OTHER

INFORMATION
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FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION 97

FRAUD REDUCTION REPORT

This section summarizes the Department’s efforts to 

comply with the Fraud Reduction and Data Analytics Act 

of 2015 (FRDAA) and details fraud reduction initiatives 

undertaken in FY 2019.

REDUCE THE FOOTPRINT

This section summarizes the Department’s efforts to 

comply with Office of Management and Budget (OMB) 

Management Procedures Memorandum-12-12, Promoting 

Efficient Spending to Support Agency Operations and OMB 

Management Procedures Memorandum 2015-01, the 

Reduce the Footprint policy implementing guidance. 

That guidance directs agencies to reduce the total square 

footage of their domestic office and warehouse inventory 

compared to an FY 2015 baseline.

CIVIL MONETARY PENALTY ADJUSTMENT 

FOR INFLATION

This section reports on the Department’s annual inflation 

adjustments to civil monetary penalties as required 

under the Federal Civil Penalties Inflation Adjustment Act 

Improvements Act of 2015.

The Other Information section includes:

OFFICE OF INSPECTOR 

GENERAL’S (OIG) MANAGEMENT AND 

PERFORMANCE CHALLENGES

OIG’s Management and Performance Challenges Report 

provides a summary of what the OIG believes are the 

Department’s biggest challenges for FY 2020. The OIG 

identified the following four challenges: (1) Improper 

Payments, (2) Information Technology Security, (3) 

Oversight and Monitoring, and (4) Data Quality and 

Reporting. The full report is available at the OIG website.

SUMMARY OF FINANCIAL STATEMENT AUDIT 

AND MANAGEMENT ASSURANCES

The Summary of Financial Statement Audit and 

Management Assurances provides information about the 

material weaknesses reported by the agency or through the 

audit process.

PAYMENT INTEGRITY

This section summarizes the Department’s efforts to 

maintain payment integrity and to develop effective 

controls designed to prevent, detect, and recover improper 

payments. It also includes information regarding the 

Department’s high-risk programs.

ABOUT THE OTHER INFORMATION SECTION
98 FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION

OTHER INFORMATION | MEMORANDUM FROM THE OFFICE OF INSPECTOR GENERAL

 
FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION 99

OFFICE OF INSPECTOR GENERAL’S (OIG) MANAGEMENT 

AND PERFORMANCE CHALLENGES FOR FISCAL 

YEAR 2020

MANAGEMENT CHALLENGE 1—

IMPROPER PAYMENTS 

“Improper payments” are payments the government 

makes to the wrong person, in the wrong amount, or for 

the wrong reason. Although not all improper payments 

are fraudulent or represent a loss to the government, all 

improper payments degrade the integrity of government 

programs and compromise citizens’ trust in government. 

To reduce instances of improper payments, agencies must 

properly identify the cause of the improper payment, 

implement effective mitigation strategies to address 

the cause, and regularly assess the effectiveness of those 

strategies, refining them as necessary.

The Improper Payments Elimination and Recovery Act 

of 2010 (IPERA) requires Federal agencies to reduce 

improper payments and to report annually on their efforts. 

It specifically requires that each agency, in accordance 

with guidance prescribed by the Office of Management 

and Budget (OMB), periodically review all programs and 

activities that the agency administers and identify those 

that may be susceptible to significant improper payments. 

For each program and activity identified as susceptible 

to significant improper payments, the agency is required 

to produce a statistically valid estimate, or an estimate 

that is otherwise appropriate using a methodology that 

OMB approved, of the improper payments made by each 

program and activity. The agency must include those 

estimates in the accompanying materials to its annual 

Agency Financial Report. 

IPERA also requires each agency’s Inspector General to 

determine the agency’s compliance with the statute for 

each fiscal year. To be considered compliant with IPERA, 

an agency must (1) publish an Agency Financial Report, 

(2) conduct a program-specific risk assessment, (3) publish 

improper payment estimates, (4) publish corrective 

action plans to reduce improper payments, (5) publish 

and meet improper payment reduction targets, and (6) 

report improper payment rates of less than 10 percent. 

Additionally, an Inspector General must evaluate the 

accuracy and completeness of the agency’s reporting and 

performance in preventing, reducing, and recapturing 

improper payments.

Why This Is a Challenge

The Department must ensure that the billions of dollars 

entrusted to it reach 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, 

and OMB has designated these programs as high-priority 

programs, which are subject to greater levels of oversight. 

