; and

• the Safeguards, a combination of operational changes and changes to existing systems 

(e.g., creation of training modules) that will ensure FSA and the Department is properly 

protecting federal tax information and complying with applicable Internal Revenue Code 

(IRC) statutory requirements

FSA plans to continue making progress towards implementing the FUTURE Act in FY 2023.

Data Source: N/A

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 5.3 

Leverage portfolio analytics to drive improved outcomes for customers and 

taxpayers.

Overview

FSA has developed, implemented, and maintained data-driven projects used in performing and 

optimizing customer communications and other customer-level interventions that improve 

customer outcomes and prevent fraud.

The purpose of objective 5.3 is to highlight FSA’s focus on providing data-driven analytics to 

support borrower decision-making and to 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 have been in operation throughout FY 2022. The Origination & Disbursement 

Default Risk model and “always-on” email campaign began in the summer 2021 and have 

continued 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. 

The COVID-19 emergency and the CARES Act’s relief benefits to borrowers with Department 

managed loans have impacted results for several performance metrics under this objective 

throughout FY 2022. Virtually 0% of Direct Loans in active repayment as of the end of 

September 2022 are delinquent, for the reasons discussed in Strategic Objective 5.1. In 

addition, new Direct Loans have been originated since March 2020. Loans that reached the end 

of the grace period during the COVID-19 emergency quickly moved to forbearance after 

entering repayment; similarly, loans that re-enter active repayment during the pandemic from an 

in-school deferment moved to forbearance. Currently, approximately 400,000 borrowers have 

asked that their servicers move their loans out of forbearance and into repayment. Should the 

borrowers subsequently become delinquent in their payments, servicers move these loans back 

to forbearance. However, borrower payments from Department-serviced borrowers during the 

pandemic have been received from those whose loans are in forbearance.

FSA has developed a detailed communication plan to remind borrowers of their obligation to 

resume payments after the payment pause. The organization is also working with oversight 

agencies and loan servicers to implement strategies to monitor the progress of returning and 

keeping loans in repayment after the administrative forbearance period ends.

FY 2022 Performance Summary and Analysis

There are four performance metrics for this strategic objective. Only one metric met its annual 

target as the other three metrics did not generate representative results due to the COVID-19 

emergency. Two of these metrics, Default rate by borrower count and Percent of borrowers >
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90-days delinquent, are at 0% because there were no active repayment data to report. Even 

though both of these two metrics showed five and seven years of improvement respectively 

prior to the pandemic, they will need to undergo a baseline re-assessment during FY 2023 

and/or FY 2024, to set targets for future years. The third affected metric, Percentage of 

borrowers who did not make the first three payments, was a new measure in the FY 2020–24 

Strategic Plan. While this measure showed promising trends for the three years prior to the 

pandemic, the metric had never been baselined and FSA will need to develop annual targets.

Key Successes and Opportunities

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 their 

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 an 

estimated one billion dollars in fraudulent disbursements. Similarly, FSA has developed models 

to help protect the integrity of the debt relief implementation through targeted income verification 

selection.

During different stages of the student aid lifecycle, such as application, disbursement, and 

repayment, different types of interventions are beneficial. In FY 2022, several examples, where 

FSA has used analytics to positively impact borrowers, including using modeling to protect FSA 

against fraudulent actors. In one example, the California mass application scheme, which first 

emerged in autumn 2021, has been an unprecedented attack on our systems; however, the 

development and implementation of a model to deny aid to fraudsters have protected more than 

$1 billion of disbursements to date. 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 266,000 borrowers with a total outstanding loan balance of more than 

$7.4 billion. Specific fraud detection models include:

• Default at Risk Application model allowed FSA to contact 4.6 million applicants 

through email, always-on and notification interventions including during FY 2022. 

• Default at Risk Origination and Disbursement model facilitated FSA in 

communications to 2.1 million borrowers during FY 2022, including both alwayson and notification interventions. 

Other modeling initiatives EDD has been working on include modeling data in preparation for 

the return to repayment. Specifically, the team worked on the targeted early delinquency 

intervention campaign that will reach out to at-risk borrowers who either miss a payment or 

successfully make a payment. The team has also been investigating the best time of day to 

send messages to different customers to increase the likelihood that they will receive, open and 

act on emails. Other model initiatives include: 

• Debt Relief initiative model is being developed by imputing borrower incomes, 

eligibility, and aid to be forgiven. 
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• Multiple school modeling efforts include Annual Risk Assessment (for planning of 

program reviews), Closed School, an Enforcement model, and a student 

outcome. 
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Performance Metrics

Performance Metric 5.3.A. Identify and provide intervention actions for customers at risk of 

default.

Table 55: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – 

Developed, 

tested, and 

deployed 

two 

projects

Developed, 

tested, and 

deployed 

two 

additional 

projects

Execute 

default 

prevention 

program—

50% 

customer 

engagement

Executed 

default 

prevention 

program at full 

scale

Performance Result – – Met Met Met

Note: Data not available prior to FY 2020.

Metric Definition: This metric will track the development, testing, implementation, evaluation, monitoring 

and updates to Statistical and Machine Learning Models, methodologies, experimental designs, and 

interventions used in reducing customer risk of negative outcomes such as default. There will be multiple 

projects wherein models will be developed and deployed for assessing which customers would benefit 

most from receiving certain interventions such as specific emails, phone calls, skip tracing, and other 

actions. The benefits shall be measured on a project-by-project basis but will typically consider defaultrelated outcomes as well as costs of performing interventions. This metric will track how many projects 

exist and what phase of the development lifecycle they are in. Each project will have its own method of 

measuring its effectiveness once deployed with consideration to its experimental design and goals.

Data Source: FSA’s project plans for each individual intervention project. 

FY 2022 Period of Performance: October 2021 through September 2022.

Performance Metric 5.3.B. Default rate by borrower count.

Table 56: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – N/A N/A N/A N/A

Performance Result – – Baseline N/A N/A

Note: Data not available prior to FY 2020.

Metric Definition: This new metric provides the rate of Direct Loan borrowers entering default. It is a 

quarterly metric and similar to other repayment metrics, uses a four-quarter rolling average to address 

seasonal variations that are common in the loan program.

Data Source: NSLDS database.

FY 2022 Period of Performance: October 2021 through September 2022.
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Performance Metric 5.3.C. Percent of borrowers > 90 days delinquent.

Table 57: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance 10.1% 9.8% 4.8% 0.0% N/A N/A

Performance Result Met Met Baseline N/A N/A

Note: At the beginning of the pandemic, Direct Loan servicers cured loans which were delinquent at that 

time and moved them into forbearance. During CARES Act/payment pause, almost all borrowers who 

were, or would be, actively repaying, have their loans moved into forbearance, and servicers move loans 

to (or back to) forbearance in cases where borrowers request to opt out of the forbearance but their loans 

become delinquent, so this metric was not representative or useful during FY 2022.

Metric Definition: This metric calculation is the count of Direct Loan recipients with loans 91–360 days 

delinquent divided by the count of Direct Loan recipients with delinquencies 0–360 days. In other words, 

the denominator includes current repayment as well as delinquency. The calculation uses recipient 

counts, rather than borrower counts, because borrower counts would approximately double system 

demands. Delinquency rates by recipient count are slightly higher than by borrower count. 

Data Source: NSLDS database.

FY 2022 Period of Performance: October 2021 through September 2022. 

Performance Metric 5.3.D. Percentage of borrowers who did not make the first three 

payments.

Table 58: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – N/A N/A N/A N/A

Performance Result – – Baseline N/A N/A

Note: Direct Loan borrowers have not been required to make payments since March 2020, so this metric 

would not provide representative or useful results.

Metric Definition: This metric tracks the percentage of Direct Loan borrowers who make the first three 

payments after entering repayment (maturity). FSA will use fiscal year maturity cohorts. The universe of 

data will exclude military deferments, in-school deferments, and non-defaulted open bankruptcy status, as 

these are loan statuses where borrowers are not billed and not expected to pay. FSA will employ EDWA’s 

consolidation linking framework in case there are consolidations during a grace period (which are 

permitted) or early in repayment, so that those borrowers do not “fall out” of the cohort.

Data Source: EDWA servicing data.

FY 2022 Period of Performance: October 2021 through September 2022.
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Strategic Objective 5.4 

Increase vendor performance through quality management activities 

centered on customer service and product delivery.

Overview

In FY 2021, FSA set a framework for oversight which put a stronger focus on key performance 

indicators and 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. FSA was able to leverage the work initiated in FY 2021 

to pivot into the new landscape in FY 2022.

Both the Vendor Oversight Group (VOG) and Operational Improvement and Oversight (OIO) 

Directorate have worked collaboratively to progress towards the annual target of three reviews 

and examinations per year as well as additional oversight measures to ensure top performance 

from vendors. VOG and OIO met the performance metric again this year and are on track to 

meet the required reviews again in FY 2023.

FY 2022 Performance Summary and Analysis

There is one performance measure for this strategic objective. In FY 2022, VOG conducted 

three reviews of loan servicers which included analysis of how they managed specific tasks 

(e.g., the implementation of CARES Act, PSLF, transferring of loans to another servicer). This 

metric met the annual metric target of three reviews to be completed. All three reviews are final 

and any recommendations and/or corrective actions are being tracked and monitored.

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 action meant that a significant portion of the 

Direct Loan portfolio would transfer to new servicers. The Vendor Oversight Group was 

responsible for providing oversight for this process and focused on loan transfer reviews in 

FY 2022. In FY 2022, VOG reviewed approximately 1.1 million student loans that were 

transferred (automated and manual). OIO division worked with VOG on developing quick data 

match analysis, conducting automated data reviews and other oversight activities throughout 

the massive loan transfer process. The oversight reviews are continuing into FY 2023 and VOG 

has notified servicers that all identified issues must be resolved with corrective actions.

Another oversight area which continued in FY 2022 is VOG’s secret shopper calls. These calls 

involved VOG staff calling servicing call centers to ask representatives questions related to 

various topics such as PSLF, CARES Act programs, and other pertinent student loan servicing 

subject matter. VOG conducted approximately 2,700 secret shopper calls in FY 2022. These 

calls ensure our customers are receiving world class customer care and accurate information

about their student loans.

A new, key oversight activity implemented in FY 2022 are targeted monitoring reviews of service 

level agreements. These are contractually required performance metrics agreed upon in several 

new contracts with FSA vendors. VOG will be sampling a minimum of 271 borrower accounts 
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(total, not per servicer) for accuracy testing each quarter. These are called our General Account 

Reviews. There will be an additional review each quarter of “Specialty Programs” with an 

additional sample of at least 271 borrower accounts to test programs such as Death Discharge, 

PSLF, TPD, etc. These reviews will be VOG’s focus each quarter since servicer volume 

allocations are tied to these Service level agreements. 

Escalated servicer performance issues and Corrective Actions are managed by Student 

Experience and Aid Delivery (SEAD) Vendor Management team and VOG. Vendor issues can 

be identified by SEAD staff or self-reported by contractors. These issues are tracked and 

discussed with other SEAD stakeholders either in specific meetings for these issues or in other 

regularly scheduled meetings between SEAD staff. Outstanding vendor performance issues are 

reviewed regularly by the Vendor Management team and with the servicers and VOG as 

needed.
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Performance Metric

Performance Metric 5.4. Conduct three vendor examinations annually.

Table 59: Performance Metric Results

Fiscal Year

FY 2018 FY 2019 FY 2020 FY 2021 FY 2022

Actual Actual Actual Actual Target Actual

Performance – – – 6 3 3 

Performance Result – – – Met Met

Note: Data not available prior to FY 2021. This performance metric was revised in FY 2021.

Metric Definition: This metric tracks the number of quality assurance reviews conducted by OIO and/or 

VOG to measure the performance of vendors. The objective is to continuously enhance FSA’s oversight 

and management of FSA vendors by evaluating the efficiency and effectiveness of their compliance with 

contractual terms and statutory requirements. 

Data Source: Internal OIO reports. 

FY 2022 Period of Performance: October 2021 through September 2022.
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Fiscal Year 2022 Accomplishments of Federal 

Student Aid

During FY 2022, FSA realized additional accomplishments that were not measured specifically 

by the performance metrics implemented to measure performance against the FY 2020–24 

Strategic Plan. Although not measured by FSA performance metrics, 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:

Empower a High-Performing Organization.

• Federal Student Aid Leadership Institute (FSALI) designed and delivered two new

offerings. FSALI - Next Level Up for Team Leads targets emerging leaders. FSALI -

Innovative Leadership explores evolving leadership issues impacting FSA's mission and

organizational culture.

• Facilities, Security, and Emergency Management (FSEM) has undertaken two initiatives

crucial to FSA operations. First, they have been assisting the Department to transition

ED PIV cards to the USAccess PIV system. To date, approximately 45% of FSA staff

have the new PIV cards. Second, they have developed a move plan for FSA’s location at

Union Center Plaza (UCP) that centralizes all business units within half of the UCP

space, for a more collaborative working environment. This new plan allows for an

appropriate amount of telework touchdown space for business units.

FSA realized the following additional accomplishments in support of Strategic Goal 2:

Provide World-Class Customer Experience to the Students, Parents, and Borrowers We Serve.

• FSA administered the shutdown of Granite State, a federal loan servicer since January

2012. Approximately 1.3 million borrowers were successfully relocated to another

servicer with minimal borrower impact or complaints.

• In July 2021, it was announced that FSA would begin waiving verification of most FAFSA

Institutional Student Information Record information, with very limited exceptions, in view

of challenges and barriers resulting from the ongoing national emergency produced by

the pandemic. This positive development helps ensure students have the most

straightforward path to getting the financial aid they need to pursue further education by

providing over 2 million FAFSA filers relief from verification. In May 2022, that waiver

was extended to cover the 2022–23 FAFSA cycle.

• Limited PSLF Waiver: On October 6, 2021, the Department announced a change to

Public Service Loan Forgiveness (PSLF) program rules for a limited time. Utilizing the

HEROES Act, the “limited PSLF waiver” refers to the time-limited policy changes to

PSLF Program rules that allow borrowers to receive credit for past periods of repayment

that would otherwise not qualify for PSLF. After the announcement in early

October 2021, FSA worked across the organization and with its PSLF servicer, FedLoan

Servicing and later, MOHELA, to implement these policy changes throughout FY 2022.

Additionally, FSA was able to quickly update the PSLF Help Tool in November 2021, to

support the flexibilities offered under the limited PSLF waiver.
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Further, in FY 2022, FSA engaged in a multi-channel communications campaign with 

targeted emails, organic social media, paid digital ads, webinars, and SMS messages.

• Reconsideration Request Process: On October 13, 2021, the Department entered into

a settlement agreement with the American Federation of Teachers AFL-CIO, which

included a requirement for the Department to establish an interim reconsideration

process for PSLF by April 2022. The Department included a permanent reconsideration

process in its final regulations for the PSLF program published on November 1, 2022.

On March 27, 2022, FSA released an online tool for borrowers to submit reconsideration

requests for PSLF and Temporary Expanded PSLF (TEPSLF) to support the interim

reconsideration process. Additionally, FSA developed standard operating procedures,

implemented a customer relationship management tool, and cross-trained FSA staff to

review and process the reconsideration requests.

• PSLF Employer Search: As part of the DCC Release 5.7, FSA released the PSLF

Employer Search in July 2022. This look-up functionality allows borrowers to search

employers to verify eligibility for PSLF and does not require login with an FSAID. The

PSLF Employer Search also helps support borrowers who may benefit from the Limited

PSLF Waiver by providing them with the ability to review their employer’s eligibility prior

to taking steps to consolidate their loans or complete a Public Service Loan Forgiveness

(PSLF) & Temporary Expanded PSLF (TEPSLF) Certification & Application (PSLF form).

FSA realized the following additional accomplishments in support of Strategic Goal 3:

Increase Partner Engagement and Oversight Effectiveness.

• The School Eligibility and Oversight Service Group (SEOSG) conducted oversight

reviews for more than 2,400 unique IHEs relating to certification, deficient audit

resolutions, flagged financial statements, program reviews, method of payment, and

technical assistance.

• SEOSG completed more than 5,450 distinct eligibility actions, including more than 1,150

recertifications and more than 4,300 other institutional eligibility applications.

• SEOSG accomplished this work while also resolving more than 1,970 flagged financial

statements and deficient compliance audits, issuing more than 120 Program Review

Reports and more than 150 Final Program Review Determinations to IHEs assessing

more than $42.7 million in liabilities, and finalizing more than 45 Automatic Closed

School Discharge letters to IHEs assessing more than $13.6 million in associated

liabilities.

• SEOSG took special actions to issue Provisional Program Participation Agreement

(PPPA) Addendums to 24 ACICS-accredited IHEs following the Department’s Deputy

Secretary's August 19, 2022, decision to deny Accrediting Council for Independent

Colleges and Schools’ (ACICS’s) appeal of an earlier June 2021 decision issued to

withdraw recognition of the accrediting agency. The 24 ACICS-accredited IHEs

disbursed more than $83.7 million in Title IV aid to more than 7,200 students during the

2020-2021 award year.

• Additionally, SEOSG implemented new accountability requirements, including those

required by a March 23, 2022, Electronic Announcement requiring IHE owner entities to

co-sign Program Participation Agreements and two July 2022 Dear Colleague Letters for

IHEs seeking to add or change an accrediting agency.
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• The Cohort Default Rates Group (CDR Group) reviewed the FY 2019 Draft Cohort 

Default Rates (CDRs) and the Official CDRs prior to their releases in February 2022, 

and September 2022, respectively. The FY 2019 Draft and Official CDRs releases cover 

more than 5,000 IHEs, GAs, and lenders. 

• Upon issuance of draft and official CDRs, an IHE may challenge or appeal the accuracy 

of the CDR or the underlying data. During FY 2022, the CDR Group received and 

completed 72 appeals related to the FY 2018 Official CDRs released at the end of 

September 2021. IHE appeals of the FY 2018 Official CDRs encompassed more than 

800 allegations related to the underlying data used to calculate the rates. Following 

FSA’s release of the FY 2019 Draft CDRs in February 2022, the CDR Group received 

and resolved 19 appeals submitted by IHEs challenging the accuracy of the draft CDR 

data with more than 60 allegations of incorrect data. 

