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The Office of Inspector General (OIG) works to 

promote efficiency, effectiveness, and integrity 

in the programs and operations of the U.S. 

Department of Education (Department). Through our 

audits, inspections, investigations, and other reviews, 

we continue to identify areas of concern within the 

Department’s programs and operations and recommend 

actions the Department should take to address these 

weaknesses. The Reports Consolidation Act of 2000 

requires the OIG to identify and report annually on the 

most serious management challenges the Department 

faces. The Government Performance and Results 

Modernization Act of 2010 requires the Department to 

include in its agency performance plan information on its 

planned actions, including performance goals, indicators, 

and milestones, to address these challenges.

Last year, we presented five management challenges: 

improper payments, information technology security, 

oversight and monitoring, data quality and reporting, 

and information technology system development and 

implementation. Although the Department made some 

progress in addressing these areas, four of the five remain 

as a management challenge for fiscal year (FY) 2018. We 

removed information technology system development 

and implementation because our current body of work 

does not support its continued reporting as a challenge to 

the Department. Our planned work for FY 2018 includes 

audits of the Department’s implementation of the Federal 

Information Technology Acquisition Reform Act and 

the Department’s implementation of the Portfolio of 

Integrated Value-Oriented Technologies Contracts. Our 

conclusions from this and other work could result in this 

area returning as a management challenge in future years.

The FY 2018 management challenges are:

(1) Improper Payments,

(2) Information Technology Security,

(3) Oversight and Monitoring, and

(4) Data Quality and Reporting.

These challenges reflect continuing vulnerabilities and 

emerging issues faced by the Department as identified 

through recent OIG audit, inspection, and investigative 

work. A summary of each management challenge area 

follows. This FY 2018 Management Challenges Report is 

available at http://www2.ed.gov/about/offices/list/oig/

managementchallenges.html.

MANAGEMENT CHALLENGE 1—

IMPROPER PAYMENTS

Why This Is a Challenge

The Department must be able to ensure that the billions 

of dollars entrusted to it are reaching the intended 

recipients. The Department identified the Federal 

Pell Grant (Pell) and the William D. Ford Federal 

Direct Loan (Direct Loan) programs as susceptible to 

significant improper payments. In addition, the Office of 

Management and Budget (OMB) has designated these 

programs as high-priority programs, which are subject to 

greater levels of oversight.

Our recent work has demonstrated that the Department 

remains challenged to meet required improper payment 

reduction targets and to intensify its efforts to successfully 

prevent and identify improper payments. In May 

2017, we reported that the Department’s improper 

payment reporting, estimates, and methodologies were 

generally accurate and complete; however, we identified 

opportunities for the Department to improve (1) its 

policies and procedures over the Direct Loan and Pell 

program’s improper payment calculations, (2) the 

completeness of its improper payment corrective action 

reporting, and (3) the evidence or support for its Agency 

Financial Report reporting. We also concluded that the 

Department did not comply with the Improper Payments 

Elimination and Recovery Act of 2010 (IPERA) because 

it (1) did not meet the reduction targets it established for 

the Direct Loan and Pell programs, (2) did not comply 

with applicable guidance regarding its risk assessment 

for the Vocational Rehabilitation State Grants program, 

and (3) did not consider all required risk factors in 

completing its risk assessments for certain grant programs 

and contracting activities.

OFFICE OF INSPECTOR GENERAL’S (OIG) MANAGEMENT 

AND PERFORMANCE CHALLENGES FOR FISCAL YEAR 

2018 EXECUTIVE SUMMARY
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Overall, our semiannual reports to Congress from April 

1, 2014, through March 31, 2017, included more than 

$2.3 million in questioned or unsupported costs from 

audit reports and more than $44 million in restitution 

payments from our investigative activity. We also recently 

issued a report on Western Governors University that 

identified over $700 million in questioned costs.