As shown in Figure 15, annual outlays for these two 

programs were about $123 billion from FY 2016 through 

FY 2018. In its FY 2018 Agency Financial Report, the 

Department reported improper payments of $2.3 billion 

(8.15 percent of total outlays) for the Pell program and 

$3.8 billion (3.99 percent of total outlays) for the Direct 

Loan program using an OMB-approved nonstatistical 

sampling and estimation methodology.

 

Source: U.S. Department of Education Agency Financial Reports (FY 2016–

FY 2018)

The OIG’s recent statutory work shows that the 

Department has made improvements towards meeting 

related requirements. However, as shown in Table 3, our 

audits have shown that the Department faces challenges to 

consistently meet key IPERA requirements.
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agencies (LEAs). Our semiannual reports to Congress 

from April 1, 2016, through March 31, 2019, included 

more than $712 million in questioned costs from audit 

activity and more than $84 million restitution payments 

from investigative activity. These examples demonstrate 

there may be other potential opportunities for the 

Department to identify and prevent improper payments.

Planned projects include our annual review of 

the Department’s compliance with the improper 

payment reporting requirements and its performance 

in preventing, reducing, and recapturing improper 

payments. We will also complete a required risk 

assessment of the Department’s purchase card 

program and, if deemed necessary, conduct an audit of 

Department purchase card transactions.

Progress in Meeting the Challenge

The Department stated that it implemented a statistically 

valid improper payment estimation methodology in FY 

2019 that addressed the acknowledged limitations of 

the prior nonstatistically valid estimation methodology 

for both the Pell and Direct Loan programs. The 

methodology is based on a larger, random sample of 

the complete population of over 5,700 schools and uses 

data from the compliance audits performed by external 

auditors, as opposed to the prior methodology that used 

a smaller, nonstatistical sample of a subset of schools 

selected for program reviews. The Department noted 

that the new sampling methodology exceeded OMB’s 

precision requirements for estimates of the percentage of 

improper payments.

According to the Department, this methodology improves 

the accuracy of the improper payment estimates allowing 

for more precise root cause analyses to improve corrective 

actions and improve the effectiveness of correction action 

plans to mitigate identified root causes. The Department 

further stated that using the new methodology has resulted 

in significantly lower improper payment estimates for the 

Pell Grant and Direct Loan Programs. 

According to the Department, it remains committed to 

maintaining the integrity of payments to ensure that the 

billions entrusted to it reach intended recipients in the 

right amount and for the right purpose. To accomplish 

this, the Department stated it establishes policies, business 

processes, and controls over key payment activities, 

to include those pertaining to payment data quality, 

cash management, banking information, and financial 

reports. The Department noted that payment integrity 

includes robust controls designed to prevent, detect, and 

While our most recent audit concluded that the 

Department complied with IPERA for FY 2018, we found 

that the Department reported inaccurate and incomplete 

information regarding the amounts of identified and 

recaptured improper payments in its FY 2018 Agency 

Financial Report. As a result, we could not accurately 

evaluate the Department’s performance in recapturing 

improper payments for its programs and activities.

In FY 2019, the Department implemented significant 

changes to its reporting on improper payments; 

specifically, it introduced new improper payment 

estimation methodologies for the Pell and Direct Loan 

programs and began estimating improper payments for 

two additional programs. Before FY 2019, FSA used 

OMB-approved nonstatistical sampling and estimation 

methodologies for its Pell and Direct Loan programs. 

Additionally, for FY 2019, the Immediate Aid to 

Restart School Operations Program and the Temporary 

Emergency Impact Aid for Displaced Students Program 

were designated as susceptible to significant improper 

payments. The Department plans to use statistically valid 

methodologies to estimate improper payments for all 

four programs. While the implementation of statistically 

valid estimation methodologies should improve the 

accuracy and reliability of the Department’s improper 

payment estimates, we have not yet reviewed these new 

estimates and our past audits identified weaknesses in 

the Department’s design and implementation of the 

methodologies used to estimate improper payments. 

Other audit work has identified potential improper 

payments in the student financial assistance programs and 

by State educational agencies (SEAs) and local educational 

FY

Met Reduction 

Target for Direct 

Loan Program

Met Reduction 

Target for Pell 

Program

Accurate and 

Complete 

Improper 

Payments 

Estimation 

Methodology

2014 No Yes No

2015 No Yes No

2016 No No Yes

2017 Yes No Yes

2018 Yes Yes Yes

Table 3. Results of Recent OIG Statutorily 

Required Improper Payment Audits
FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION 101

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review and reconsideration. We support the Department’s 

efforts to pursue legislation that would allow it access 

to taxpayer information in order to reduce improper 

payments. 