• The Performance Management Group (PMG) released the FY 2022 National Standards 

for SEOSG’s five core business processes, including Financial Analysis, Compliance 

Audit Resolution, Program Review, Eligibility, and Method of Payment. 

• Additionally, PMG resolved more than 745 internal Operational Support Branch Action 

Requests and answered more than 100 technical questions from the field which led to 

36 approved Q&A documents issued providing procedural updates. 

• PMG processed more than 175 Financial Responsibility Notifications submitted by IHEs 

and more than 330 Letters of Credit submitted on behalf of IHEs. 

• PMG and SEOSG staff also provided subject matter expertise to support the 

Department’s FY 2022 negotiated rulemaking sessions and proposed regulations and 

public comment analysis, and they supported and delivered annual FSATC

presentations.

• The Clery Group provided expert guidance and analysis regarding school compliance 

requirements established by 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 HEA requiring IHEs to implement Drug and Alcohol Abuse 

Prevention Programs as a condition of their Title IV participation. 

• The Clery Group assessed more than 210 media and complaint assessments including 

30 complaints submitted by the public and 183 campus-crime media reports. One 

hundred forty-one of these complaints and media reports warranted further assessment 

by the Clery Group. These assessments 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. Seventy-two media reports reviewed did not include initial information 

suggestive of an IHE’s noncompliance with statutory requirements. The Clery Group 

extended technical assistance to 25 IHEs in conjunction with the media and complaint 

assessments. 

• Notably, the Clery Group’s media and complaint assessment program flagged 35 

HBCUs for follow-up outreach in the wake of the bomb threats directed towards their 

institutions earlier this year. This resulted in 11 HBCUs being offered and 8 accepting 

focused technical assistance to help improve their preparedness and capabilities to 
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issue timely warnings to all students, employees, and faculty members regarding 

credible safety threats.

• Furthermore, the Clery Group reached a significant number of individuals through 

campus safety and Clery Act compliance conferences, trainings, and learning 

opportunities for IHE officials, public safety professionals, and other stakeholders, and 

through numerous one-on-one and group technical assistance sessions. 

• 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 45 school program reviews and school audits assigned to SEOSG’s 

School Participation Divisions for resolution. 

• The Clery Group, together with Department colleagues, is supporting the implementation 

of new VAWA 2022 provisions applicable to IHEs including by representing FSA on a 

new federal interagency “Task Force on Sexual Violence in Education” with counterparts 

from the Department, the U.S. Department of Justice, and the U.S. Department of Health 

and Human Services. 

• The Clery Group also provided support for the implementation of Section 1507 of VAWA 

2022 requiring the Department to create a standardized, mandatory online campus 

climate survey tool for IHEs’ 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 began and is continuing a process to transfer and assume a wide 

range of responsibilities from the Department’s Office of the General Counsel to 

administer the Department’s collection and oversight of IHEs’ semiannual reporting of 

foreign gifts and contracts information required by Section 117 of the HEA. 

• In addition to the new responsibilities, the Clery Group has continued providing direct 

oversight of Clery Act, VAWA, DFSCA, and VAWA 2022 requirement through program 

reviews of IHEs and through active post-review monitoring processes for IHEs with a 

history of egregious violations.

• The Financial Institution Oversight Service Group (FIOSG) issued 13 oversight reports 

and determinations covering FFEL Program commercial servicers, lenders, and GAs, 

and initiated new program reviews of 13 financial institutions who collectively administer 

and service more than $76 billion dollars in FFEL Program loans out of a combined total 

portfolio of more than $147 billion in outstanding FFEL Program loans held for more than 

5.5 million recipients as of the first quarter of fiscal year 2022. 

• Additionally, FIOSG provided operational support and oversight in the development and 

implementation of the Department’s Dear Colleague Letter GEN-21-03 expanding the 

loan collections pause to include defaulted FFEL Program loans managed by nonfederal GAs, including preparation, management review, and finalization of more than 

1,000 critical element assessments prepared during FY 2022 providing on-going 

oversight related to "GA Pause" activities. 

• FIOSG carefully monitored GA performance of required actions in the following areas 

related to the national student loan payment pause: 
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• pending and completed removals of GAs’ trade lines from defaulted borrower 

credit reports for more than 189,000 defaulted borrowers related to nearly 

550,000 loans valued at more than $5.2 billion, 

• GAs’ retroactive application of 0% loan interest rates to the March 13, 2020, start 

date of the national student loan payment pause for more than 1.4 million 

borrowers and nearly 4 million loans of more than $33 billion, 

• for improper involuntary collections activity by GAs, and monitoring GAs’ 

repayment to borrowers of more than $69 million in involuntary Treasury Offsets 

Payments initially diverted from more than 53,000 borrowers owing on more than 

154,000 loans totaling more than $1 billion, 

• GAs’ repayment of more than $107 million in administrative wage garnishments 

deducted from the paychecks of more than 111,000 borrowers owing on more 

than 359,000 loans of more than $2.3 billion, 

• GAs’ fulfillment of borrower-requested refunds totaling more than $6.6 million of 

voluntary loan payments made by more than 3,100 borrowers towards more than 

9,100 loans of more than $60 million, 

• GAs’ processing of $544 million in refunds for more than 130,000 borrowers who 

consolidated more than 392,000 loans of more than $3.4 billion, 

• GAs’ resolution of more than $38 million in refundable collection costs for more 

than 50,000 borrowers who rehabilitated at least 150,000 FFEL Program loans 

totaling more than $1.5 billion into Direct Consolidation loans, and 

• GAs’ Special Mandatory Assignments (SMAs) of defaulted loans in GA portfolios, 

including SMAs completed for nearly 12,000 borrowers who defaulted on more 

than 32,000 loans of $281.4 million, and pending SMA submissions for another 

260,000 borrowers who defaulted on 732,000 loans of more than $7.2 billion. 

• Some GAs, including those for the States of Illinois, Louisiana, Missouri, New 

Hampshire, New York, and Utah, are in the process of exiting the FFEL Program. 

FIOSG continues 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 their 

Federal Student Loan Reserve Fund (Federal Fund) accounts subject to reasonability 

requirements. FIOSG tracked transfers and request for transfers on a monthly basis.

GAs reimbursed themselves from their Federal Fund accounts until some were in a 

negative financial position. FIOSG timely raised concerns regarding the financial 

shortfalls these GAs were facing with FSA and Department senior leaders. The 

Department presented these financial concerns to OMB, which resulted in FIOSG’s 

approval of 26 payment transactions transferring more than $1 billion to 9 GAs in order 

replenish their Federal Fund accounts to the minimum reserve requirement levels. 

• FIOSG has been an active participant in the ongoing development and planned 

implementation of the "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 
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communications from the FFEL Program loan participants and representatives regarding 

the "Fresh Start" initiative announced on April 6, 2022. 

• FIOSG collaborated with FSA’s Project Success team and FSA’s senior leaders to 

prevent the disruption of Project Success funding due to GAs’ implementation of Dear

Colleague Letter GEN 21-03. FIOSG reviewed and approved quarterly Project Success 

reimbursement requests from GAs’ Federal Fund accounts for Project Success’ current 

phase expenses. FIOSG continues to collaborate with the Department’s Office of the 

Under Secretary, OIG, Institute for Education Statistics, Office of the Chief Data Officer, 

Chief Economist, and OMB to develop an evaluation plan, operations plan, and 

agreements for GAs to renew their Project Success participation in future years. 

• FIOSG developed and/or implemented updated methodologies for program reviews of: 

(1) commercial loan servicers’ administration of FFEL Program loans; (2) small selfserviced FFEL Program lenders with portfolios less than $5 million; (3) GAs exiting the 

FFEL Program; (4) GAs continuing their participation in the FFEL Program; (5) default 

aversion fees; and (6) GAs’ administration of Project Success. 

• Additionally, FIOSG Lead Reviewers served as subject matters experts for the FIOSG 

Procedures and Critical Elements with the Performance Management Group. A FIOSG 

reviewer assisted SEOSG in completing a review related to a closed school that closed 

and entered bankruptcy in 2005. FIOSG contacted appropriate GAs and obtained data 

and management attestation relating to the GAs’ payment of closed school discharge 

claims thus allowing SEOSG to close out the review. In another case, a FIOSG reviewer 

assisted SEOSG and an institution process credit balance checks for two paid in full 

borrowers who were due a refund. FIOSG conducted skip tracing efforts and research 

and reached out to appropriate internal contacts and GAs to bring this issue to resolution 

and have the money appropriately remitted to its owner and aided the institution in 

resolve and close a program review finding. 

• FIOSG staff served as the Department liaison to GAs participating in the FFEL Program 

"Common Review Initiative (CRI)" and as a non-voting representative to the CRI 

Governance Council. 

• FIOSG participated on bi-monthly FSA Ombudsman calls with all GAs to discuss 

pending issues. 

• FIOSG supported FSA’s Next Generation Program Office and venders on changes and 

updates necessary for the Next Gen system. 

• FIOSG developed and presented FSA Organizational briefing materials related to 

FIOSG’s program review function. 

• The Partner Eligibility and Oversight Services Directorate (PEOSD) Front Office 

provided ongoing support, information, technical assistance, and other resources to 

students, institutions, and borrowers impacted by an upsurge of natural disasters across 

the southern and midwestern states, Pacific states, and the East Coast, including 

proactive communications before the disasters struck and communications following the 

disaster, technical and operational assistance, regulatory and administrative relief and 

reporting flexibilities. In anticipation of a need to support these efforts, the PEOSD Front 

Office issued more than 4,000 pre-disaster emails to more than 2,000 institutions 

communicating the Department’s request for advanced preparedness information in the 

event of hurricanes, wildfires, and other types of cyclical natural disaster risks. 
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• When disasters struck, the PEOSD Front Office issued nearly 700 emails to aid in the 

recovery efforts of approximately 350 institutions who enrolled approximately 368,000 

students who received more than $3.8 billion in Title IV funding to attend schools located 

in geographic areas that were adversely impacted by natural disasters during FY 2022. 

• The PEOSD Front Office supported the fulfillment of more than 135 Freedom of 

Information Act requests, and ensured responses were provided to more than 100 

control mail responses to inquiries submitted to senior Department officials by the public 

and by members of Congress. 

• The PEOSD Front Office 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 Front Office 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 draft report including corrective actions. PEOSD Front Office

also supported hiring initiatives throughout the year. 

• In October 2021, the Department announced the establishment of an Office of 

Enforcement within FSA and the hiring of a chief enforcement officer, reporting directly 

to the chief operating officer. The Office completed hiring of its leadership team and 

continued hiring in Borrower Defense and Investigations groups. 

• BDG successfully recommended, and the Department announced group discharges 

based on borrower defense findings, covering 875,000 students who attended 

Corinthian Colleges, Inc., ITT Tech, Marinello Schools of Beauty, and Westwood 

College. These discharges total $11.4 billion in relief to defrauded students.

• The Administrative Actions and Appeals Services Group initiated dozens of actions 

against bad actors in the Title IV program including 10 recertification denials, 6 PPPA 

revocations, levying 18 fines totaling $2.3 million, 5 suspensions, 7 debarments, and 2 

terminations.

• FSA published its first Enforcement Bulletin warning institutions that the Department will 

act aggressively when it finds misrepresentations made to servicemembers and 

veterans by institutions. Enforcement plans additional bulletins to better communicate 

with outside stakeholders.

• The Investigations Group opened investigations into multiple institutions of higher 

education related to fraud and deceptive practices and completed multiple related site 

visits. 

• The FSA Training Center (fsatraining.ed.gov) provided training and technical 

assistance to 20,000 unique users. The Ease of Doing Business Survey respondents 

rated the ease of using the FSA Training center at 76 in its first appearance on the 

survey.

• TISG provided training to more than 15,000 school partners via the Wednesday Webinar 

series, Regional Conferences, congressionally-mandated Fundamentals of Title IV

training sessions and other outreach events.
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• The Conference Management Group conducted FSA’s second Virtual FSATC with more 

than 15,000 participants in attendance.

• The Internal/External Communications Group maintained timely operational 

communications while simultaneously supporting high-profile communication needs for 

numerous FSA and Department priorities including, but not limited to, preparation for 

SABER, implementation of Next Gen NSLDS database, consolidation of public CDR

information into one website, and creation of a disclaimer statement process through 

which FSA and the Department agree to publish PDFs until 508 compliance is attained.

• The Partner Technical Assistance Group (PTAG) and the Partner Engagement & 

Relationship Management Group (PERMG) identified a need for a Title IV administration 

best practices training aimed at new college/university presidents and chancellors. In 

September, PTAG and PERMG launched FSA’s New President’s Briefing in a two-part 

series to share critical information, strategies, and best practices concerning oversight 

and monitoring of Title IV Programs.

• TISG, PTAG and the Partner Connect Help Desk provided technical assistance support 

to over 2,000 school partners.

• The Minority Serving Under-Resourced Schools Division (MSURSD) provides technical 

assistance and training to MSIs. This year based on a statistical analysis of MSIs and a 

predetermined set of data (compliance) points, the MSURSD group was able to lower 

the number of MSIs with severe compliance issues to the lowest number (17 out of 823 

schools) in 7 years. 

• PERMG provided leadership and coordination for FSA’s session at the 2022 HBCU 

Annual Conference, which saw 1,232 individuals attending in person along with 1,535 

virtual attendees. PERMG also participated in the HBCU Presidential Board of Advisors 

meeting. Leadership was also provided for the second series of virtual “Birds of a 

Feather” sessions which included financial aid staff from six institutional segments. An 

internal interim platform for the Institutional Ombudsman for schools was created to track 

cases received from schools and FSA enterprise internal partners; a communications 

plan is being executed to support the full implementation of this new function.

• PPO’s managed-systems supported the award of more than $113 billion in federal 

student aid during the 2020–21 award year.

• A newly re-engineered NSLDS launched on July 24, 2022. The 28+ year old mainframe 

system was completely re-engineered to now being hosted using virtual machines

(midrange servers) into FSA’s segregated cloud solution. The NSLDS database holds 

more than 80 billion records, which amount to over 105 million students, 517 million 

loans, 176 million grants, and plays a pivotal role in the delivery and management of 

federal student aid by providing functions such as pre-screening of FAFSA applicants, 

tracking of enrollment status, and calculations of Cohort Default Rates.

• A government-wide initiative began in 2019 to transition all federal agencies from the 

use of the DUNS for business transactions with the federal government to a new Unique 

Entity Identifier (UEI). FSA implemented the new UEI on April 4, 2022. During this 

transition, FSA worked to ensure all Title IV institutions were converted from their 

traditional DUNS to a new UEI to allow all schools to continue processing their federal 

awards.
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FSA realized the following additional accomplishments in support of Strategic Goal 4:

Strengthen Data Protection and Cybersecurity Safeguards.

• The FSA Identity and Access Management team in the Technology Directorate recently 

completed the Global Password Change for StudentAid.gov, FSA ID user accounts in 

the Person Authentication Service system. Over 22.7 million of our 83 million users have 

already logged in and changed their passwords.

• FSA IHE Cybersecurity Division established a quarterly Newsletter program to share 

cybersecurity information and improve relationships with IHEs. The initial newsletter was 

emailed to over 11,000 IT and Compliance Professionals in the education sector and 

has since been requested by 1,073 more.

• IHE performed 21 outreach activities including those for Cybersecurity Month and FSA 

Day. Resolved GLBA audit compliance for 282 schools. 

• FSA is investing on a new Services Platform project to gain broader cybersecurity 

situational awareness. This platform will rely on an Enterprise CMDB, enabling higher 

speed when responding to incidents, faster response to data calls, automation of 

workflows (case management), Customer Portal to enhance the quality of support to 

IHEs, Vulnerability and Risk Management as it pertains to FSA assets.

• The Cybersecurity Operations Division has been very active performing market surveys 

looking to identify technologies to enable FSA to comply with Executive Order 14028. 

Identifying technologies is one of multiple steps to move from conceptual ideas to actual 

implementation of solutions on time. Plenty of work is also happening defining 

requirements for contract modifications with hosting facilities. 

FSA realized the following additional accomplishments in support of Strategic Goal 5:

Enhance the Management and Transparency of the Portfolio.

• Throughout FY 2022, FSA measured and analyzed performance based upon 

performance metric results outlined in the FY 2020–24 Strategic Plan, as well as various 

internal metrics used for operational management. The analysis of performance 

continues to be a transparent process within the organization, executed through weekly 

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

analyses of specified performance metrics are developed and provided to the FSA 

leadership and management team in the form of dashboards.

• At the end of the fiscal year, the organization was updating 22 dashboards on 12 topics, 

with 68 visualizations representing approximately 90 metrics on a weekly basis. Areas of 

focus and metrics were added as FSA identified potential concerns or opportunities for 

improvement. These dashboards were used to identify and resolve issues that may be 

affecting organizational performance.

• In FY 2022, the Enterprise Data Directorate (EDD) deployed a new data visualization 

software in its enterprise data warehouse in preparation for launching a more robust selfservice module to continue to expand and improve the FSA Data Center.

• FSA leveraged data and analytics to keep customers informed in an ever-changing 

environment and mitigate risks to the Title IV programs. In FY 2022, there are several 

examples where FSA has used analytics to positively impact borrowers:
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• Regarding TPDR fraud, which is when unscrupulous actors reach out to our 

borrowers and convince them to pay them for services that the government offers 

for free – our model is leveraged every day to reach out to our borrowers at risk 

of falling victim to these schemes. 

• The Enterprise Risk Management team continued to provide enhanced training, 

tools, templates, and reports to increase the connection between risk, strategy, 

and performance. These enhanced products helped FSA to better manage risk 

across the enterprise and continue to move toward becoming a more risk 

intelligent organization.