Progress in Meeting the Challenge

The Department stated that it places a high value on 

maintaining payment integrity to ensure that Federal 

funds reach intended recipients in the right amount 

and for the right purpose. The Department stated that 

its work to sustain payment integrity in response to 

this challenge includes establishing policies, business 

processes, and controls over key payment activities that 

are intended to prevent, detect, and recover improper 

payments. The Department added that its efforts intend 

to achieve the appropriate balance between making 

timely and accurate payments to recipients, while at the 

same time ensuring the controls are not too costly or 

overly burdensome.

The Department reported that it had developed 

and implemented corrective actions in response to 

OIG recommendations to improve the accuracy and 

completeness of its 2017 improper payment estimates 

for the Direct Loan and Pell Grant programs. The 

Department added that it developed and implemented 

corrective actions to improve its improper payment risk 

assessment process for non-Federal Student Aid (FSA) 

grant programs and contracts.

The Department stated that it continues to assess and 

enhance its controls over payments. According to the 

Department, this includes routinely analyzing application 

and payment data and considering other factors, such 

as program reviews and audit reports, to help identify 

ways to further reduce risks and enhance its controls. The 

Department also stated that its payment integrity internal 

control framework includes more than 500 controls 

designed to help prevent and detect improper payments. 

According to the Department, those controls are included 

in the universe of internal controls that are tested 

annually to assess their design and operating effectiveness. 

When control deficiencies are detected, the Department 

works to identify the root causes, develops corrective 

action plans, and tracks the plans through resolution.

Finally, the Department stated that it has increased its 

efforts to enhance payment integrity through three new 

or ongoing initiatives. These included (1) establishing 

a payment integrity workgroup, (2) developing a 

continuous control monitoring system, and (3) 

developing policies and new business processes to more 

accurately report the number and amount of improper 

payments detected and collected.

What Needs to Be Done

The Department needs to continue to take action to 

improve its ability to reduce improper payments. The 

Department should continue its work to complete 

planned corrective actions to bring programs into 

compliance with IPERA and improve its quality 

control processes, process documents, and policies and 

procedures. While the Department continues to review 

its controls, it should continue to explore additional 

opportunities for preventing improper payments. 

Although the Department has added controls and seeks 

to strike a balance between burden and controls, it 

needs to consider options to strengthen existing internal 

controls and to develop new and cost-effective controls to 

reduce the level of risk.

The Department needs to develop and implement 

processes to more effectively and efficiently monitor 

Student Financial Assistance (SFA) program recipients, 

State educational agencies (SEA), and local educational 

agencies (LEA) to ensure they properly spend and account 

for Federal education funds. This area will remain a 

management challenge until the Department fully meets 

the expectations of IPERA and its monitoring systems 

provide greater assurance that Federal funds are both 

properly distributed and appropriately used by recipients.

MANAGEMENT CHALLENGE 2—INFORMATION 

TECHNOLOGY SECURITY

Why This Is a Challenge

Department systems contain or protect an enormous 

amount of sensitive information, such as personal 

records, financial information, and other personally 

identifiable information. Without adequate management, 

operational, and technical security controls, the 

Department’s systems and information are vulnerable to 

attacks. Unauthorized access could result in losing data 

confidentiality and integrity, limiting system availability, 

and reducing system reliability.
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The OIG’s work related to information technology 

continues to identify control weaknesses and ineffective 

security management programs that the Department needs 

to address to adequately protect its systems and data. For 

example, our most recent report on the Department’s 

compliance with the Federal Information Security 

Modernization Act of 2014 (FISMA) concluded that 

the Department’s and FSA’s overall information security 

programs were generally not effective. We found the 

Department and FSA were generally effective in two of 

the five security functions reviewed—identify and recover. 

However, they were not generally effective in the three 

remaining security functions—protect, detect, and respond.

Our report included specific findings in the areas 

of configuration management, identity and access 

management, security and privacy training, information 

security continuous monitoring, and incident response. 

We made recommendations to assist the Department and 

FSA with increasing the effectiveness of their information 

security program so that they fully comply with all 

applicable requirements.

Progress in Meeting the Challenge

The Department reported that it continued to make 

progress in implementing actions to mitigate risks 

associated with information technology security during 

FY 2017. The Department stated that it completed 

a cybersecurity workforce capability assessment to 

identify current gaps in the Department’s cybersecurity 

workforce skills and certifications and developed 

several new cybersecurity guidance documents. The 

Department also noted that the Chief Information 

Security Officer (CISO) is leading coordination efforts 

to meet deadlines for assigning new cybersecurity codes 

to positions with information technology, cybersecurity, 

and cyber-related functions.

The Department further responded that beginning in 

December 2016, the CISO formally established and 

led a Cybersecurity Steering Committee to improve the 

Department’s cybersecurity posture and communicate 

critical information. The Department stated that the 

committee also coordinated and resolved issues that 

impacted the quality and timely reporting of performance 

measures; coordinated reporting for the Department’s 

high-value assets; ensured timely completion of high 

visibility, government-wide security operations directives; 

and completed risk assessment actions required by 

the President’s Executive Order, Strengthening the 

Cybersecurity of Federal Networks and Critical 

Infrastructure, and OMB M-17-25.

The Department reported that the CISO led a number of 

cybersecurity policy updates that include improving the 

Department’s overarching cybersecurity policy guidance, 

revising its Handbook for Cybersecurity Incident 

Response and Reporting, and developing a Cybersecurity 

Strategy and Implementation Plan. According to 

the Department, its plan highlights Departmental 

cybersecurity initiatives, strategies, and action items that 

are directly mapped to the Cybersecurity Framework 

categories. Finally, the Department stated that it 

completed numerous other actions that included the 

completion of risk assessments for all systems in the 

FISMA inventory and the formal designation of a Senior 

Accountable Official for cybersecurity risk.

What Needs to Be Done

The Department is reporting significant progress towards 

addressing longstanding information technology security 

weaknesses. However, we continue to identify significant 

weaknesses in our annual FISMA audits—despite the 

Department’s reported corrective actions to address our 

prior recommendations.

While we commend the Department for placing a 

priority on addressing these weaknesses, it needs to 

continue its efforts to develop and implement an effective 

system of information technology security controls, 

particularly in the areas of configuration management 

and identity and access management. Within 

configuration management, we identified weaknesses that 

include the Department using unsupported operating 

systems, databases, and applications in its production 

environment and not adequately protecting personally 

identifiable information. Within identity and access 

management, we identified weaknesses where the 

Department has not fully implemented its network access 

control solution or two-factor authentication and where 

the Department and FSA did not adhere to the required 

Federal background investigation process for granting 

and monitoring access to its external users.

Our FISMA audits will continue to assess the 

Department’s efforts and this will remain a management 

challenge until our work corroborates that the 

Department’s system of controls achieves expected 

outcomes. To that end, the Department needs to 

effectively address IT security deficiencies, continue 

to provide mitigating controls for vulnerabilities, and 

implement planned actions to correct system weaknesses.
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MANAGEMENT CHALLENGE 3—OVERSIGHT 

AND MONITORING

Effective oversight and monitoring of the Department’s 

programs and operations are critical to ensure that 

funds are used for the purposes intended and programs 

are achieving goals and objectives. This is a significant 

responsibility for the Department given the numbers of 

different entities and programs requiring monitoring and 

oversight, the amount of funding that flows through the 

Department, and the impact that ineffective monitoring 

could have on stakeholders. Two subareas are included in 

this management challenge—SFA program participants 

and grantees.

Oversight and Monitoring—SFA Program Participants

Why This Is a Challenge

The Department must provide effective oversight and 

monitoring of participants in the SFA programs under 

Title IV of the Higher Education Act of 1965, as 

amended, to ensure that the programs are not subject 

to fraud, waste, and abuse. The Department’s FY 2018 

budget request includes $134.2 billion in new grants, 

loans, and work-study assistance to help an estimated 

12.2 million students and their families pay for college.