• Reconstituted the Enterprise Risk Management Committee representing 

collaboration across FSA to understand its enterprise risks. Reestablished 

Enterprise Risk Portfolio reporting and monitoring of FSA’s highest risks.
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Additional Reporting Requirements 

Additional Reporting Requirements 

(Unaudited)
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Additional Reporting Requirements 

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 Consolidated Appropriations Act, 2021 and the 

Consolidated Appropriations Act, 2022, both of which make significant changes 

to the requirements for completing the FAFSA; determining a student’s eligibility 

for federal student aid; and calculating Federal Pell Grants,

• Interpreting the provisions of the Stop Student Debt Relief Scams (STOP) Act, 

• Ending the prohibition on Federal Pell Grants for students incarcerated in federal 

and state penal institutions and developing regulations for the Department’s and 

states’ approval of prison education programs, and

• Supporting the Department’s negotiated rulemaking efforts related to gainful 

employment; financial responsibility; institutional certification; 90/10 

requirements; changes in ownership; administrative capability; closed school 

discharges and discharges for TPD; PSLF; income contingent repayment; and 

borrower defense to repayment.
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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 2022. However, 

because FY 2022 performance results were not finalized at the time this report was prepared, 

the section discusses FY 2021 performance results.

At the end of FY 2022, there were 107 FSA senior managers and 4 SES members. The FSA 

Executive Committee contained 11 of the 107 senior managers and 1 of the 4 SES members. 

As members of the FSA Executive Committee, these senior managers reported directly to the 

COO. The remaining 96 senior managers and 3 SES staff served in a variety of senior positions 

and capacities within FSA.

The following section discusses FY 2021 performance results.

For performance year 2021, the COO received a rating of Exceptional Results and a 

performance bonus of $46,000 for his work at FSA.

There were also FY 2021 performance ratings and awards for 5 of the remaining 12 senior 

managers who were members of the FSA Executive Committee reporting directly to the COO. 

Seven senior managers were not eligible to receive a performance rating. The composition of 

ratings for the remaining 4 senior managers and 1 SES member of the FSA Executive 

Committee achieved a performance rating of Exceptional Results. There were 2 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 $20,129 to 

$29,895, 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 105 senior managers who did not serve on the FSA Executive 

Committee last year were as follows: 68 senior managers achieved a performance rating of 

Exceptional Results; 19 achieved a performance rating of High Results; and 18 achieved a 

performance rating of Results Achieved.

Award amounts for those senior managers achieving an Exceptional Results rating ranged from 

$5,915 to $21,163 with a median award of $8,558. Award amounts for those achieving a High 

Results rating ranged from $4,908 to $5,979 with a median award of $5,624.

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, the Ombudsman is required to describe the 

activities and evaluate the effectiveness of the role during the preceding year.

The Ombudsman Group oversees all complaints submitted directly to FSA, as well as 

complaints referred by members of Congress, the Department, the CFPB, 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 2022 

During FY 2022, FSA received 101,516 cases—more than double the number of cases received 

in FY 2021.20 Cases may be submitted in a variety of ways, including through FSA’s website, by 

telephone, postal mail, or email.

In general, significant public announcements and improved user experience on StudentAid.gov

drive traffic to FSA’s complaint system. For example, in FY 2016, FSA launched the first 

iteration of its web-based complaint intake form, which increased intake by more than 10,000 

cases the following year.21 In FY 2019, the announcement of the TEPSLF drove a record 

number of case submissions.22 

In October 2021, FSA improved the visibility of its complaint tool, which again drove a large 

amount of traffic to the complaint system.23 Then, the Administration announced several policy 

initiatives, including the Limited PSLF Waiver, the IDR Account Adjustment, and One-Time Debt 

Relief, which drove record traffic to the StudentAid.gov website, and subsequently the 

complaint portal.24 The Department also announced its proposed settlement in the Sweet v. 

20 FSA receives 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 

Ombudsman Group, which most commonly occur when a complainant disagrees with the initial resolution of their case), general 

inquiries (questions about the operation of federal student aid programs and the use of FSA tools, such as resetting an FSA ID or 

questions about completing the FAFSA), suspicious activity (reports of suspected fraud within federal financial aid programs), or 

unassigned cases (cases submitted over the web awaiting categorization by intake agents). During FY 2022, FSA received 89,441 

complaints, 511 disputes, 7,777 general inquiries, and 2,040 suspicious activity submissions. At the end of the fiscal year, 1,747 

cases were unassigned. Data are current as of October 12, 2022 and reflect the number of cases stored in FSA’s case 

management system as of the date the data was extracted. 

21 U.S. Department of Education, Federal Student Aid Launches Online Feedback System (July 1, 2016), 

https://fsapartners.ed.gov/knowledge-center/library/electronic-announcements/2016-07-01/general-subject-federal-student-aidlaunches-online-feedback-system.

22 U.S. Department of Education, Temporary Expanded Public Service Loan Forgiveness, https://studentaid.gov/manageloans/forgiveness-cancellation/public-service/temporary-expanded-public-service-loan-forgiveness (last visited October 20, 2022).

23 FSA’s complaint portal link is now in the header of nearly every page on StudentAid.gov. 24 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-loan-
Fiscal Year 2022 Annual Report | Federal Student Aid 139

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Cardona lawsuit, which prompted a significant number of complaints from students who alleged 

misconduct by their school.25 

Figure 24: All Cases Received by Fiscal Year26 

Total Cases Received: 101,516

Data Limitations

The data discussed in this section reflects the status of cases received in the complaint system 

at the time of reporting. During the first quarter of FY 2022, as part of FSA’s broader effort to

forgiveness-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.

25 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. 26 Due to a methodological change, the case count listed in this figure does not match the number reported in previous FSA annual 

reports. Data in this visualization are current as of October 12, 2022 and reflect the number of cases stored in FSA’s case 

management system on the date the data was extracted. Previous FSA annual reports used a methodology that aggregated the 

number of cases observed throughout the year, but may not have accounted for cases that were referred or received after the initial 

observation. 
140 Fiscal Year 2022 Annual Report | Federal Student Aid

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modernize how it engages with aid recipients, FSA transitioned to a BPO vendor model to 

manage FSA complaints, leading to changes in data collection and categorization.27 

Since January 2022, 94% of FSA complaint system cases were submitted through 

StudentAid.gov. Web-based intake improves the customer experience by giving users more 

control over their narrative but requires intake agents to perform categorization work after case 

submission. As a result, web submissions remain unassigned until an agent reads the details of

the narrative and completes the FSA categorization. Approximately 2% of cases were 

unassigned at the time data was analyzed for this report. 

Finally, submissions created using the online complaint tool do not present the same 

categorization options as those maintained internally, so reporting is not uniform. In FY 2023, 

FSA will update and streamline its complaint system to synchronize the web-based intake form 

and the internal categorization process. 

Demographics of Borrower Complaints

During the fiscal year, borrowers reached out to FSA from across the country. By improving the 

visibility of FSA’s complaint system on StudentAid.gov, FSA gained insight into the issues 

faced by a large cross-section of federal student loan borrowers. 

Figure 25: Cases Received by Geographic Location 

27 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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In reviewing available demographics about complainants, data shows borrowers across every 

age bracket run into issues navigating loan repayment. However, higher-balance borrowers 

disproportionately submit complaints about their loan or school. Additionally, borrowers who 

were enrolled in IDR prior to the federal student loan payment pause submitted a significantly 

greater number of complaints than borrowers in any other repayment plan. 

Figure 26: Select Demographics of Complaint Submissions28

Table 60: Complaints about Repayment by Pre-Pandemic Repayment Plan29

REPAYMENT PLAN NUMBER OF BORROWERS

Standard Plan 3,906

Graduated Plan 2,795

Extended Plan 2,948

IDR Plan 20,244

Other Repayment Plan 895

No Repayment Plan 5,147

28 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. 29 This table represents complaints categorized as “repaying student financial aid,” “repaying student financial aid-default,” “public 

service loan forgiveness,” and “credit reporting.” Data is 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 nearly 90,000 complaints as borrowers sought to 

manage their federal aid. The majority of these complaints were related to student loan 

repayment.

Figure 27: All Complaints Received by Stage of Federal Aid Lifecycle

Total Complaints Received: 89,441

The most common complaint issues related to student loan repayment fall into four categories: 

general loan repayment issues, problems navigating the PSLF program, repayment issues 

faced when in default, and credit reporting. Taken together, FSA received 51,268 complaints 

(57%) about repayment.

Individuals navigating the student aid application process submitted 20,118 complaints (23%), 

making it the second largest topic by stage of the aid lifecycle. These complaints described 

problems users encountered when completing the FAFSA form and accessing their FSA ID. 

FSA received 7,446 complaints (8%) from individuals who had problems with FSA’s customer 

support. Most commonly, these complaints raised issues related to navigation of 

StudentAid.gov, including site error messages and web outages. Additionally, this category 

includes complaints from individuals who reported a negative interaction with an FSA or student 

loan servicer customer service agent.

FSA received 6,326 complaints (7%) from students describing issues while enrolled in school, 

including problems with their school. Topics within this category include cases related to the 

timing and amount of federal student aid and about school operations after enrollment.

Finally, FSA received 4,283 complaints (5%) about other topics, which include aid eligibility, aid 

disbursement, and 61 complaints awaiting categorization by intake agents.

Servicing-Related Complaints

The majority of complaints received by FSA during FY 2022 concerned issues related to student 

loan repayment, with a significant number of complaints related to PSLF. As previously 

discussed, many of these complaints were driven by the introduction of the Limited PSLF 

Waiver.

Issues with 

Loans, 57%

Issues 

Applying for 

Aid, 23%

Issues with 

Customer 

Support, 8%

Issues with 

Schools, 7%

Other, 5%
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Figure 28: Complaints about Student Loan Repayment by Subcategory30

Total Complaints Received: 51,268

This year, the Department expanded the Second Chance Pell experiment—a program designed 

to facilitate educational attainment and reduce recidivism for incarcerated individuals.31 This 

initiative includes access to Fresh Start, which will provide a pathway out of default for federal

student loan borrowers.32 But while the Department is expanding its efforts to help incarcerated 

students and borrowers, complaints suggest there may still be obstacles faced by this 

population in attempting to access these benefits. During FY 2022, FSA received more than 300 

complaints that mentioned issues related to imprisonment.33

These complaints suggest that the logistical barriers faced by incarcerated individuals may 

impede their ability to access certain benefits and protections—a sentiment echoed in listening 

sessions about this issue, wherein legal aid organizations described how incarcerated 

individuals are often prohibited from calling toll free phone numbers, which makes contacting 

FSA or their servicer difficult. Complaints from borrowers describe the lived reality of this 

impediment. For example, one borrower described struggling to access even basic information 

about the loan program:

So, I'm in the Department of Corrections. I am in prison at the moment, and I cannot 

use the internet to get a hold of my loan provider unless it's through the mail. I am 

interested in learning more about the new student loan relief the Administration is 

going to approve for anyone that has a student loan. My studentaid.gov portal has 

my address, but I want to receive mail and other helpful information that I would 

need and would like for the studentaid.gov to send everything to me in the mail 

30 Complaints about “issues with loans,” in Figure 27. 31 Press Release, U.S. Department of Education, U.S. Department of Education Announces Expansion of Second Chance Pell 

Experiment and Actions to Help Incarcerated Individuals Resume Educational Journeys and Reduce Recidivism (April 26, 2022), 

https://www.ed.gov/news/press-releases/us-department-education-announces-expansion-second-chance-pell-program-and-actionshelp-incarcerated-individuals-resume-educational-journeys-and-reduce-recidivism.

32 U.S. Department of Education, A Fresh Start for Federal Student Loan Borrowers in Default 

https://studentaid.gov/announcements-events/default-fresh-start (last visited October 20, 2022). Fresh Start benefits trigger 

automatically for those who reenroll in school. 

33 Complaint narratives that use the term “prison,” “incarcerated,” or “jail.”

Loan Discharge, 

Cancellation, or 

Forgiveness, 

28%

PSLF 

Qualifying 

Monthly 

Payments, 21%

Loan 

Accuracy, 

10%

PSLF 

Applications, 

9%

Other, 32%
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since I [cannot] use the internet to access other site only this site that is approved 

by the Department of Corrections.34

In other complaints, borrowers describe struggling to access Department programs, such as 

eligibility to have one’s loans written off if incarcerated for more than ten years.35 However, 

incarcerated borrowers must affirmatively know to ask for this discharge while there is still at 

least ten years remaining on their sentence. With little or no internet access and limited 

resources with which to do research about student loans, incarcerated borrowers are unlikely to 

know how to access this critical relief. As one borrower described:

I was incarcerated for over 10 years. I was not able to pay my student loans during 

that time. While incarcerated, I received a letter from my loan servicer stating I was 

in default and stating the interest and penalties. The letter also stated that if I was 

incarcerated for 10 years or longer, I would not be responsible for the loans 

anymore. Upon release, I contacted the loan servicer and was redirected several 

times before being informed that I am not eligible for forgiveness. 

Research shows that justice-involved individuals are disproportionately low-income and 

indebted, and following reentry, debt burdens may increase the likelihood of recidivism.36 As the 

Department continues its efforts to promote rehabilitative outcomes for formerly incarcerated 

borrowers, it should consider operational strategies, like automation, that support access to 

student loan debt relief and other benefits for these individuals in light of the significant 

constraints on their ability to access key information or engage with the Department or its 

servicers. 

School-Related Complaints

During FY 2022, FSA received 6,326 cases related to schools. These submissions cover a wide 

range of issues, including problems with federal student aid eligibility and disbursement to 

complaints about school operations once enrolled. Separately, borrowers submitted 1,683 

complaints about Borrower Defense to Repayment applications, which concerns FSA’s process 

discharging a loan when there is proof a student was misled or defrauded by their school. Those 

complaints are organized within the category related to student loans.

Borrowers who attended for-profit schools disproportionately submit complaints about their 

schools, relative to the share of Title IV aid funds disbursed for attendance at those schools. 

The sector accounts for 13% of annual aid volume but represents nearly three times (38%) that 

share of FSA’s identified complaints.37 In contrast, the public and private, not-for-profit school 

sectors account for a smaller share of complaints than annual aid volume.

34 Note that this complaint was received during FY 2022. As of January 2023, a court order was in place preventing the Department 

from continuing to accept applications related to debt relief. 

35 U.S. Department of Education, Loan Servicing and Collection Frequently Asked Questions, https://fsapartners.ed.gov/fsaprint/faq/1002617 (last visited October 20, 2022). 36 Anne Harper et. al., Debt, Incarceration, and Re-entry: a Scoping Review 46 Am. Journal of Criminal Justice 250, 251, 266 

(August 11, 2020), https://link.springer.com/article/10.1007/s12103-020-09559-9; An Assessment of Prisoner Reentry, Legal 

Financial Obligations and Family Financial Support: A Focus on Fathers; Andrea N. Montes et. al., An Assessment of Prisoner 

Reentry, Legal Financial Obligations and Family Financial Support: A Focus on Fathers Int J Environ Res Public Health 18 

(September 13, 2021), https://www.ncbi.nlm.nih.gov/pmc/articles/PMC8470671/. 37 This figure details the aid volume by school type disbursed during the 2019-20 school year, the most recent year for which data 

final is available. 
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Figure 29: School-Related Complaints by School Sector38

Complaints suggest that students who attend for-profit colleges have problems managing 

unforeseen balances owed to their school, asserting that these balances should be covered by 

federal aid. They report struggling to come up with out-of-pocket funds at the last minute. These 

borrowers complain that these charges hamper their ability to complete or progress through 

their programs. For example, one student writes that her school withheld her degree and 

threatened collections to settle her debt when she expected to use financial aid to pay tuition: 

I applied for financial aid to pay for my tuition, which I was approved for. They have 

yet to apply my financial aid to my $2,187 balance when I was told by a couple 

different team members in their financial aid dept that they would do a late 

disbursement in December; here it is February and that has yet to be done. They 

threatened me with collections if they don't receive their money. I also have yet to 

receive my degree in the mail as they are holding it hostage until they receive their 

money.

On June 22, 2022, the Department announced a proposed settlement in Sweet v. Cardona 

related to the processing of Borrower Defense applications.39 Since the announcement, FSA 

continues to receive complaints from borrowers who attended a school in the Sweet group but 

who had never submitted a Borrower Defense application and, are therefore not covered by the 

settlement. FSA also received numerous complaints from students alleging misconduct by

38 FSA received 6,326 complaints from students related to their school; of those, 4,392 were matched to identify the school sector. 

Calculations by the Enterprise Data Warehouse and Analytics group.

39 U.S. Department of Education, Sweet v. Cardona Settlement, https://studentaid.gov/announcements-events/sweet-settlement

(last visited October 20, 2022).
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colleges that are not included in the Sweet settlement. For example, one borrower described 

being misled by her school about the employment opportunities of their program:

I am a low-income mother of four children. I can’t even get a minimum wage job 

because my college [redacted] used false advertising. I did not know my college 

does NOT certify me for medical billing and coding until the last three months. They 

waited to tell me when I as almost done with college. I graduated and [received] a 

certificate but I did not know that that is not the same as a certified coder and I had 

not realized how that would affect my job. I can’t even get hired as a medical coder 

because everyone only wants a certified coder.

Military-Related Complaints

Pursuant to its responsibilities under the Principles of Excellence, FSA monitors complaints 

submitted from service members and military families.40 During FY 2022, FSA received 3,606 

complaints from military borrowers who struggled to manage their loans.

Figure 30: Complaints from Military Borrowers Related to Repayment41 

Total Complaints Received: 3,606

During the fiscal year, military borrowers submitted complaints describing a wide range of 

student loan issues stemming from their service. For example, several borrowers described 

difficulties trying to reach FSA’s call centers while deployed because of the time difference. 

Other borrowers described entering military deferment before deploying, only to return and learn 

that their loans were in default.42 

Earlier this year, FSA made it easier for military borrowers to receive PSLF credit for their 

service by allowing them to submit DD-214 forms in lieu of employer signatures when certifying 

employment.43 However, complaints indicate that these borrowers still struggle to certify their 

40 Executive Order No. 13607, 3 C.F.R. § 13607 (2012), https://obamawhitehouse.archives.gov/the-pressoffice/2012/04/27/executive-order-establishing-principles-excellence-educational-institutions-serving-service-members.

41 Complainants are asked whether they are an active member of the military, a veteran, or a dependent of an active member or 

veteran.

42 These complaints involved loans that defaulted prior to the payment pause in March 2020. 43 A DD-214 is certificate of release or discharge from active duty. 