The growth of distance education has added to the 

complexity of the Department’s oversight of SFA 

program participants. The management of distance 

education programs presents challenges to the 

Department and school officials because little or no 

in-person interaction between the school officials and 

the student presents difficulties in verifying the student’s 

identity and academic attendance. The overall growth 

and oversight challenges associated with distance learning 

increases the risk of school noncompliance with the 

Federal student aid laws and regulations and creates 

new opportunities for fraud, abuse, and waste in the 

SFA programs. Our investigative work has identified 

numerous instances of fraud involving the exploitation of 

vulnerabilities in distance education programs to obtain 

Federal student aid.

Our audits and work conducted by the Government 

Accountability Office continue to identify 

weaknesses in FSA’s oversight and monitoring 

of SFA program participants.

Progress in Meeting the Challenge

The Department reported that it employs several 

oversight tools in its work to ensure program participants’ 

compliance with statutes and regulations and to mitigate 

the inherent risks associated with the administration 

of financial assistance programs. These include (1) 

program reviews, (2) review and resolution of program 

participant’s annual compliance audits and financial 

statements to ensure administrative capability and 

financial responsibility, and (3) certification activities 

to ensure continued eligibility for participation in the 

Federal student aid programs.

The Department stated that during FY 2017, FSA 

implemented actions to improve its oversight and 

monitoring process for schools, lenders, servicers, and 

guaranty agencies. In August 2017, the Department 

announced that FSA was adding several key senior 

executives to help lead and implement a more 

comprehensive, broader approach to its oversight 

function. The Department also reported that FSA had 

begun establishing an integrated system of oversight 

functions that were intended to better ensure compliance 

by all participating parties. The Department intends for 

this approach to oversight to begin with proactive risk 

management that identifies and mitigates risks before 

they pose a threat.

The Department stated that is has also taken steps to 

strengthen its accreditation oversight. According to 

the Department, this includes improving data sharing, 

enhancing its processes to determine agency effectiveness, 

and improving its processes to assess whether agencies 

evaluate institutions in a manner consistent with the 

Secretary’s Criteria for Recognition.

The Department stated that this management challenge 

reflects the inherent risks associated with Federal student 

aid and the ongoing challenge to mitigate these risks 

through oversight and monitoring.

What Needs to Be Done

The Department continues to identify important 

accomplishments that are intended to improve its ability 

to provide effective oversight. We recognize the progress 

the Department is making and the need to balance 

controls with both cost and the ability to effectively 

provide necessary services. However, our audits and 
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investigations involving SFA programs continue to 

identify instances of noncompliance and fraud, as well as 

opportunities for FSA to improve it processes.

The financial responsibility provisions that were planned 

to go into effect in July 2017 as part of the borrower 

defense regulation changes would have included tools 

to improve the Department’s oversight of schools. 

Enforcement of such regulations could have improved 

FSA’s processes for mitigating potential harm to students 

and taxpayers by giving FSA the ability to obtain 

financial protection from schools based on information 

that is broader and more current than information 

schools provide in their annual audited financial 

statements. The Department needs to implement 

provisions that will allow it to receive important, timely 

information from publicly traded, private for-profit, and 

private nonprofit schools that experience triggering events 

or conditions. Collecting and analyzing this information 

could improve FSA’s processes for identifying Title IV 

schools at risk of unexpected or abrupt closure.

Overall, the Department needs to ensure that the 

activities of its new efforts to better coordinate 

oversight result in effective processes to monitor 

SFA program participants and reduce risk. It should 

work to ensure that its program review processes are 

designed and implemented to effectively verify that 

high-risk schools meet requirements for institutional 

eligibility, financial responsibility, and administrative 

capability. The Department further needs to ensure 

its oversight functions work together to effectively 

provide the intended additional protections to students 

and taxpayers. Finally, the Department could enhance 

its oversight of SFA programs by developing and 

implementing improved methods to prevent and detect 

fraud. This includes methods to limit the effectiveness of 

organized activities involving distance fraud rings.

Oversight and Monitoring—Grantees

Why This Is a Challenge

Effective monitoring and oversight are essential for 

ensuring that grantees meet grant requirements and 

achieve program goals and objectives. The Department’s 

early learning, elementary, and secondary education 

programs annually serve nearly 18,200 public school 

districts and 50 million students attending more than 

98,000 public schools and 32,000 private schools. Key 

programs administered by the Department include 

Title I of the Elementary and Secondary Education Act, 

which under the President’s 2018 request would deliver 

$15.9 billion for local programs that provide extra 

academic support to help nearly 25 million students in 

high-poverty schools meet challenging State academic 

standards. Another key program is the Individuals with 

Disabilities Education Act, Part B Grants to States, which 

would provide about $11.9 billion to help States and 

school districts meet the special educational needs of 6.8 

million students with disabilities.

OIG work has identified a number of weaknesses in 

grantee oversight and monitoring. These involve LEA 

and SEA control issues; fraud relating to education 

programs; fraud perpetrated by SEA, LEA, and charter 

school officials; and internal control weaknesses in the 

Department’s oversight processes.

Progress in Meeting the Challenge

The Department noted that mitigating the risks 

associated with grants awarded to States, school districts, 

institutions of higher education, and other entities 

remains a significant challenge given the Department’s 

relatively limited resources for oversight and monitoring. 

The Department stated that in response to this challenge, 

it initiated an enterprise-approach to risk management in 

FY 2017 and implemented targeted actions to improve 

support for grant recipients. The Department added that 

these actions focused on increasing staff expertise and 

leveraging risk-based tools and approaches to provide 

improved technical assistance and oversight.

The Department also reported that it completed several 

activities that were intended to improve its monitoring 

skills and capacity across offices through a variety of 

collaborative training and development efforts. Examples 

included developing training related to distance 

monitoring and providing technical assistance.

The Department added that it has implemented 

a number of new risk-based monitoring tools and 

approaches. The Department stated that its Risk 

Management Service provided analysis of complex 

monitoring issues that are intended to support wellinformed, timely decision-making and preparation 

for site monitoring visits. The Department further 
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reported that it deployed two monitoring tools that were 

intended to (1) assist in analyzing risk and create riskbased monitoring plans and (2) centralize and automate 

key monitoring data while expanding the monitoring 

information into new areas.

The Department also noted that its grant offices had 

implemented a number of new risk-based approaches 

to better target limited resources on those educational 

agencies and entities in need of the most assistance. 

This included the expansion of the Office of Elementary 

and Secondary Education’s (OESE) fiscal monitoring 

pilot that leverages joint reviews across its programs. 

The Department reported that this approach has better 

positioned it to work more proactively with SEAs and 

LEAs, identify issues of concern, and share best practices 

and lessons learned.

The Department further reported other improvements 

that included the Office of Career, Technical, and 

Adult Education’s enhancements to its comprehensive 

monitoring web portal, the Office of Postsecondary 

Education’s collaboration with other offices in developing 

and implementing a standard discretionary grant site 

visit monitoring tool, and the Institute of Education 

Sciences’ efforts to improve the oversight of privacy and 

information security.

What Needs to Be Done

The Department acknowledges that this area is a major 

risk and points out actions it has taken to address this 

challenge. In particular, its efforts to pilot joint program 

fiscal monitoring reviews appear to leverage its limited 

resources to focus on areas of risk. The Department 

should closely review the results of this pilot and look 

for ways to improve it and expand it into other areas. 

Also, the Department should continue to make use of 

risk-based information, develop common training and 

procedures, and take steps to ensure that its program 

offices are consistently providing effective risk-based 

oversight of grant recipients across applicable Federal 

education programs.

As various offices implement improvements to 

monitoring, such as those cited above, the Department 

should review their effectiveness and replicate effective 

practices to other program areas. Given the Department’s 

generally limited staffing in relation to the amount 

of Federal funding it oversees, it is important for the 

Department to continue to explore ways to more 

effectively leverage the resources of other entities that 

have roles in grantee oversight. Another area where 

there is the potential to make use of limited resources 

to improve oversight is to review the results of single 

audits and program monitoring efforts in order to revise 

the single audit process and updates to the 2 C.F.R. 

200, Subpart F—Compliance Supplement to improve 

program compliance and help mitigate fraud and abuse.