Loan Discharge, 

Cancellation, or 

Forgiveness, 32%

PSLF Qualifying Monthly 

Loan Accuracy, 10% Payments, 19%

PSLF Applications, 

9%

Other, 30%
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service. For example, one borrower described receiving conflicting information about the ability 

to use a DD-214 form when pursuing PSLF:

I am a military veteran trying to apply for PSLF and cannot get clarity on how to 

certify my military service. Since there's isn't an HR department to call at the US 

Air Force, I'm not sure whom to ask to certify my previous employment records. I 

called my servicer . . . who told me I should simply submit my DD-214 (record of 

service and discharge from military duty). I have since received an email stating 

that the information cannot be reviewed because I didn't have my employment 

certified by a person. I have been working on this application, going in circles, for 

8 months.

Early in FY 2022, as part of the Limited PSLF Waiver, the Department announced plans to 

match federal data to automatically provide military borrowers with credit towards PSLF.44 It is 

incumbent on the Department to finalize this data match to provide military borrowers with the 

full range of federal repayment protections they are entitled to under law yet cannot access 

because of the unique obstacles imposed by military life. 

Activities of the Ombudsman

Approximately one in six adults in the United States owes student loan debt, affecting families 

and communities across the country.45 To ensure FSA was hearing from all communities 

affected by student debt, throughout the fiscal year the Ombudsman Group solicited feedback 

from organizations representing various affinities. 

44 Press Release, U.S. Department of Education, Fact Sheet: Public Service Loan Forgiveness (PSLF) Program Overhaul 

(October 6, 2021), https://www.ed.gov/news/press-releases/fact-sheet-public-service-loan-forgiveness-pslf-program-overhaul. 45 Data assessed prior to One-Time Debt Relief, which may provide relief for as many as 20 million borrowers. Press Release, The 

White House, FACT SHEET: The Biden-Harris Administration’s Plan for Student Debt Relief Could Benefit Tens of Millions of 

Borrowers in All Fifty States (Sept. 20, 2022), https://www.whitehouse.gov/briefing-room/statements-releases/2022/09/20/fact-sheetthe-biden-harris-administrations-plan-for-student-debt-relief-could-benefit-tens-of-millions-of-borrowers-in-all-fifty-states/. The 

Census reports 258 million adults in the United States. U.S. Census Bureau, QuickFacts 

https://www.census.gov/quickfacts/fact/table/US/PST045221 (last visited October 20, 2022).
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Figure 31: Average Student Debt per Borrower by County46 

To promote the visibility of the office and of the many initiatives announced by the Department, 

the Ombudsman Group increased engagement with a myriad of government, advocacy, and 

industry stakeholders. During FY 2022, the Ombudsman Group met with state regulators and 

law enforcement officials, community organizers, trade associations, legal aid organizations, 

guaranty agencies, private lenders, national advocacy groups, organizations representing 

service members and veterans, disability advocates, and civil rights groups. The Ombudsman 

Group also hosted a series of listening sessions with borrowers who struggled to afford incomedriven payments to better understand how to assess affordability and competing financial 

priorities. 

During listening sessions with consumer advocates, participants repeatedly highlighted the 

racial disparities in student loan outcomes. While applauding actions taken by the 

Administration to improve access to federal student loan programs, including IDR loan 

forgiveness and PSLF, advocates urged the Department to establish an equity office dedicated 

to evaluating disparities resulting from student loan policy and operations and improving access 

to repayment benefits for protected classes. Groups emphasized the need to ensure equity as 

FSA works to restart payments for millions of student loan borrowers as borrowers of color are 

at higher risk of delinquency and default.47

During listening sessions with industry, participants noted that they are often asked to 

implement policy on short timelines, resulting in an increased risk to the agency and to 

46 Data as of February 2022, based on the calculations by the Enterprise Data Warehouse and Analytics group. Bexar County, 

Texas is omitted due to discrepancies in the data. 47 Ben Miller, The Continued Student Loan Crisis for Black Borrowers, Center for American Progress (December 2, 2019), 

https://www.americanprogress.org/article/continued-student-loan-crisis-black-borrowers/. 
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borrowers. Industry also asked for more guidance in areas that are subject to interpretation to 

improve their ability to implement policy. 

Amid the various policy initiatives, FY 2022 also saw an unprecedented number of student loan 

servicing transfers. The Ombudsman Group, in partnership with FSA’s VOG, hosted regular 

meetings with state regulators to facilitate communication and information sharing to ensure a 

seamless transition for borrowers. The Ombudsman Group continued its student loan 

roundtable with more than a dozen states that have state-level ombudsman or advocate 

positions to facilitate sharing information and trends in complaint data. 

Finally, in an effort to continually improve the effectiveness of its engagement with third-party 

stakeholders, the Ombudsman Group developed and launched a survey to measure 

participants’ experiences engaging with FSA.48 This survey complements ongoing efforts to 

solicit feedback from students and borrowers and will be incorporated into FSA’s latest strategic 

plan.49 

Ombudsman Discussion

The following discussion and recommendations are made by the Ombudsman in accordance 

with the authority established under the HEA and informed by thousands of borrower complaints 

received throughout the year. 

Introduction

For decades, the availability of federal student aid has opened a pathway to economic mobility 

for low- and middle-income families by making higher education more accessible. From Federal 

Pell Grants to student loans, the federal student aid system offers access to higher education 

for families who lack other means to pay for school.50 When students and families must use 

loans to cover the cost of college, the federal student loan safety net promises affordability and 

eventually loan forgiveness to ensure that student debt does not negate one of the intended 

benefits of higher education—economic mobility and financial security for those who pursue it.51 

Due to ongoing and systemic wealth and income disparities, people of color are more likely to 

take on debt to pay for college and earn lower wages throughout their careers. The student loan 

safety net is crucial to their achieving economic mobility and financial stability.52 However, a 

growing body of data, including borrower complaints, shows that the student loan safety net 

48 Office of Management and Budget, Executive Office of the President, OMB Control No. 1845-0045, Generic Clearance for 

Federal Student Aid Customer Satisfaction Surveys and Focus Groups Master Plan (2022).

49 U.S. Department of Education., DRAFT: Federal Student Aid FY 2023-2027 Strategic Plan (September 9, 2022) at 18,

https://studentaid.gov/sites/default/files/FY202327StrategicPlanDraft.pdf. 50 U.S. Government Accountability Office., College Access and Affordability, https://www.gao.gov/college-access-and-affordability

(last visited October 20, 2022). 51 President Lyndon B. Johnson, Remarks at Southwest Texas State College Upon Signing the Higher Education Act of 1965 

(November 8, 1965) (transcript available through University of California, Santa Barbara American Presidency Project, 

https://www.presidency.ucsb.edu/documents/remarks-southwest-texas-state-college-upon-signing-the-higher-education-act-1965) 

(stating that the Higher Education Act “a high school senior anywhere . . . can apply to any college . . . a not be turned away 

because his family is poor. . . .”); Congressional. Research. Service., R43351, The Higher Education Act (HEA): A Primer (2021) at 

1, https://sgp.fas.org/crs/misc/R43351.pdf.

52 See, e.g., Shelley Stewart III, et. al., McKinsey Global Institution, Harvard Business Review, Closing the job mobility gap between 

black and white Americans (July 14, 2021), https://www.mckinsey.com/mgi/overview/in-the-news/closing-the-job-mobility-gapbetween-black-and-white-americans. 
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may not be meeting the needs of communities of color. In fact, it may be the inverse. As one 

researcher notes, “[Black young adults] have made significant gains in educational attainment 

but don’t have the wealth profile to match. This disparity appears to stem from the educational 

debt acquired to pursue their education.”53 

As the following sections will discuss, at each stage of the student aid lifecycle, the higher 

education finance model disproportionately fails families of color. Collectively, these failures 

perpetuate disparities in student and borrower outcomes and may ultimately widen the racialwealth gap. If policymakers wish to restore the promise of higher education and the pathway to 

the middle class for all, they should examine the student loan safety net through an equity lens 

and consider expanding existing programs to ensure more equitable outcomes for student loan 

borrowers. 

Background

Research shows that systemic racism in financial markets leaves families of color with less 

wealth to pull from to fund higher education, driving them to disproportionately rely on student 

loans compared to their white peers.54 Then, labor market inequities and disparities in servicing 

outcomes lead borrowers of color to disproportionately struggle during repayment.55 This cycle 

continues through generations, and many parents of color are still paying down their own 

student loans as they take on debt for their children’s college educations.56 

The student loan safety net should, in theory, offer a path to mitigate some of these disparities. 

For example, public service employees, who are disproportionately people of color, can have 

their student debt forgiven after ten years through PSLF.57 However, complaints from students 

and borrowers demonstrate how the safety net often fails to account for the lived reality of 

families of color and how they access federal aid and manage their finances. The following 

discussion reviews three examples in which students, borrowers, and families of color may be 

disproportionately burdened by their student loan debt during the financial aid lifecycle—

53 Fenaba Addo, Federal Reserve Bank of St. Louis, Parents’ Wealth Helps Explain Racial Disparities in Student Loan Debt (March 

29, 2018), https://www.stlouisfed.org/publications/in-the-balance/2018/parents-wealth-helps-explain-racial-disparities-in-studentloan-debt. 

54 According to the 2019 Survey of Consumer Finance, the median white family has nearly eight times the wealth as the median 

Black family ($188,200 compared to $24,100). Neil Bhutta et. al., Board of Governors of the Federal Reserve System, FEDS Notes, 

Disparities in Wealth by Race and Ethnicity in the 2019 Survey of Consumer Finances, (September 28, 2020), 

https://www.federalreserve.gov/econres/notes/feds-notes/disparities-in-wealth-by-race-and-ethnicity-in-the-2019-survey-ofconsumer-finances-20200928.html. 55 See e.g., Louise Seamster and Raphaël Charron-Chénier, Predatory Inclusion and Education Debt: Rethinking the Racial Wealth 

Gap, 4 Social Currents (2017), https://journals.sagepub.com/doi/10.1177/2329496516686620; Joanna Pearl, Driving Inequity: Are 

IDR’s Documentation Requirements Hurting Borrowers of Color? (October 1, 2021), 

https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3933430; “Black workers [are] currently concentrated in low-wage jobs, 

underrepresented in higher-paying occupations, and paid less than white workers on average within the same occupation 

categories, especially in managerial and leadership roles.” Stewart supra note 51. 56 Tiara Moultrie, Student Loan Cancellation Should Include Federal Parent PLUS Loans to Low-Income Parents, The Century 

Found. (May 31, 2022), https://tcf.org/content/commentary/student-loan-cancellation-should-include-federal-parent-plus-loans-tolow-income-parents/; see generally Jason N. Houle and Fenaba R. Addo, Racial Disparities in Student Debt and the Reproduction 

of the Fragile Black Middle Class, 5 Sociology of Race and Ethnicity at 1 (2018), 

http://static1.1.sqspcdn.com/static/f/1212067/27958796/1533219065950/HouleAddo2018.pdf?token=Jy0agSqP%2Bh7dFG7%2BIfU

GJTiI%2Buw%3D (“student debt may be a new mechanism of wealth inequality that creates fragility in the next general of the black 

middle class.”).

57 "During 2008–10, 21.2% of all Black workers are public employees, compared with 16.3% of non-Black workers. Both before and 

after the onset of the Great Recession, African Americans were 30% more likely than other workers to be employed in the public 

sector." Steven C. Pitts, Black Workers and the Public Sector, University of California, Berkeley Laboratory Center (April 4, 2011), 

https://laborcenter.berkeley.edu/black-workers-and-the-public-sector/. 
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accessing aid through college-sponsored accounts, managing loan repayment amidst Chapter 7 

or Chapter 13 bankruptcy, and paying for their children’s education through Parent PLUS 

loans—and offers solutions to promote more equitable outcomes.

College-Sponsored Accounts

When students take out loans to pay for school, they often receive a credit balance to cover 

living expenses during the school year.58 Many colleges and universities choose to contract with 

third-party financial services providers to disburse credit balances to students, and these 

companies may offer students the option to establish bank accounts and debit cards as a way to 

access federal aid funds throughout the year.59 Additionally, colleges and universities may 

partner with financial institutions to market certain general purpose school-branded bank 

accounts and credit products. This market is commonly referred to as “campus cards” or 

“college-sponsored accounts.”

Recent research by the CFPB found that many of these college-sponsored accounts charge 

higher fees than similar account products from other financial institutions.60 Additionally, the 

CFPB found that these companies charge students attending MSIs higher fees than those 

imposed on students attending non-MSI public and private, not-for-profit universities.61 

While Department regulations require that students be provided the option to have their funds 

disbursed to an account of their choosing,62 aggressive marketing tactics and imprimaturs of 

college endorsements often drive students into more expensive accounts.63 Complaints suggest 

that students may effectively be faced with two unsatisfactory choices—pay fees to access their 

own federal aid, or struggle to access their aid at all. For example, one student attending a MSI 

complained:

My school uses [bank] deposit to distribute their funds when previously I have had 

my funds deposited directly to my account from [my school]. [Bank] is a predatory 

banking company that is holding my funds hostage unless I sign up for their 

checking account. Meanwhile, while I can’t have the money I have borrowed and 

need to pay interest on, I won’t be able to pay my rent or credit card because this 

[bank] is holding my money hostage unless I sign up for their predatory checking 

account.

When students are driven into these expensive accounts, it may cause financial shock that 

could derail their educational pursuits by limiting their ability to cover basic living expenses.64

58 Federal aid, including federal student loans, are disbursed to schools. Schools deduct tuition and fees from the aid package, and 

then disburse the remainder to the student to use towards textbooks, living expenses, and other college costs. U.S. Department of 

Education, Federal Student Aid, Receiving Financial Aid, https://studentaid.gov/complete-aid-process/receive-aid (last visited 

October 20, 2022). 59 Consumer Financial Protection Bureau, Annual Report to Congress: College banking and credit card agreements (“2022 Report”) 

(October 2022) at 3, https://files.consumerfinance.gov/f/documents/cfpb_college-banking-report_2022.pdf. 60 Id. at 5; Consumer Financial Protection Bureau, Annual Report to Congress: Student banking (“2016 Report”) (December 2016) 

at 2, https://files.consumerfinance.gov/f/documents/2016_cfpb_student_banking_report.pdf. 61 Consumer Financial Protection Bureau supra note 58 at 29.

62 34 C.F.R § 668.164(d)(4).

63 2022 Report supra note 58 at 29; 2016 Report supra note 59. 

64 See, e.g., Karole Dachelet et al, Investing in Student Completion: Overcoming Financial Barriers to Retention Through SmallDollar Grants and Emergency Aid Programs (December 2015), http://wihopelab.com/publications/Investing-in-Student-Completion-
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This burden may be disproportionately borne by students of color, who face higher account 

fees65 and less financial flexibility66 than their white peers. 

In conjunction with the CFPB’s findings on campus-sponsored accounts, the Department 

released a Dear Colleague Letter to colleges and universities explaining that it was “aware of 

certain practices that may pose risks or excessive costs to students.” 67 The Department 

committed to monitoring these agreements for compliance with the Department’s cash 

management rules, which require that schools only partner with account providers that offer 

products that are in the best financial interest of students. 

However, requirements for college-sponsored accounts can go further—policymakers can 

expressly ban disparate pricing models and fee structures across school sectors.68 Additionally, 

enforcement efforts should examine whether disparate product structures, features, or terms 

across school sectors are consistent with Department regulations. Both approaches would 

promote more equitable product offerings and leave more money in the pockets of students of 

color. Additionally, market participants that use these accounts as loss leaders would still find 

value in establishing these relationships with schools and students—even without imposing 

fees.69 

Bankruptcy

Experts have long called for bankruptcy reforms that reevaluate the treatment of student 

loans.70 Legislators could reconsider statutes that impose heightened standards on debtors 

seeking to discharge their student loans. While the Administration has taken action to promote a 

more just approach to student debt in bankruptcy,71 policymakers could do more to improve 

access to various student loan repayment programs to borrowers with loans in a bankruptcy 

status.72 For example, a borrower cannot accrue credit towards income-driven repayment loan 

WI-Hope_Lab.pdf; Kevin Kruger et al., Landscape Analysis of Emergency Aid Programs (2016), 

http://postsecondary.gatesfoundation.org/wpcontent/uploads/2016/11/Landscape-Analysis-of-Emergency-Aid-Programs.pdf. 65 2022 Report supra note 58 at 3.

66 University of Chicago, UChicago News, Financial distress can hinder success of academically prepared minority students, study

finds, (September 9, 2015), https://news.uchicago.edu/story/financial-distress-can-hinder-success-academically-prepared-minoritystudents-study-finds. 67 U.S. Department of Education, Dear Colleague Letter GEN-22-14, Cash Management – Tier One and Tier Two Arrangements 

(October 13, 2022), https://fsapartners.ed.gov/knowledge-center/library/dear-colleague-letters/2022-10-13/cash-management-tierone-and-tier-two-arrangements. 

68 Regulators can also have an impact through better enforcement of laws prohibiting discrimination in financial services. For 

example, earlier this year, the CFPB revised its interpretation of Unfair, Deceptive, and Abusive Acts and Practices to include 

discriminatory conduct as an unfair practice. Many states have laws prohibiting unfair practices. Given the concentration of financial 

institutions in the college-sponsored account market, regulators should review whether these actors are offering products equitably 

across their portfolios.

69 Frederick Reichheld et al., The Hidden Advantages of Customer Retention, 12 Journal of Retail Banking 4 (1990). 70 See e.g., Oversight of Bankruptcy Law and Legislative Proposals Before the U.S. House Judiciary Subcommittee on Antitrust, 

Commercial and Administrative Law (June 25, 2019), https://www.law.uci.edu/news/in-the-news/2019/jimenez-bankruptcytestimony.html; Dalié Jiménez, A Tortuous History: The Student Loan Exception to Discharge (April 2014),

https://ssrn.com/abstract=3544267; Aaron N. Taylor, Undo Undue Hardship: An Objective Approach to Discharging Federal Student 

Loans in Bankruptcy, Journal of Legislation 38 J. Legis. (2012), https://heinonline.org/HOL/P?h=hein.journals/jleg38&i=195. 71 U.S. Department of Justice, Justice Department and Department of Education Announce a Fairer and More Accessible 

Bankruptcy Discharge Process for Student Loan Borrowers (November 17, 2022), https://www.justice.gov/opa/pr/justicedepartment-and-department-education-announce-fairer-and-more-accessible-bankruptcy.