MANAGEMENT CHALLENGE 4—DATA QUALITY 

AND REPORTING 

Why This Is a Challenge

The Department, its grantees, and its subrecipients 

must have effective controls to ensure that reported 

data are accurate and reliable. The Department relies 

on program data to evaluate program performance and 

inform management decisions. Our work has identified a 

variety of weaknesses in the quality of reported data and 

recommended improvements at the Department, SEA, 

and LEA level. This included weaknesses in controls over 

the accuracy and reliability of program performance and 

graduation rate information provided to the Department.

Progress in Meeting the Challenge

The Department reported that it made progress in 

FY 2017 to implement actions that are intended to 

mitigate the inherent risks associated with data quality. 

The Department stated that it continued to build 

standardized procedures to evaluate the quality of SEAsubmitted data. As an example, the Department noted 

that two of its offices used a new tool to identify, followup, and track individual State data quality concerns after 

the submission of School Year 2015–16 Consolidated 

State Performance Reports.
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The Department stated that it developed a policy that 

promotes a comprehensive approach to active and 

strategic data management with clearly identified roles 

and responsibilities for data management work. The 

Department added that the EDFacts Data Governance 

Board continues to promote and support program offices’ 

stewardship of data through a unified Information 

Collection package, standardized technical reporting 

instructions, centralized data submission systems, and 

increasingly standardized post-submission data quality 

procedures. The Department also reported that it 

implemented a new certification for Consolidated State 

Performance Reports. The certification served as reminder 

that the person certifying the data was providing 

assurance, on behalf of the State, of the accuracy of the 

data submission to the Department.

The Department stated that the EDFacts Data 

Governance Board routinely meets to exchange best 

practices. For example, board members shared strategies 

used with State grantees to document data review 

procedures, build replicable processes, and generate 

meaningful and timely messages back to the grantees 

post-data submission. The Department further stated that 

the National Center for Education Statistics developed 

a basic Data Quality Summary Form that will be shared 

with the Department principal offices for use in their 

reviews of submitted data files.

The Department also reported that OESE initiated work 

to develop a plan to address issues of data quality, data 

security, data reporting, and overall data management. As 

part of the effort, OESE is using prior OIG data quality 

recommendations as areas for possible improvement. 

Finally, the Department stated that the Office of 

Career, Technical, and Adult Education continues to 

offer several ongoing initiatives to help States develop 

and implement accountability systems that yield valid, 

reliable, and complete data on the progress of career 

and technical education students. The Department 

reported that these efforts included annual conferences 

to improve the quality and consistency of the definitions 

and measurement approaches that States use to report 

performance data, conference calls to discuss emerging 

issues in accountability, and customized technical 

assistance to States to improve the validity, reliability, and 

completeness of their data.

What Needs to Be Done

The Department continues to complete significant work 

that is intended to improve the overall quality of data that 

it collects and reports. This effort remains important, as 

data quality contributes to effective program management 

and helps ensure the credibility of information published 

by the Department. Although the Department has made 

progress in strengthening both grantees’ data quality 

processes and its own internal reviews of grantee data, 

this area is an ongoing challenge. Our recent audits 

continue to find weaknesses in grantees’ internal controls 

over the accuracy and reliability of program performance 

and graduation rate information. 

The Department’s efforts by the EDFacts Data 

Governance Board to promote common strong practices 

across its program offices is an important step to 

improving the quality of data the Department relies 

on. In addition, efforts to strengthen data certification 

statements and reach out to States and other entities that 

report data to the Department are important steps to 

reinforce the importance of good data quality practices. 

The Department should continue to monitor the quality 

of the data it receives, work to implement effective 

controls to address known weaknesses, and take steps 

to ensure that strong data management practices are 

implemented across the Department as well as by entities 

that submit data to the Department. The Department 

should also make use of its current oversight mechanisms, 

such as single audits and program monitoring protocols, 

to ensure that program participants have strong 

controls to ensure the quality of data submitted to the 

Department and to ensure that they have good practices 

to support the data certifications they sign.