72 U.S. Department of Education, PSLF Waiver Offers Way to Get Closer to Loan Forgiveness,

https://studentaid.gov/announcements-events/pslf-limited-waiver (last visited October 20, 2022). “Can I get payment counts for time 

I spent in bankruptcy or in default? No, time spent in bankruptcy status does not count as time in repayment nor does it count 

towards the various forbearance exceptions.”
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forgiveness or PSLF while his or her loans are in a bankruptcy forbearance, despite Chapter 13 

filers making payments required by the bankruptcy process that essentially function as incomedriven payments.73 

Individual consumers may file for bankruptcy under either Chapter 7 or Chapter 13 of the 

bankruptcy code. While Chapter 7 bankruptcy protections are available to all borrowers who 

earn less than the median income for their state, research shows that the average Chapter 7 

filer earns an income that would qualify them for a low- or zero-dollar payment under incomedriven repayment plan.74 When a borrower enters Chapter 7 bankruptcy, their student loans are 

placed in an automatic bankruptcy forbearance for the duration of the bankruptcy proceeding.75

During the stay, interest continues to accrue and even if the borrower could afford to make 

payments, bankruptcy attorneys report that servicers generally do not accept them. As a result, 

many borrowers exit Chapter 7 with even higher student loan balances than before and 

complain about how these stays derail their efforts to earn loan forgiveness. 

Borrowers similarly struggle under a Chapter 13 bankruptcy, where they must make payments 

comprised of the entirety of their disposable income to a trustee, and the trustee distributes 

payments to creditors.76 However, because student loans are placed in a bankruptcy 

forbearance, any payments made by the trustee would not count towards IDR loan forgiveness 

or PSLF. As a result, borrowers in bankruptcy may make up to five years of extra payments as 

compared to solvent borrowers before being able to access PSLF or IDR loan forgiveness.

I have been making payments while in a Chapter 13 bankruptcy, but my account 

is suspended, so the payments are not being counted towards my loan 

forgiveness. The bankruptcy will be in effect until May 2023 (60 months of 

payments). I would like the payments to qualify for PLSF since I'm making the 

payment.

Bankruptcy protections are disproportionately exercised by people of color,77 and in particular, 

black women78—a population that already struggles unequally during student loan repayment.79

Bankruptcy policies therefore have outsized, if unintended, consequences for borrowers of 

color. For example, approximately 70% of low-income Black Chapter 13 filers do not achieve a 

bankruptcy discharge, as compared to 50% of low-income white filers.80 Not only do student 

73 But see U.S. Department of Education, Chapter 13 Plan Non-Standard Section Template for Student Loan IDR Plans During 

Bankruptcy (2018). In 2018, the Department drafted model language that can be used by borrowers during Chapter 13 bankruptcy 

to maintain IDR enrollment. 

74 Jonathan Fisher, Center for Economic Studies, Who Files for Personal Bankruptcy in the United States? (September 2017) at 10,

29, https://www2.census.gov/ces/wp/2017/CES-WP-17-54.pdf. 75 34 C.F.R § 682.402(f)(2); 34 C.F.R.§ 682.402(f)(5)(ii).

76 U.S. Courts, “Chapter 13, Bankruptcy Basics”, https://www.uscourts.gov/services-forms/bankruptcy/bankruptcy-basics/chapter13-bankruptcy-basics.Generally, federal student loan debt owned by the Department of Education is an unsecured, non-priority 

debt, however “some judges allow student loan borrowers to give priority to their student loans during the Chapter 13 plan.”;

National Consumer Law Center., Student Loan Borrower Assistance, “Bankruptcy”, 

https://www.studentloanborrowerassistance.org/bankruptcy/ (last visited October 20, 2022). 77 Fisher, supra note 73 at 10.

78 Pamela Foohey et. al., Portraits of Bankruptcy Filers, 56 Georgia Law Review, 573, 579 (2022).

https://digitalcommons.law.uga.edu/glr/vol56/iss2/3; Fisher, supra note 73 at 10.

79 Kevin Miller, Deeper in Debt, American Association of University Women (March 2020), 

https://www.aauw.org/app/uploads/2020/03/DeeperinDebt-nsa.pdf.

80 Paul Kiel and Hannah Fresques, Data Analysis: Bankruptcy and Race in America, 

ProPublica.org (September 27, 2017), https://projects.propublica.org/graphics/bankruptcy-data-analysis. Note that the data does not 

make clear whether these discharges include student debt—a consumer may achieve a discharge on his or her debts, but student 

loans may be excluded.
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loan payments made during bankruptcy not count towards student loan forgiveness, but 

borrowers are left with the same debt burden as when they started and even less ability to 

pay.81 This effect is particularly notable for borrowers of color, who research shows return to 

repayment more financially vulnerable than before filing for bankruptcy.82 

The goal of bankruptcy is to provide a financial “fresh start” and “a new opportunity in life”83—yet 

current treatment of student loans may leave bankruptcy filers, and especially borrowers of 

color, even further behind as it stymies their progress towards loan forgiveness. Policymakers 

should consider expressly counting time spent in bankruptcy towards PSLF and IDR loan 

forgiveness as a means to promote more equitable student loan outcomes while complying with 

bankruptcy stay requirements.84

Parent PLUS Loans

Note to readers: This section was drafted in October 2022, prior to the Department’s 

updates to the scope of the One-Time IDR Adjustment. In January 2023, the Department 

expanded the IDR Adjustment to include Parent PLUS loans.85

As of July 2022, 3.6 million borrowers owed $106.3 billion in Parent PLUS loans owned by the 

Department.86 Parent PLUS loans are one of the more costly loan products offered by the 

federal student loan program—these loans have higher interest rates and origination fees than 

Direct subsidized and unsubsidized loans and have less flexibility in repayment.87 While Parent 

PLUS loans may have been originally intended as a way for high-asset, low-liquidity families to 

pay for school, research shows that the reality of who is taking out these loans is quite different. 

In fact, the high costs of Parent PLUS loans are disproportionately borne by families of color, 

who have less wealth to pull from to pay for school and therefore rely on Parent PLUS loans to 

bridge the gap between the cost of attendance and other federal aid offerings.88 

81 Paul Kiel and Hannah Fresques, How the Bankruptcy System Is Failing Black Americans, (September 27, 2017), 

https://features.propublica.org/bankruptcy-inequality/bankruptcy-failing-black-americans-debt-chapter-13 (“And when their cases are 

dismissed, debtors are often in worse straits, because as they struggled to make payments, the interest on their unpaid debts 

continued to mount. Once the refuge of bankruptcy is gone, the debt floods back larger than ever. They’ve borne the costs of 

bankruptcy — attorney and filing fees, a seven-year flag on their credit reports — without receiving its primary benefit.”).

82 See id.; Houle and Addo, supra note 55 at 3, 4; Racial Disparities in Student Debt and the Reproduction of the Fragile Black 

Middle Class, 5 Sociology of Race and Ethnicity at 3 (2018), 

http://static1.1.sqspcdn.com/static/f/1212067/27958796/1533219065950/HouleAddo2018.pdf?token=Jy0agSqP%2Bh7dFG7%2BIfU

GJTiI%2Buw%3D. 83 U.S. Courts, Bankruptcy, https://www.uscourts.gov/services-forms/bankruptcy (last visited October 20, 2022); Local Loan Co. v. 

Hunt, 292 U.S. 234, 244 (1934).

84 In late 2022, the Department announced new PSLF regulations that include a “hold harmless” provision for borrowers during 

periods of forbearance. This would allow borrowers an opportunity to gain PSLF credit for certain periods of forbearance and 

deferment. See U.S. Department of Education, Fact Sheet: Charting the Path Forward for Public Service Loan Forgiveness 

(October 31, 2022), https://www2.ed.gov/policy/highered/reg/hearulemaking/2021/futureofpslffactsheetfin.pdf.

85 U.S. Department of Education, Income-Driven Repayment Account Adjustment, https://studentaid.gov/announcementsevents/idr-account-adjustment (last visited January 13, 2023).

86 U.S. Department of Education, Federal Student Aid Data Center, Federal Student Aid Portfolio By Loan Type, 

https://studentaid.gov/data-center/student/portfolio. 87 Casey Goldvale et. al., Georgetown Center on Poverty and Inequality, Unrepayable Debt How Economic, Racial, & Geographic 

Inequality Shape the Distribution of Parent PLUS Loans (September 2022) at 4, https://www.georgetownpoverty.org/wpcontent/uploads/2022/09/UnrepayableDebt-September2022.pdf. 88 For example, one study found that parents of students who attend HBCUs are nearly three times as likely to use Parent PLUS 

loans to pay for school. Sruthi Darbhamulla and Kimberly Jin, What Does Data Tell Us About Parents Borrowing at HBCUs?, Medill 

News Service (October 12, 2019), https://feed.georgetown.edu/access-affordability/hbcu-families-disproportionately-carry-parentplus-loans/. 
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Over the last decade, the share of low-income families of color who took out Parent PLUS loans 

increased dramatically.89 As one study shows, “the share of black Parent PLUS borrowers 

whose families have so little wealth or income that their expected family contribution . . . is zero 

rose from 15% in 2008 to an astonishing 42% in 2018.”90 In another study, researchers found 

that “the adverse effects of Parent PLUS loans on borrowers with fewer economic resources are 

inextricably linked with racialized disparities in wealth and education.”91

These higher-cost loans also lack the repayment flexibility found with other federal student 

loans. For example, Congress prohibited Parent PLUS loan borrowers from enrolling in an IDR 

plan. If parent borrowers consolidate their loans, the only IDR plan available to them is incomecontingent repayment, which sets payments twice as high as most other IDR plans.92

Complaints show that Parent PLUS borrowers are struggling to afford repayment and are 

subjected to the same servicing breakdowns as other borrowers. 

The high costs, servicing failures, and policy exclusions have culminated in expensive loans for 

families well into retirement (that is, if they can retire).93 The fallout for families of color is 

notable—according to one study, “ten years after starting repayment, the parents who received 

Parent PLUS loans and had children attending the top colleges for Black enrollment still owe on 

average 96% of their principal, compared to 47% among those whose children attended the top 

colleges for white enrollment.”94 If these parents default, they risk having their wages garnished 

and Social Security benefits offset—an outcome that, again, disproportionately affects 

borrowers of color. 

Policymakers can address the inequities faced by families of color by providing more 

fundamental reforms to Parent PLUS loans. For example, the Limited PSLF Waiver expired on 

October 31, 2022, but similar relief could be offered to Parent PLUS borrowers through the IDR 

Adjustment, currently slated to take effect in mid-2023. Additionally, policymakers should 

consider steps to address the unaffordable options facing some parents seeking to finance 

postsecondary education, including more financial aid and more affordable repayment options. 

Conclusion

Without additional robust interventions, the cycle of inequity in higher education finance is 

doomed to repeat itself generation after generation. The student loan safety net has the 

infrastructure to provide much-needed relief to borrowers and communities of color, but it must 

be expanded to effectively meet the needs of the intended beneficiaries. Until then, student debt 

will continue drive disparities that negate the benefits of a college education.

89 Goldvale, supra note 86 at 4; Peter Granville, The Century Foundation, Parent PLUS Borrowers: The Hidden Casualties of the 

Student Debt Crisis (May 31, 2022), https://tcf.org/content/report/parent-plus-borrowers-the-hidden-casualties-of-the-student-debtcrisis/?session=1&agreed=1. 90 Granville, id. 91 Goldvale, supra note 86 at 5. 92 Parent PLUS loans only qualify for income contingent repayment, the least generous IDR plan. 34 C.F.R. § 682.215(a)(2), 34 § 

685.209(a)(ii), (b), (c)(ii); U.S. Department of Education, Direct PLUS Loans are federal loans that parents of dependent 

undergraduate students can use to help pay for college or career school, https://studentaid.gov/understandaid/types/loans/plus/parent (last visited October 22, 2022).

93 Granville, supra note 88.

94 Id.
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Financial Section (Fiscal Year 2022 Unaudited) 

Financial Section

(Fiscal Year 2022 Unaudited) 
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Financial Section 

Overview of the Financial Section

This section provides a financial presentation of FSA’s stewardship and accountability for its 

resources. The financial statements are followed by the accompanying notes to the financial 

statements, required supplementary information, and the Independent Auditors’ Report. The 

subsections are listed and briefly discussed below: 

• Financial Statements: The Financial Statements consist of the following 

comparative statements: Balance Sheet, Statement of Net Cost, Statement of 

Changes in Net Position and Statement of Budgetary Resources.

• Notes to the Financial Statements: The Notes to the 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 presents the Combining Statements of Budgetary 

Resources by Program.

• Independent Auditors’ Report: The Independent Auditors’ Report 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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Financial Statements

FSA prepares the following comparative financial statements: the Consolidated Balance Sheets, 

the Consolidated Statements of Net Cost, the Consolidated Statements of Changes in Net 

Position, and the Combining Statements of Budgetary Resources. These statements are 

prepared pursuant to the requirements of the Chief Financial Officers Act of 1990, the 

Government Management Reform Act, and OMB Circular A-136; and demonstrate FSA’s 

accountability and stewardship of the resources entrusted to it. 

Below is a brief description of the principal financial statements included in this section: 

• Consolidated Balance Sheets: The Consolidated Balance Sheets present, as 

of a specific time, the amount of resources FSA has to use or distribute (assets), 

the amounts owed by FSA (liabilities) and the difference between the two (net 

position).

• Consolidated Statements of Net Cost: The Consolidated Statements of Net 

Cost present the annual cost of agency operations. The gross cost less any 

offsetting revenue is used to determine the net cost.

• Consolidated Statements of Changes in Net Position: The Consolidated 

Statements of Changes in Net Position report the accounting activities, including 

changes to Cumulative Results of Operations and Unexpended Appropriations

that caused the change in net position during the reporting period.

• Combining Statements of Budgetary Resources: The Combining Statements 

of Budgetary Resources report the budgetary resources that were made 

available to FSA, the status of those resources at fiscal year-end, along with the 

outlays of budgetary resources. 
Bala

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Financial Section 

Consolidated Balance Sheets 
162 Fiscal Year 2022 Annual Report | Federal Student Aid

Financial Statements 

Consolidated Statements of Net Cost
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Financial Section 

Consolidated Statements of Changes in Net Position
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Financial Section 

Combined Statements of Budgetary Resources
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Financial Section 

Notes to the Financial Statements

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 General Fund

Note 9. Other Liabilities

Note 10. Net Cost 

Note 11. COVID-19 Activity 

Note 12. Statements of Budgetary Resources

Note 13. Reconciliation of Net Cost to Net Outlays

Note 14. Commitments and Contingencies

Note 15. Subsequent Events
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Financial Section 

Notes to the Financial Statements for the Years Ended, 

September 30, 2022 and September 30, 2021

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. These financial statements 

should be read with the realization that they are 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 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 Loans. 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 with reinsurance and interest subsidies provided by the Department. 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. However, under the 
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terms of the Put Agreement with the conduit, ABCP Conduit activity ceased operations in 

January 2014. (See Notes 5 and 10)

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. (See Note 10)

COVID-19. COVID-19 relief legislation and administrative actions provided support for student 

loan borrowers by temporarily suspending nearly all federal loan payments, interest free. FSA also 

stopped all federal wage garnishments and collection actions for borrowers with federally held 

loans in default. Funding for the student loan repayment was provided through indefinite 

appropriations. (See Notes 5 and 11)

Other regulatory flexibilities and incentives provided to help students through COVID-19 include:

• Federal Supplemental Educational Opportunity Grants to provide emergency aid 

to students.

• Continuation of work-study payments, even if students can no longer work onsite.

• 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.

• Waiving satisfactory academic progress requirements to help ensure that 

students do not lose academic standing and the ability to receive federal financial 

student aid.

• Tax credits that incentivize employers to help pay for student loans.

Basis of Accounting and Presentation

These financial statements were prepared to report the financial position, net cost of operations, 

changes in net position, and budgetary resources of FSA as required by the Chief Financial 

Officers Act of 1990 and the Government Management Reform Act of 1994. The 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 No. A-136, Financial 

Reporting Requirements, as revised. These financial statements are different from the financial 

reports prepared by the Department pursuant to OMB directives that are used to monitor and 

control FSA’s use of budgetary resources.

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 
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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 

financial statements.

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 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.

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. FSA estimates subsidy expense 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 

discount rate used to calculate the cost of the modification and the interest rate at which the 

cohort pays or earns interest.

The subsidy cost 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.

In order 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,
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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.

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.

• 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. Financing accounts are presented separately in 

the combined statements of budgetary resources (SBR) as non-budgetary credit 

reform accounts to allow for a clear distinction from all other budgetary accounts. 

This facilitates reconciliation of the SBR to the Budget of the United States

Government.

• 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.

• Treasury General Fund receipt accounts receive amounts paid from financing 

accounts when there are negative subsidies for new loan disbursements or

downward re-estimates of the subsidy cost of existing loans. (See Notes 12 and 

13)

FSA records an obligation each year for direct loan awards to be made in a fiscal year based on 

estimates of schools’ receipt of aid applications. FSA advances funds to schools based on these 

estimates. 

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. FSA’s obligation estimate may also not reflect the actual 

amount of awards made. Based on historical averages, FSA expects approximately 7.7 percent

of the amount obligated for new loan awards will not be disbursed.

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. 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 repayments plans under which borrowers may receive forgiveness of the 

remaining balance of their loans after 20 or 25 years under certain rules.
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Budgetary Terms

The purpose of Federal budgetary accounting is to control, monitor, and report on funds made 

available to FSA 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 

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 program, 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. 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 FSA 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 
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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 FSA 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 

account amounts for direct loan and loan guarantee programs shown on the SBR. Financing 

accounts reflect program cash flows as distinct from credit “program” accounts, which are 

budgetary accounts that reflect the subsidy cost of the programs. (See Note 12)

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 
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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 18 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 

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 U.S. and are 

reflected in the Budget of the United States Government. 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.
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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. 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 Note 4)

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)
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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 and scheduled payments transmitted but not yet processed. Other than 

intragovernmental accounts payable to the public primarily consists of in-process grant and loan 

disbursements, including an accrued liability for schools that have disbursed loans before 

requesting funds. (See Note 9)

Accrued Grant Liabilities

Some grant recipients incur allowable expenditures as of the end of an accounting period but 

have not been 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.

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.

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 
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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 

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)

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 cost 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 and 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. (See 

Note 10)

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 
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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. (See Notes 5 and 10)

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.

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. (See Note 10)

Net Position

Net position consists of unexpended appropriations and cumulative results of operations. 

Unexpended appropriations include undelivered orders and unobligated balances, except for 

federal credit financing and liquidating funds and trust funds. Cumulative results of operations 

represent the net difference since inception between (1) expenses and (2) revenues and 

financing sources.

Taxes

FSA is 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 

consolidated financial statements in conformity with GAAP. These estimates are reflected in the 

assets, liabilities, net cost, and net position of the financial statements 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 
Fiscal Year 2022 Annual Report | Federal Student Aid 179

Financial Section 

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, 5, 9, and 10)

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 

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 2022 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 (40.4 percent), reported as cash and other 

monetary assets, and Federal Perkins Loan program loan receivables (59.4 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)
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Note 3. 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. Total unavailable unobligated balance ($68.7 billion) differs 

from unapportioned and expired amounts on the SBR ($69.4 billion) due to the Guaranty 

Agencies’ Federal Funds ($0.7 billion).

In FY 2022 and FY 2021, $289 million and $38 million, respectively 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. (See 

Note 12)

Note 4. Other Assets

(Dollars in Millions)
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Changes in property and equipment balances were as follows.

Property and Equipment

(Dollars in Millions)

Note 5. Loan Receivables, Net and Loan Guarantee Liabilities

Loan Receivables

(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. The net loans receivable increased by $306.5 billion during FY 2022 because 

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 

modifications to the allowance for subsidy for Department-held defaulted FFEL guaranteed 

loans.
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Financial Section 

What follows is additional analysis of the activity, costs, and adjustments 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 $1,428.4 billion in gross loan receivables, as of September 30, 2022, $85.8 

billion (6.0 percent) in loan principal was in default and had been transferred to FSA’s defaulted 

loan servicer, compared to $91.5 billion (6.6 percent) as of September 30, 2021.

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 $36.9 billion during FY 2022 and $21.5 billion during FY 2021. 

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.
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Direct Loan Program Interest Expense and Revenues (See Note 10)

(Dollars in Millions)

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 the 

FSA’s estimated cost to finance the direct loan on a present value basis. The Other 

Components 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 2022 included the 

following:

• Broad-Based Debt Relief. To address the financial harms of the pandemic by 

smoothing the transition back to repayment and helping borrowers at highest risk 
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of delinquencies or default once payments resume, the Department provided 

broad-based debt relief. Borrowers with loans held by the Department who 

received a Pell Grant in college and meet the specified income limits are eligible 

for up to $20,000 in debt relief, while non-Pell Grant recipients who meet the 

specified income limits are eligible for up to $10,000 in relief. Applications for this 

debt relief launched on October 17, 2022. This action resulted in an upward 

modification cost of $361.0 billion in the Direct Loan Program. There was a net 

negative $23.7 billion modification adjustment transfer associated with this 

modification, bringing the total FY 2022 modification cost for the Direct Loan 

Broad-Based Debt Relief to $337.3 billion. 

• Loan Deferral Extension. In FY 2022, the administration extended the student 

loan repayment deferrals through December 31, 202295. The extended relief for 

borrowers resulted in an upward modification cost of $48.4 billion. There was a 

net positive $0.2 billion modification adjustment transfer associated with this 

modification, bringing the total FY 2022 modification cost for the student loan 

repayment deferrals to $48.6 billion. 

• PSLF Waiver. The PSLF Program removes the burden of student debt on public 

servants by cancelling loans after 10 years of payments while the borrower is in 

public service. Temporary changes were made to the program through a Limited 

PSLF Waiver to allow student borrowers to get credit for payments made while 

working for a qualifying employer, regardless of loan type or repayment plan. The 

Waiver, which ran through October 31, 2022, applies to borrowers with Direct 

Loans, those who have already consolidated into the Direct Loan Program, and 

those with other types of federal student loans who submit a consolidation 

application into the Direct Loan Program while the waiver is in effect. These 

temporary changes have resulted in an upward modification cost of $10.1 billion

in the Direct Loan Program. There was a net negative $1.0 billion modification 

adjustment transfer associated with this modification, bringing the total FY 2022

modification cost for the Direct Loan Program PSLF Waiver to $9.1 billion. 

• Income-Driven Repayment (IDR) Waiver one time account adjustment. 

Borrowers on most IDR plans are entitled to forgiveness after 20 years of 

payments and depend on FSA and its servicers to accurately track their progress 

toward relief. However, FSA’s review of IDR payment-tracking procedures 

revealed significant flaws that suggested borrowers had been missing out on 

progress toward IDR forgiveness. To address past issues with IDR payment 

counting, the IDR Waiver allowed any borrower who made IDR-qualifying 

payments to count toward IDR, regardless of repayment plan. Any borrower who 

made the required number of payments for IDR forgiveness based on this 

payment-count revision would receive loan forgiveness automatically, and 

months spent in deferment prior to 2013 would count toward forgiveness as well. 

These changes resulted in an upward modification cost of $16.4 billion during 

FY 2022 in the Direct Loan Program. There was a net negative $2.3 billion

modification adjustment transfer associated with this modification, bringing the 

95 Subsequent to the end of FY 2022, the Administration announced an additional extension of 

the student loan repayment deferrals. (See Note 15) 
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total FY 2022 modification cost for the Direct Loan Program IDR Waiver to 

$14.1 billion.

• Shift to Business Process Operations (BPO). The holder of defaulted federal 

student debt has historically entered into contracts with Private Collection 

Agencies (PCAs) to collect on defaulted student loans. FSA transitioned PCA 

services to new Business Process Operations (BPO) contracts in FY 2022, which 

is estimated to result in lower costs for future defaulted student loan collection 

activities. This action resulted in a downward modification cost (savings) of $10.1 

billion in the Direct Loan Program. There was a net positive $1.0 billion 

modification adjustment transfer associated with this modification, bringing the 

total FY 2022 modification cost (savings) for the Direct Loan Program shift to 

business process operations to $9.1 billion.

Net Upward Subsidy Re-Estimates for All Prior Year Loan Cohorts. The Direct Loan 

Program subsidy re-estimate decreased subsidy expense in FY 2022 by $21.9 billion. Reestimated costs only include cohorts that are 90 percent disbursed (i.e., cohort years 1994–

2021). 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. FSA updated the assumption to reflect changes made in 

recent cycles, including adjustments made for Covid-related Return of Title IV 

Fund claims, the VA-match and SSA-match TPD adjustments, and the change to 

a 30-year distribution. One addition in this update cycle was for an expected 

increase in closed school discharges. The combined effect of these updates led 

to a new upward re-estimate of $2.9 billion. 

• IDR Model Changes. FSA completed a standard IDR data update. The income 

calibration used in the IDR model was updated to use more of the available data 

from NSLDS. The calibration was done by the risk groups used in the model. 

Doing so resulted in a smaller calibration for some groups (especially graduate 

students), which contributed significantly to savings for this component. Data on 

inflation, interest rates, and the poverty line were adjusted to reflect the latest 

current data, as well as OMB's most recent forecasts. Several smaller technical 

updates were made to improve the accuracy and functioning of the IDR model, 

including the handling of payments during the COVID-19 payment pause and 

calculating the percentage of debt allocated to the borrower when jointly repaying 

with the borrower’s spouse. The combined effect of these updates led to a net 

downward re-estimate of $24.0 billion.

• Deferment and Forbearance. FSA updated actual deferment and forbearance 

rates for FY 2021 and calibrated FY 2022 and FY 2023 rates using data from 

FSA on borrower payments made during the period of repayment deferral. The 

combined effect of these changes led to a net upward re-estimate of $2.6 billion.

• Collections. FSA updated the data and calibrated FY 2022 collection rates to 

reflect the extension of the repayment deferral. The combined effect of these 

changes led to a net downward re-estimate of $1.7 billion.
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Financial Section 

• Default. In addition to the adjustments for the extension of the student loan 

repayment deferrals, FSA updated the data and incorporated actual 

unemployment rates from the Bureau of Labor Statistics and projected 

unemployment rates from OMB. The combined effect of these changes led to a 

net upward re-estimate of $3.0 billion

• Repayment Plan Selection. FSA incorporated new repayment plan data through 

FY 2021. This update led to a downward re-estimate of $3.0 billion.

• 2021 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 $7.7 billion for these current-year 

assumption changes attributable to the FY 2021 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 re-estimated subsidy had been included as part of the original subsidy 

estimate. The interest on the re-estimate calculated on the overall subsidy reestimate resulted in a net downward re-estimate of $0.4 billion.

• Interactive Effects. The re-estimate includes a net upward re-estimate of $7.4 

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

• Discount Rates. The rates are used to calculate the NPV of the cash flows to 

create subsidy rates. Adjustments to the 2020 and 2021 cohorts were calculated. 

All other cohorts are actual. The combined effect of these changes led to a net 

downward re-estimate of $16.6 billion.

Direct Loan Subsidy Rates—Cohort 2022

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. 

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 
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borrower and lender rate formulas. Interest rate projections are based on probabilistic interest 

rate scenario inputs developed and provided by OMB.

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. FSA 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 

rate to be used for borrowings received to fund the disbursed portion of the loan awards 

obligated.

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 
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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, 2022, the total principal value of guaranteed loans outstanding and the 

amount of that principal which is guaranteed is approximately $98.6 billion.

Additionally, the FFEL program guarantees outstanding interest balances. As of September 30, 

2022, the interest balances outstanding for guaranteed loans held by lenders was approximately

$4.2 billion.

FSA’s total FFEL program guarantees (principal and interest) are approximately $102.8 billion 

as of September 30, 2022. 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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FFEL Program Subsidy Expense

(Dollars in Millions)

Loan Modifications. Loan modifications for the FFEL Loan program for FY 2022 included the 

following:

• Broad-Based Debt Relief. To address the financial harms of the pandemic by 

smoothing the transition back to repayment and helping borrowers at highest risk 

of delinquencies or default once payments resume, the Department provided 

broad-based debt relief. Borrowers with loans held by the Department who 

received a Pell Grant in college and meet the specified income limits are eligible 

for up to $20,000 in debt relief, while non-Pell Grant recipients who meet the 

specified income limits are eligible for up to $10,000 in relief. Applications for this 

debt relief launched on October 17, 2022. This action resulted in an upward 

modification cost of $18.1 billion in the FFEL Program. There was a net negative 

$2.0 billion modification adjustment transfer associated with this modification, 

bringing the total FY 2022 modification cost for the FFEL Broad-Based Debt 

Relief to $16.1 billion. 

• Loan Deferral Extension. In FY 2022, the administration extended the student 

loan repayment deferrals for Department-held loans through December 31, 

202296. The extended relief for borrowers resulted in an upward modification cost 

of $5.8 billion. There was a net positive $0.1 billion modification adjustment 

transfer associated with this modification, bringing the total FY 2022 modification 

cost for the student loan repayment deferrals to $5.9 billion.

96 Subsequent to the end of FY 2022, the Administration announced an additional extension of 

the student loan repayment deferrals. (See Note 16) 
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Financial Section 

• Support for the Federal Student Loan Reserve Fund. FSA authorized the 

Guaranty Agencies to reimburse themselves from the Federal Fund for lost 

revenue that resulted from the student loan repayment deferrals. 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 $1.1 billion. 

• Shift to Business Process Operations. The holder of defaulted federal student 

debt has historically entered into contracts with PCAs to collect on defaulted 

student loans. FSA transitioned PCA services to new BPO contracts in FY 2022, 

which is estimated to result in lower costs for future defaulted student loan 

collection activities. This action resulted in a downward modification cost 

(savings) of $0.6 billion in the FFEL Loan Program. 

• Shift of FFEL Special Allowance to SOFR. For the purposes of Special 

Allowance Payment calculations on certain FFEL Program loans, lenders or 

beneficial owners were given the option to substitute the 1-month London 

Interbank Offered Rate (LIBOR) for the 3-month commercial paper rate. 

However, as LIBOR is expected to be discontinued by June 2023, lenders and 

servicers in the FFEL Program have begun switching to the Secured Overnight 

Financing Rate (SOFR), permitted by the Consolidated Appropriations Act of 

2022. This shift resulted in an upward modification cost of $0.2 billion. 

Net Upward/(Downward) Subsidy Re-estimates. The total FFEL subsidy re-estimate 

decreased subsidy expense in FY 2022 by $0.6 billion. The net upward re-estimates in the 

FFEL Program were due primarily to updated IDR model changes in the Loan Purchase 

Commitment and Loan Participation Purchase programs.

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.
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Allowance for Subsidy Reconciliation for Acquired FFEL Loans

(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 
Fiscal Year 2022 Annual Report | Federal Student Aid 193

Financial Section 

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 $393 million and $79 million for FY 2022 and FY 

2021, respectively.

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 $689 

million and $850 million to FSA in FY 2022 and FY 2021, respectively, for the federal share of 

collected cash.

Schools will continue to service outstanding Perkins loans to recover the money they 

contributed to their Perkins funds for as long as it is feasible to do so or until the eventual winddown 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 2022-2023 

reporting year shows a $2.6 billion outstanding principal balance on Perkins loans held by 

schools, and FSA’s equity interest on this portfolio is $2.2 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. (See Note 12)

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. 
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Loan modifications for the TEACH Program for FY 2022 included the following:

• Broad-Based Debt Relief. This action resulted in an upward modification cost of 

$55 million in the TEACH Program for Department-hold TEACH Program loans. 

There was a net negative $4 million modification adjustment transfer associated 

with this modification, bringing the total FY 2022 modification cost for the TEACH 

Broad-Based Debt Relief to $51 million.

• Loan Deferral Extension. In FY 2022 the administration extended the student 

loan repayment deferrals through December 31, 202297 for Department-held 

TEACH Program loans. The extended relief for borrowers resulted in an upward 

modification cost of $16 million. There was a net positive $1 million modification, 

bringing the total FY 2022 modification for student loan repayment deferrals to 

$17 million.

• Shift to Business Process Operations. This action resulted in a downward 

modification cost (savings) of $2 million in the TEACH Program.

TEACH Subsidy Rates—Cohort 2022

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. In FY 2022 the 

administration extended the student loan repayment deferrals through December 31, 202298. 

The extended relief for borrowers resulted in an upward modification cost of $1.5 million. There 

was a net negative $0.1 million modification adjustment transfer associated with this 

modification, bringing the total modification cost to $1.4 million.

97 Subsequent to the end of FY 2022, the Administration announced an additional extension of 

the student loan repayment deferrals. (See Note 16) 

98 Subsequent to the end of FY 2022, the Administration announced an additional extension of 

the student loan repayment deferrals. (See Note 16) 
Fiscal Year 2022 Annual Report | Federal Student Aid 195

Financial Section 

Note 6. Liabilities Not Covered by Budgetary Resources

Liabilities Not Covered

(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. During FY 2022, debt decreased

25.9 percent from $1,221.1 billion in the prior year to $905.0 billion. 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 92.5 percent of FSA’s debt, as of September 30, 2022, is attributable to the 

Direct Loan program. Most of the new borrowing activity for the year was designated for funding 

new direct loan disbursements.

FSA also borrows from Treasury for activity in the Other Credit Programs for Higher Education. 

During FY 2022, TEACH net borrowing was $(96) million, as repayments to Treasury were 
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Financial Section 

greater than borrowing. This was used for the advance of new grants and repayments of 

principal made to Treasury.

Note 8. Subsidy Due to Treasury

(Dollars in Millions)

Note 9. Other Liabilities

(Dollars in Millions)
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Financial Section 

Note 10. Net Cost

Gross Costs and Exchange Revenue by Program

(Dollars in Millions)
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Financial Section 

Gross Costs and Exchange Revenue by Program

(Dollars in Millions)
Fiscal Year 2022 Annual Report | Federal Student Aid 199

Financial Section 

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 temporarily suspend nearly all required federal student 

loan payments and set borrower interest rates to zero percent, no new interest revenues were 

recognized in FY 2021 and FY 2022. However, interest adjustments and reapplication activities

are 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

2021 and FY 2022 interest revenues for the Direct Loan Program and the FFEL Program.

Grant Expenses

(Dollars in Millions)
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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.

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. This program is administered by the schools that participate in the 

Federal Work-Study program. 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 11. COVID-19 Activity 

(Dollars in Millions)

The COVID-19 relief legislation and administrative actions also provided support for student 

loan borrowers by:
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Financial Section 

• Proposing broad-based debt relief to address the financial harms of the 

pandemic by smoothing the transition back to repayment and helping borrowers 

at the highest risk of delinquencies or default once payments resume. 

Applications for this debt relief launched on October 17, 2022.

• Suspending nearly all federal student loan payments through December 31, 

2022, interest free. 

• Authorizing Guaranty Agencies to reimburse themselves from the Federal 

Student Loan Reserve Fund for lost revenue that resulted from student loan 

repayment deferrals. This reimbursement covers the share of what a guaranty 

agency might have reasonably collected during the pandemic, but for the 

suspension.

• Making temporary changes to the PSLF program through a Limited PSLF Waiver 

to allow student borrowers to get credit for payments made while working for a 

qualifying employer, regardless of loan type or repayment plan. 

• Addressing issues with IDR payment counting by allowing any borrower who 

made IDR-qualifying payments to count toward IDR, regardless of repayment 

plan.

Funding for each of 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 10)

In addition, other COVID-19 relief provided to student loan borrowers included the following:

• FSA stopped all federal wage garnishments and collection actions for borrowers 

with federally held loans in default.

• FSA provided relief for certain borrowers who received student loan discharges 

due to total and permanent disability. Unless it is through a process with the VA, 

borrowers receiving this discharge are, by regulation, subject to a three-year 

monitoring period during which they must provide FSA with information about 

their earnings from employment. Per regulation, borrowers whose earnings 

exceed certain thresholds and borrowers who do not meet certain other criteria 

will have their loans reinstated. FSA provided relief to ensure no borrowers are at 

risk of having their loans reinstated, meaning they would have to repay their 

debt—for failure to provide earnings information during the COVID-19 

emergency. This change was made retroactive to March 13, 2020, the start of 

the COVID-19 national emergency.

• FSA requested a waiver from the Small Business Administration to immediately 

help nearly 30,000 small business owners in the Paycheck Protection program 

who faced difficulties because they were delinquent or in default on a federal 

student loan.
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Note 12. Statements of Budgetary Resources

The SBR compares budgetary resources with the status of those resources. As of September 

30, 2022, budgetary resources were $824.4 billion and net agency outlays were $511.2 billion. 

As of September 30, 2021, budgetary resources were $381.0 billion and net agency outlays 

were $164.2 billion.

Net Adjustments to Unobligated Balances Brought Forward

(Dollars in Millions)

During the periods ended September 30, 2022, and September 30, 2021, certain adjustments 

were made to the balance of unobligated budgetary resources available as of October 1, 2021, 

and October 1, 2020. These adjustments include, among other things, recoveries of prior year 

unpaid obligations that result 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.
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Undelivered Orders at the End of the Period

(Dollars in Millions)

Undelivered orders represent the amount of goods and/or services ordered that have not been 

actually or constructively received. The paid amount includes 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 and negative 

subsidies. 

Reconciliation of SBR to Budget of the United States Government

(Dollars in Millions)
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The FY 2024 President’s Budget, which presents the actual amounts for the year ending 

September 30, 2022, has not been published as of the issue date of these financial statements. 

The FY 2024 President’s Budget is scheduled for release in February 2023 and will be made 

available on OMB’s website. The table above reconciles the FY 2021 SBR to the FY 2023 

President’s Budget (FY 2021 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 

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.

Note 13. Reconciliation of Net Cost to Net Outlays

(Dollars in Millions)
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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 

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 re-estimates 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 14. 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.
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Guaranty Agencies

FSA may assist guaranty agencies experiencing financial difficulties. FSA has not done so in FY 

2022 or 2021 and does not expect to in future years. No provision has been made in the 

financial statements for potential liabilities.

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, 2022. The final 

disposition of claims filed and those yet to be filed from loans originated before September 30, 

2022, is not expected to have a material impact on these financial statements.

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. 

NOTE 15. Subsequent Events 

On November 10, 2022, a U.S. District Court in Texas issued an order to vacate the program for 

Broad-Based Debt Relief that was previously adopted by the U.S. Secretary of Education and 

announced on August 24, 2022. On November 14, 2022, the U.S. Court of Appeals for the 

Eighth Circuit stayed the Department’s implementation of the same program pending an appeal 

by six states of their case challenging the relief, on which the Department had prevailed in a 

U.S. District Court. The U.S. Department of Education subsequently requested a stay of both 

decisions, and ultimately sought stays as well as a hearing on the merits from the Supreme 

Court of the United States. Those stay requests were denied, but the Supreme Court of the 

United States granted certiorari and has agreed to hear both cases and to address both 

questions of standing and the Department’s authority to provide the debt relief. The Department 

is confident in its position in these matters before the Court.

On November 22, 2022, the Department announced that it would be extending the existing 

pause on student loan repayments through a period which would be largely determined by the 

court cases mentioned previously. The pause has been extended until 60 days after the 

Department is permitted to implement the program or the litigation is resolved. If the program 

has not been implemented and the litigation has not been resolved by June 30, 2023, payments 

will resume 60 days after that.
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Required Supplementary Information (Unaudited) 
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Independent Auditors’ Report

Office of Inspector General Audit Transmittal

 
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Independent Auditors’ Report
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Other Information 

Other Information (Unaudited)
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Other Information 

Summary of Financial Statement Audit and Management 

Assurances

The following table provides a summarized report of FSA’s financial statement audit.

Audit Opinion: Disclaimer of Opinion

Restatement: No

Table 61: Summary of Financial Statement Audit 

Material Weaknesses Beginning 

Balance New Resolved Consolidated Ending Balance

Total Material Weaknesses 1 1 0 1 1 

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 2023 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 2022, 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

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 

metric targets that were made during the strategic plan annual update. 

In FY 2022, no revisions were made to the performance metrics or targets due to the close-out 

of the current strategic plan and the expected implementation of a new strategic plan in FY 2023 
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Appendix B: Data Validation and Verification Matrix

Appendix B provides data validation and verification information for all performance metrics 

included within the five Strategic Goals of the current FSA strategic plan.

Strategic Goal 1: Empower a High-Performing Organization

Table 62: Performance Data Validation and Verification for Metric 1.1

Performance Metric 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.

Data Source FY 2022 FEVS survey.

Data Validation and Verification

OPM has been conducting FEVS since 2002 and maintains a 100 

percent accuracy rate for employee security and data integrity. One 

limitation is that the survey results are provided in real time, and there is 

at least a one quarter delay in receipt by agencies. This may limit the 

true interpretation of the data, in that leadership changes, employee 

attrition and a shift in organizational priorities may impact the relevance 

of the data. FSA will continue using tools such as pulse surveys and 

focus group data to assist with employee engagement and other 

organizational improvements based on feedback. 

Table 63: Performance Data Validation and Verification for Metric 1.2.A

Performance Metric 1.2.A

Identification, validation, assessment, and prioritization of 

skill competencies, required grades, and strategic 

alignment in accordance with the workforce requirements 

study results.

Data Source

U.S. Department of Interior Business Center Payroll/Personnel Data, 

qualitative interview, and resource information from internal FSA 

sources. 

Data Validation and Verification

Data from FSA’s internal personnel system provided an organizational 

resource picture (i.e., the number of staff onboard by organization, 

occupation, grade, and/or other attributes) for approximately 1,225 

positions, or roughly 85% of the FSA workforce in the study baseline. 

Front offices were not included in the analysis based on nature of their 

work, small sizes, and standard staffing patterns. The required number 

of staff per organizational business unit, from which specific staffing 

needs can be computed, was generated from a staffing dashboard 

developed by FSA’s contractor. The needs or staffing gap computation 

utilizes current staffing onboard and required staffing determined by the 

study to derive a numeric and percentage staffing gaps for each 

organizational element covered by the study. 

The Study results can also be used to assist FSA with tools that will 

enable tracking of full-time equivalent staff and financial execution (i.e., 

average onboard staffing and aggregate salaries over the course of a

fiscal year). This calculation, in conjunction with the staffing gap 

computation, will provide a more accurate picture of FSA's 

requirements and capabilities beyond the historical onboard staffing 

snapshots that have typically been produced.
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Table 64: Performance Data Validation and Verification for Metric 1.2.B

Performance Metric 1.2.B Conduct targeted multi-year training based on identified 

workforce needs.

Data Source FedTalent system, FSA staffing reports, training data reports, 

participant feedback, course attendance and FSA Training Database. 

Data Validation and Verification

FedTalent, the Department of Education’s learning management 

system, was used as the primary source to track individual and 

cumulative training completion data. Courses, whether virtual instructorled or self-paced, are placed in the LMS. Course completions are also 

tracked through participant self-certification by a course code provided 

to and submitted by participants or checkbox marker, learning platform 

attendance records, or facilitator attendance records. The data is 

integrated from FedTalent into FSA’s Training Database to calculate 

and verify statistics like percentage of employees trained, types of 

trainings attended, modality of training, and number of initiatives 

delivered by FSA. 

Table 65: Performance Data Validation and Verification for Metric 1.2.C

Performance Metric 1.2.C Perform a training analysis at each performance review 

period within the fiscal period.

Data Source Course evaluations, facilitator observations, FSA Training Database, 

and Momentive (formerly called SurveyMonkey). 

Data Validation and Verification

FSA used the FSA Training Database, an internal training data analysis 

and validation tool, and Momentive to collect, track and compare data 

across training iterations to identify various performance trends. FSA 

courses used various assessment instruments and data sets such as 

formative and summative data collection mechanisms, Kirkpatrick Level 

evaluations, participant anecdotal feedback, and after-action 

briefings/reports. To gauge participant knowledge within these specified 

trainings and allow for the application of learning to address real-life 

situations or leadership problems/challenges Kirkpatrick Level 

evaluations were administered during and/or post-training. 

For the managerial trainings and developmental programs directed at 

enhancing leadership competencies, action-based learning through 

individual activities, group capstone projects, and/or course Level 1 

evaluations were used. The limitations of the data are the inability to 

sync various databases and data sources into one platform to allow for 

a seamless migration and calculation of data. The FSA Training 

Database was developed as an interim stopgap mechanism; a longterm solution must be identified to ensure training trends and target 

areas of need are fully captured.
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Strategic Goal 2: Provide World-Class Customer Experience to the Students, Parents and 

Borrowers We Serve 

Table 66: Performance Data Validation and Verification for Metric 2.1.A

Performance Metric 2.1.A Number of visits (sessions) demonstrating adoption of the 

updated StudentAid.gov site.

Data Source FSA’s online platform analytics.

Data Validation and Verification

The data is an absolute number so no calculation and methodology are 

performed. The indicator is a direct reflection of the data platform 

analytics. FSA constantly monitors the analytics platform to ensure the 

system is secure and the query results are consistent. The indicator 

value is based on the number of visits (as opposed to unique visitors or 

page views). FSA operational systems have procedures in place to 

address potential data quality issues. 

The process for querying system data is consistent and disciplined. A 

separate data analyst from a different office within FSA validates the 

accuracy of the query and the resulting data and validates any 

anomalous data. The Customer Analytics Group is responsible for the 

primary calculation of the indicator as well as the technical validation of 

the indicator, which is done by reviewing for accuracy the query used to 

pull the data.

Table 67: Performance Data Validation and Verification for Metric 2.1.B

Performance Metric 2.1.B Percentage of high school seniors submitting the FAFSA.

Data Source FSA’s online platform analytics. 

Data Validation and Verification

FSA operational systems have procedures in place to address potential 

data quality issues. The process for querying system data is consistent 

and disciplined. A separate data analyst from a different office within 

FSA validates the accuracy of the query and the resulting data and

validates any anomalous data. Queries and calculations are 

simultaneously conducted on data from previous years by FSA’s 

Business Intelligence Team to ensure technical definitions remain 

consistent. The Customer Analytics Group is responsible for the 

primary calculation of the indicator as well as the technical validation of 

the indicator, which is done by reviewing for accuracy the query used to 

pull the data and all calculations made with the data. 

The data is pulled from the FSA’s Central Processing System. Finally, 

the Financial Reporting and Analysis Branch is responsible for ensuring 

that documentation is complete and archived. These calculations also 

restrict the application period to the first nine months of the application 

cycle (through the close of the fiscal year) rather than the entire 18 

months. Since most applicants, including high school seniors, file their 

FAFSA prior to the start of the upcoming academic year (usually before 

fiscal year end), this decision better aligns the performance indicator 

with the fiscal year where most of the performance occurred.
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Table 68: Performance Data Validation and Verification for Metric 2.1.C

Performance Metric 2.1.C Number of customers submitting the FAFSA via a mobile 

platform—the myStudentAid mobile app or fafsa.gov.

Data Source FSA’s online platform analytics. 

Data Validation and Verification

The data is an absolute number so no calculation and methodology are 

performed. The indicator is a direct reflection of the data platform 

analytics. FSA constantly monitors the analytics platform to ensure the 

system is secure and the query results are consistent. FSA operational 

systems have procedures in place to address potential data quality 

issues. The process for querying system data is consistent and 

disciplined.

A separate data analyst from a different office within FSA validates the 

accuracy of the query and the resulting data and validates any 

anomalous data. The Customer Analytics Group is responsible for the 

primary calculation of the indicator as well as the technical validation of 

the indicator, which is done by reviewing for accuracy the query used to 

pull the data.

Table 69: Performance Data Validation and Verification for Metric 2.1.D

Performance Metric 2.1.D Persistence among first-time filing aid recipients.

Data Source EDWA. 

Data Validation and Verification

Data results are ascertained through standardized system queries. 

These queries are used to rerun and match calculations for earlier 

cycles as part of the verification and validity assessment. 

Table 70: Performance Data Validation and Verification for Metric 2.2.A

Performance Metric 2.2.A Number of customers checking loan balances via the 

myStudentAid mobile app.

Data Source FSA’s online platform analytics.

Data Validation and Verification

The data is an absolute number as the number of customers checking 

their loan balances, so no calculation and methodology are 

performed. This metric is a direct reflection of the data platform 

analytics. FSA monitors to ensure the system is secure and the query 

results are consistent. FSA operational systems have procedures in 

place to address potential data quality issues. The process for querying 

system data is consistent and disciplined.

A separate data analyst from a different office within FSA validates the 

accuracy of the query and the resulting data and validates any 

anomalous data. The Customer Analytics Group is responsible for the 

primary calculation of the metric as well as the technical validation of 

the metric, which is done by reviewing for accuracy the query used to 

pull the data.
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Table 71: Performance Data Validation and Verification for Metric 2.2.B

Performance Metric 2.2.B Number of borrowers who view their aid summary 

information on StudentAid.gov.

Data Source FSA’s online platform analytics.

Data Validation and Verification

The data is an absolute number as the value is based on the number of 

users (as opposed to sessions or page views), so no calculation and 

methodology are performed. This metric is a direct reflection of the data 

platform analytics. FSA monitors to ensure the system is secure and 

the query results are consistent. FSA operational systems have 

procedures in place to address potential data quality issues. The 

process for querying system data is consistent and disciplined.

A separate data analyst from a different office within FSA validates the 

accuracy of the query and the resulting data and validates any 

anomalous data. The Customer Analytics Group is responsible for the 

primary calculation of the metric as well as the technical validation of 

the metric, which is done by reviewing for accuracy the query used to 

pull the data.

Table 72: Performance Data Validation and Verification for Metric 2.2.C

Performance Metric 2.2.C Number of users of “Aidan,” the StudentAid.gov virtual 

assistant.

Data Source FSA’s online platform analytics.

Data Validation and Verification

This metric is a direct reflection of the data platform analytics. FSA 

monitors to ensure the system is secure and the query results are 

consistent. The total users are defined as individuals that interact with 

Aidan beyond the initial greeting button prompt provided to customers. 

An FSA contractor performs a two-step validation of the Aidan data in 

the DCC Tableau system prior to sharing with FSA.

Table 73: Performance Data Validation and Verification for Metric 2.2.D

Performance Metric 2.2.D Transactional email volume for outreach and 

communications to customers.

Data Source MCP. 

Data Validation and Verification

There is no calculation necessary for this metric. It is reported by 

the MCP system. Several data analysts pull the system data, and a 

data analyst validates the numbers.
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Table 74: Performance Data Validation and Verification for Metric 2.2.E

Performance Metric 2.2.E Recurring campaign email delivery volume for outreach and 

communications to customers.

Data Source MCP.

Data Validation and Verification

There is no calculation necessary for this metric. It is reported by 

the MCP system. Several data analysts pull the system data, and a 

data analyst validates the numbers. 

Table 75: Performance Data Validation and Verification for Metric 2.2.F

Performance Metric 2.2.F American Customer Satisfaction Index (ACSI) Aid Lifecycle 

Survey score.

Data Source MSS, FAFSA.gov (housed on StudentAid.gov), and (federal 

student aid recipients) In-School customer satisfaction survey. 

Data Validation and Verification

Traditionally, the ACSI survey has been conducted annually for FSA’s

major programs. The index provides a national, cross-industry, crosssector economic indicator, using widely accepted methodologies to 

obtain standardized customer satisfaction information. Survey scores

are indexed on a 100-point scale. The ACSI scores for application, inschool experience, and servicing are weighted by the utilization of each 

process/service and the intensity of the service provided. This metric is

a direct reflection of the data collected through the ACSI Aid Life Cycle 

Survey. 

FSA monitors to ensure the system is secure and the query results are 

consistent. This metric is calculated by using weighted customer 

satisfaction scores from the Multiple Servicer Survey, FAFSA.gov and 

the In-School customer satisfaction survey. Several data analysts pull 

the data, and a data analyst validates the numbers. 

Table 76: Performance Data Validation and Verification for Metric 2.2.G

Performance Metric 2.2.G Customer Satisfaction Survey(s) for StudentAid.gov site 

and associated tools.

Data Source FSA customer feedback system.

Data Validation and Verification

This metric intends to measure customer satisfaction with the 

StudentAid.gov website. These customer satisfaction surveys will assist 

FSA in developing additional tools and offering website improvements 

based on customer feedback. 
Fiscal Year 2022 Annual Report | Federal Student Aid 245

Appendices

Table 77: Performance Data Validation and Verification for Metric 2.3.A

Performance Metric 2.3.A Quality Standard for Average Speed to Answer (ASA) at all 

Call Centers.

Data Source Federal servicers’ quarterly reports.

Data Validation and Verification

The verification and validation of performance by the nondefault federal 

student loan servicers is conducted by FSA and includes (but is 

not limited to): (1) review and validation of federal servicer reports; (2) 

ongoing/recurring quality assurance discussion with federal servicers; 

(3) site visits to federal servicer call center sites; and (4) documented

on-phone (“mystery caller”) evaluations of services. Because the

agency directive is succinct and builds on current contractor operational

capabilities, FSA does not anticipate anomalous data or issues with

implementation. However, in cases where verification and validation

detect anomalies that suggest less-than-complete information, FSA will

address any deficiencies through direct contact with federal servicers,

requests for information, audits, site visits, and/or other assessment

measures of performance, as applicable.

Table 78: Performance Data Validation and Verification for Metric 2.3.B

Performance Metric 2.3.B Quality Standard for Abandon Rate (AR) for Incoming Calls 

at all Call Centers.

Data Source Federal servicers’ quarterly reports.

Data Validation and Verification

The verification and validation of performance by the nondefault federal 

student loan servicers is conducted by FSA and includes (but is not 

limited to): (1) review and validation of federal servicer reports; (2) 

ongoing/recurring quality assurance discussion with federal servicers; 

(3) site visits to federal servicer call center sites; and (4) documented

on-phone (“mystery caller”) evaluations of services. Because the

agency directive is succinct and builds on current contractor operational

capabilities, FSA does not anticipate anomalous data or issues with

implementation. However, in cases where verification and validation

detect anomalies that suggest less-than-complete information, FSA will

address any deficiencies through direct contact with federal servicers,

requests for information, audits, site visits, and/or other assessment

measures of performance, as applicable.
246 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Table 79: Performance Data Validation and Verification for Metric 2.4.A

Performance Metric 2.4.A Number of borrowers using Make a Payment feature to pay 

student loans.

Data Source DCC Web Logs. 

Data Validation and Verification

No calculation is necessary as the data is an absolute number reported 

to FSA from the DCC Web Logs. This figure represents the number of 

student loan payments made on StudentAid.gov. FSA is unable to 

provide the unique number of customers who made payments. A 

separate data analyst pulls the data and then a different analyst pulls 

the data independently to validate the accuracy of the information and 

any anomalous data.

Table 80: Performance Data Validation and Verification for Metric 2.4.B

Performance Metric 2.4.B Percentage of borrowers using auto-debit.

Data Source NSLDS® database.

Data Validation and Verification

Enrollment in auto debit is reported by federal loan servicers to the 

NSLDS database. 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. NSLDS queries and 

calculations are validated by FSA's Data Review Team for accuracy. 

Table 81: Performance Data Validation and Verification for Metric 2.4.C

Performance Metric 2.4.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.
Fiscal Year 2022 Annual Report | Federal Student Aid 247

Appendices

Strategic Goal 3: Increase Partner Engagement and Oversight Effectiveness

Table 82: Performance Data Validation and Verification for Metric 3.1.A

Performance Metric 3.1.A

FSA will annually conduct an Institutional Review for its 

participating partners including schools, third-party 

servicers, and financial institutions.

Data Source PEPS. 

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 

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 

PPO performed a compliance review is compared with an unduplicated 

count of participating institutions to calculate the actual percentage for 

this performance metric.

Table 83: Performance Data Validation and Verification for Metric 3.1.B

Performance Metric 3.1.B Number of Borrower Defense (BD) applications adjudicated 

(subject to existing BD regulations).

Data Source Customer Engagement Management System. 

Data Validation and Verification

Weekly production data is derived from the borrower defense case 

management platform which tracks progress and status of borrower 

defense applications through intake, adjudication, borrower notification, 

and loan servicer documentation on effectuated loan relief, where 

applicable. Weekly data verification reviews are coordinated among the 

business unit and FSA’s enterprise data office. This production data is 

reported in weekly performance metrics evaluated by FSA and 

Department Senior Leadership.
248 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Table 84: Performance Data Validation and Verification for Metric 3.2.A

Performance Metric 3.2.A FSA will measure institutional participation rates in Title IV 

training and specialized technical assistance programs

Data Source FSA LMS, PEPS, eZ-Audit, PCnet, FSA Data Center, and NSLDS 

database.

Data Validation and Verification

The activity is primarily a manual count (e.g., manual inbox count of 

Ask-a-Fed email inquiries), but FSA does remove duplicate OPEIDs to 

ensure its participation rate is non-duplicative. OPEID is self-reported 

by users of the training system. Reports run in the LMS 

(fsatraining.ed.gov) identify users of the site. The report is exported to 

Excel and manipulated to remove users without an OPEID and 

duplicate OPEIDs. The Federal Student Aid Training Center registrant 

data is also received from the conference team. 

Data is pulled from CVENT for registrants at state and regional 

association conferences where TISG staff presented. This data is 

merged with the LMS data to produce a list of OPEIDs who have 

received training. To minimize errors, the assessment process consists 

of batch loading the performance data in excel spreadsheets from the 

source databases into the Salesforce assessment tool. 

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 

OPEID v Main Campus) and manual counts of user emails can affect 

the consistency of the information used for analysis. 

Table 85: Performance Data Validation and Verification for Metric 3.2.B

Performance Metric 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.

Data Source FSA LMS.

Data Validation and Verification

This performance metric is a numerical count of changes within a 

defined electronic training environment. The TISG tracks additions, 

modifications, and removals within the FSA Training Center 

(fsatraining.ed.gov). 
Fiscal Year 2022 Annual Report | Federal Student Aid 249

Appendices

Table 86: Performance Data Validation and Verification for Metric 3.2.C

Performance Metric 3.2.C Ease of doing business with FSA.

Data Source FY 2022 Schools Partners Survey.

Data Validation and Verification

This performance metric is based on calculations from CFI Group. The 

FSA project officer verifies the FY 2022 School Partners survey scores 

for the Ease of Doing Business with FSA metric and coordinated 

validation through FSA Data Review Team. The survey contractor 

collects this data and calculates the results and presents findings and 

conclusions to FSA.

Strategic Goal 4: Strengthen Data Protection and Cybersecurity Safeguards

Table 87: Performance Data Validation and Verification for Metric 4.1

Performance Metric 4.1

Increase partner/vendor cybersecurity effectiveness by 

reducing the total number of FSA system assessment 

findings by 20% per year.

Data Source FSA Enterprise Cybersecurity Group, Department Cybersecurity 

Assessment and Management Shared Service.

Data Validation and Verification

The data for this performance metric is provided by the assessments 

conducted and utilized by the OCIO for the Department’s monthly 

cybersecurity scorecard. Data is verified through the assessment 

process as defined by the National Institute of Standards and 

Technology, the Department, and FSA guidance. The plan of action 

and milestone is a description of the vulnerability findings using the 

National Vulnerability Database.

Table 88: Performance Data Validation and Verification for Metric 4.2.A

Performance Metric 4.2.A

Increase Institutions of Higher Education cybersecurity 

effectiveness by reducing GLBA cybersecurity noncompliance by 20% per year.

Data Source The record of GLBA Audits managed by Partner Connect.

Data Validation and Verification

The performance metric is a numerical count of the cybersecurity 

related audit findings. The finding count is provided by the Partner 

Connect staff and verified against the findings posted in eZ-Audit by the 

Technology Directorate.
250 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Table 89: Performance Data Validation and Verification for Metric 4.2.B

Performance Metric 4.2.B Reduce incident reporting time at Institutions of Higher 

Education.

Data Source Self-reports from the schools, discovery through media reports, and 

information derived from internet research activities.

Data Validation and Verification

The calculation of this performance metric is from the date, hour, and 

minute that the school detected the event to the time that FSA receives 

the report. In the event the school does not provide the information, the 

time is calculated from the time FSA discovers the cybersecurity 

incident and the time that FSA is able to contact the appropriate school 

point of contact at the institution. The data is verified through a manual 

audit process comparing the security event report received from the 

school and the data discovered through incident response process with 

the data within SecOps.

Table 90: Performance Data Validation and Verification for Metric 4.3

Performance Metric 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.

Data Source FSA SecOps, email reports, phishing exercise results, and OCIO DLP 

metrics.

Data Validation and Verification

The performance metric is a numerical count of events-based exercise 

results and actual incident reports over time. The data is validated 

through a manual review of automated reports from SecOps, which 

provide the test results for the cybersecurity exercises administer to 

employees.

Strategic Goal 5: Enhance the Management and Transparency of the Portfolio

Table 91: Performance Data Validation and Verification for Metric 5.1.A

Performance Metric 5.1.A Initiate monthly reporting to the public through the FSA 

data center.

Data Source FSA data request process and queries 

Data Validation and Verification

FSA leverages a data request process to ensure queries are written by 

one subject matter expert and validated separately by a second subject 

matter expert to help ensure consistency and accuracy. Queries used 

to produce FSA Data Center reports are required to go through this 

data request process. Subject matter experts also review results prior to 

publication to help identify any potential areas of concern.
Fiscal Year 2022 Annual Report | Federal Student Aid 251

Appendices

Table 92: Performance Data Validation and Verification for Metric 5.1.B

Performance Metric 5.1.B Outstanding Direct Loan Portfolio in Current Repayment 

Status.

Data Source NSLDS database.

Data Validation and Verification

The calculation uses the rounded results appearing in the FSA Data 

Center’s Direct Loan Delinquency report. The fiscal year metric is a 

moving average of the four quarters. It is the outstanding principal and 

interest balance of “current” Direct Loans in the active repayment status 

divided by the total principal and interest balance of Direct Loans in an 

active repayment status at the non-default servicers. FSA validated the 

report when it was implemented, and subject matter experts review the 

results each month to assess data quality and initiate efforts to 

diagnose and resolve any anomalies.

Table 93: Performance Data Validation and Verification for Metric 5.2.A

Performance Metric 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.

Data Source Stakeholders’ surveys and ERM Maturity Matrix. 

Data Validation and Verification

The Risk Maturity Matrix is directly linked to the Committee of 

Sponsoring Organizations of the Treadway Commission ERM 

Framework, Enterprise Risk Management: Integrating with Strategy and 

Performance. The data is derived from surveys to stakeholders 

throughout the organization and is compiled and assessed against the 

ERM Maturity Matrix. The evaluation and validation of data is subjective 

within guidelines established by the model.

Table 94: Performance Data Validation and Verification for Metric 5.2.B

Performance Metric 5.2.B Implementation timeline for FUTURE Act. 

Data Source N/A

Data Validation and Verification

The FUTURE Act team continues to work closely with other offices 

within the Department, the IRS, and Treasury to establish a FUTURE 

Act implementation schedule. While the team has established a 

notional implementation schedule, all offices continue to work on critical 

dependencies to finalize the implementation schedule. Variances to the 

schedule caused by these dependences will impact the quality of the 

implementation timeline. The FUTURE Act team also works closely with 

the ERM Office to monitor any risks and limitations.
252 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Table 95: Performance Data Validation and Verification for Metric 5.3.A

Performance Metric 5.3.A Identify and provide intervention actions for customers at 

risk of default.

Data Source FSA’s project plans for each individual intervention project. 

Data Validation and Verification

This performance metric will leverage high-level project data as its 

source: the project plans FSA uses for each individual intervention 

project, and possibly include specific measures to be determined on a 

project-by-project basis. The projects within the default prevention 

definition are expected to use new interventions and actions to reduce 

customer risks, therefore it is necessary to first collect data on customer 

outcomes given they have received the new interventions and actions 

to support Contextual Bandits model training.

Different methodologies for initially collecting data have been designed 

and implemented in a reusable fashion. Contextual Bandits models 

have been designed to further collect required model training data, 

incorporating experimental design into the model development process. 

Data collected from projects for use in creating and updating models 

has a high probability of bias due to impacts from COVID-19, especially 

when analyzing outcomes of default, based on the CARES Act 

forbearance. 

Table 96: Performance Data Validation and Verification for Metric 5.3.B

Performance Metric 5.3.B Default rate by borrower count.

Data Source NSLDS database.

Data Validation and Verification

The metric leverages a report that is 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. Because the 

nature of this metric is to compare to same quarter of earlier years and 

to calculate rolling four-quarter averages, this helps facilitate spotting 

anomalies. FSA also continues to monitor overall performance of the 

federal loan servicers to identify any areas where errors have occurred 

and notifies servicers of results and corrective actions as needed. By 

design, the data directorate is separated from the servicers' staff and 

systems, so there is currently no direct communication between EDD 

and loan servicers to verify servicer reporting. For this reason, the data 

directorate worked with the servicer monitoring team during FY 2020 

and FY 2021 to address reporting issues identified.
Fiscal Year 2022 Annual Report | Federal Student Aid 253

Appendices

Table 97: Performance Data Validation and Verification for Metric 5.3.C

Performance Metric 5.3.C Percent of borrowers > 90 days delinquent.

Data Source NSLDS database.

Data Validation and Verification

The calculation uses the rounded results appearing in the FSA Data 

Center’s Direct Loan Delinquency report. The fiscal year metric is a 

moving average of the four quarters. This allows FSA to account for 

changes relating to seasonality and indirect factors that could be false 

indicators of change. FSA also continues to monitor overall 

performance of the federal loan servicers to identify any areas where 

errors have occurred and notifies servicers of results and corrective 

actions as needed. 

Table 98: Performance Data Validation and Verification for Metric 5.3.D

Performance Metric 5.3.D Percentage of borrowers who did not make the first three 

payments.

Data Source EDWA servicing data.

Data Validation and Verification

EDWA receives data from the Direct Loan servicers over the Student 

Aid Internet Gateway connection/interface. Each Direct Loan servicer 

reports weekly, and not all on the same day. The Direct Loan servicers 

report on different days of the week to manage FSA’s operational 

burden. FSA monitors overall performance of the federal loan servicers 

to identify any areas where errors have occurred and notifies servicers 

of results and corrective actions as needed.

Table 99: Performance Data Validation and Verification for Metric 5.4

Performance Metric 5.4 Conduct three vendor examinations annually.

Data Source Internal OIO reports. 

Data Validation and Verification The performance metric is calculated by the number of completed 

quality assurance reviews for all loan servicers.
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Fiscal Year 2022 Annual Report | Federal Student Aid 255

Appendices

Appendix C: Glossary of Acronyms and Terms

Acronym Description 

A

ABCP Conduit Asset-Backed Commercial Paper Conduit

ACICS Accrediting Council for Independent Colleges and Schools

the Acknowledgment Annual Student Loan Acknowledgment

ACSI American Customer Satisfaction Index

AFR U.S. Department of Education FY 2022 Agency Financial Report

Annual Report Federal Student Aid Fiscal Year (FY) 2022 Annual Report

APG Agency Priority Goal

AR Abandon Rate

ASA Average Speed to Answer

ATO Authorities to Operate

B

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

CDM Continuous Diagnostics and Mitigation

CDR Cohort Default Rate

CISA Cybersecurity and Infrastructure Agency

Clery Act Jeanne Clery Disclosure of Campus Security Policy and Campus 

Crime Statistics Act

COD Common Origination and Disbursement

Congress U.S. Congress

COO Chief Operating Officer

COVID-19 Coronavirus Disease 2019
256 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Acronym Description 

C

CRI Common Review Initiative

CSRS Civil Service Retirement System

D

DCC Digital Customer Care

DDB Death, Disability, and Bankruptcy

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

DLP Data Leakage Prevention

DMCS Debt Management and Collection System

DOL U.S. Department of Labor

E

ECASLA Ensuring Continued Access to Student Loans Act of 2008

EDD Enterprise Data Directorate

EDWA Enterprise Data Warehouse and Analytics

EEI Employee Engagement Index

ERM Enterprise Risk Management

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

F

FA-DDX FUTURE Act Direct Data Exchange interface

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

FECA Federal Employees’ Compensation Act

Federal Fund Federal Student Loan Reserve Fund
Fiscal Year 2022 Annual Report | Federal Student Aid 257

Appendices

Acronym Description 

F

FERS Federal Employees Retirement System

FEVS Federal Employee Viewpoint Survey

FFEL Federal Family Education Loan 

FIOSG Financial Institution Oversight Service Group

FSA Federal Student Aid

FSALI Federal Student Aid Leadership Institute

FSATC Federal Student Aid Training Conference

FSEM Facilities, Security, and Emergency Management

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 

G

GA Guaranty Agency

GAAP Generally Accepted Accounting Principles

GAO Government Accountability Office

GLBA Gramm-Leach-Bliley Act

GPRA Modernization 

Act

Government Performance and Results Modernization Act of 2010

H

HBCU Historically Black College or University

HCERA Health Care and Education Reconciliation Act of 2010

HEA Higher Education Act of 1965, as amended

HEAL Health Education Assistance Loan

HEROES Act Health and Economic Recovery Omnibus Emergency Solution Act
258 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Acronym Description 

I

IDR Income Driven Repayment

IHE Institution of Higher Education

IP Internet Protocol

IRS Internal Revenue Service

IT Information Technology

L 

LMS Learning Management System

M

MCP Marketing Communications Platform

Met Performance result met or exceeded target

MSI Minority-Serving Institution

MSS Multiple Servicer Survey

MSURSD Minority-Serving Under-Resourced Schools Division

N

N/A Performance result is not applicable because the performance 

metric was not developed, the performance metric was not 

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

OCIO Office of the Chief Information Officer

OIG Office of Inspector General

OIO Operational Improvement and Oversight Directorate

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
Fiscal Year 2022 Annual Report | Federal Student Aid 259

Appendices

Acronym Description 

O

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

PAYE Pay As You Earn

PBO Performance-Based Organization

PCA Private Collection Agency

Pell Grant Federal Pell Grant Program

PEOSD Partner Eligibility and Oversight Services Directorate

PEPS Postsecondary Education Participants System

PERMG Partner Engagement & Relationship Management Group

PII Personally Identifiable Information

PLUS Parent Loan for Undergraduate Students

PMG Performance Management Group

POAM Plan of Action and Milestones

PPPA Provisional Program Participation Agreement

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

S

SABER Student Aid & Borrower Eligibility Reengineering

SAR Satisfaction Assessment Rating

SBR Statement of Budgetary Resources

SEAD Office of Student Experience and Aid Delivery
260 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Acronym Description 

S

Secretary Secretary of Education

SecOps Security Operations

SEOSG School Eligibility and Oversight Service Group

SES Senior Executive Service

SMA Special Mandatory Assignment

SPPR Strategic Planning Performance Review

STOP Act Stop Student Debt Relief Scams Act of 2019

Sweet Settlement Sweet v. Cardona Settlement

T

TEACH Grant Teacher Education Assistance for College and Higher Education 

Grant

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

TPD Total and Permanent Disability

TPDR Third Party Debt Relief

Treasury U.S. Department of the Treasury

U

UEI Unique Entity Identifier 

UCP Union Capital Plaza

V 

VAWA The Violence Against Women Act

VAWA 2022 VAWA Reauthorization Act of 2022

VOG Vendor Oversight Group
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262 Fiscal Year 2022 Annual Report | Federal Student Aid

Appendices 

Appendix D: Availability of the FSA Report

The Federal Student Aid Fiscal Year 2022 Annual Report and the Annual Reports from prior

years are available on the following websites:

• FSA: StudentAid.gov/strategic-planning-reporting

• The Department: http://www.ed.gov/about/reports/annual/index.html

The Federal Student Aid: Strategic Plan, Fiscal Years 2020–24 and prior years’ strategic plans 

are also available at StudentAid.gov/strategic-planning-reporting.

Stay connected to Federal Student Aid through social media: 

• Visit the FSA website: StudentAid.gov

• Like FSA on Facebook

• Follow FSA on Twitter

• Follow FSA on Instagram

• Follow FSA on LinkedIn

• Find FSA on YouTube

: Facebook.com/federalstudentaid

: @FAFSA

: instagram.com/federalstudentaid/

: linkedin.com/company/federalstudentaid

: YouTube.com/user/federalstudentaid
Acknowledgments

The FSA FY 2022 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 2022 Financial Statements. 

The Federal Student Aid FY 2022 Annual Report

Federal Student Aid

A Principal Office of the U.S. Department of Education

Finance Directorate

January 2023