MANAGEMENT CHALLENGE 2—INFORMATION 

TECHNOLOGY SECURITY

The Department’s systems house millions of sensitive 

records on students, their parents, and others, and are 

used to process billions of dollars in education funding. 

These systems are primarily operated and maintained by 

contractors and are accessed by thousands of authorized 

people (including Department employees, contractor 

employees, and other third parties such as school 

financial aid administrators). As shown in Figure 16, the 

Department’s total spending for information technology 

investments for FY 2019 was about $731 million and may 

exceed $760 million in FY 2020. The estimated FY 2020 

information technology spending is an increase of about 

13.8 percent from FY 2017 levels. 

recover improper payments. In designing controls, the 

Department strives to strike the right balance between 

making timely and accurate payments and ensuring 

the controls put in place are not too costly or overly 

burdensome and thereby deter intended beneficiaries 

from obtaining funds they are entitled to receive. 

Additionally, the Department noted it must rely heavily 

on controls established by external entities that receive 

Department payments, including Federal, State, and 

private organizations and institutions, because those 

entities further distribute funds that they receive from the 

Department to subordinate organizations and individuals. 

Because these “third party” controls are outside of the 

Department’s operational authority, they present a higher 

risk than the payments made directly by the Department, 

as evidenced by the Department’s root cause analysis.

In addition, the Department stated that it is coordinating 

with the Treasury Department and OMB to pursue 

legislation that would authorize the Internal Revenue 

Service to disclose tax return information directly 

to the Department for the purpose of administering 

programs authorized by Title IV of the Higher Education 

Act of 1965, through which the Department awarded 

more than $122 billion in FY 2019. Several bills have 

been introduced in Congress that would amend the 

Internal Revenue Code to allow the Internal Revenue 

Service to disclose tax return information to authorized 

Department officials for purposes of determining 

eligibility for, and amount of, Federal student financial 

aid. The Department expects the exemption would allow 

for significant simplification of and improvement to the 

administration of Title IV programs, including reduction 

in improper payments.

What the Department Needs to Do 

This year marks a potential turning point in the 

Department’s Improper Payments Management Challenge. 

The Department’s development of a statistically valid 

estimation methodology is intended to allow for a more 

robust and accurate estimate of improper payments. The 

Department’s draft estimates using this measure indicate 

that improper payments are much lower than what 

was estimated using its previous alternative approaches. 

However, the OIG has not assessed the Department’s new 

estimation methodology or the accuracy and validity of 

the Department’s new estimates. The OIG will review the 

accuracy and validity of these measurements as part of the 

FY 2019 IPERA audit. Depending on whether the OIG 

finds issues with the new estimation methodology and 

estimates, this Management Challenge Area is subject to 

 

Source: Information Technology Agency Summary, ITDashboard.gov

Through the Office of the Chief Information Officer 

(OCIO), the Department monitors and evaluates the 

contractor-provided information technology services 

through a service-level agreement framework and develops 

and maintains common business solutions required 

by multiple program offices. OCIO is responsible for 

implementing the operating principles established by 

legislation and regulation, establishing a management 

framework to improve the planning and control of 

information technology investments, and leading 

change to improve the efficiency and effectiveness of 

the Department’s operations. In addition to OCIO, 

Federal Student Aid (FSA) has its own chief information 
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Each of our recent FISMA reports recommended ways the Department and FSA could increase the effectiveness of their 

information security program so that they fully comply with all applicable requirements. Our FY 2018 FISMA audit 

specifically noted that the Department and FSA could strengthen their controls in areas such as (1) corrective action 

plan remediation (risk management); (2) reliance on unsupported operating systems, databases, and applications in its 

production environments (configuration management); (3) removing access of terminated users to the Department’s 

network (identity and access management); (4) protecting personally identifiable information (data protection and privacy); 

(5) fully implementing its Continuous Diagnostics and Mitigation program (information security continuous monitoring); 

and (6) ensuring functionality of data loss prevention tools (incident response). We made recommendations to help the 

Department and FSA fully comply with all applicable requirements.

Recent audits of the Department’s financial statements, performed by an independent public accountant with OIG 

oversight, have consistently identified information technology control as a significant deficiency. While the independent 

officer, whose primary responsibility is to promote the effective use of technology to achieve FSA’s strategic objectives 

through sound technology planning and investments, integrated technology architectures and standards, effective systems 

development, and production support.

The Federal Information Security Modernization Act of 2014 (FISMA) requires the OIG to assess the effectiveness of the 

agency’s information security program. FISMA mandates that this evaluation includes (1) testing of the effectiveness of 

information security policies, procedures, and practices of a representative subset of the agency’s information systems and (2) 

an assessment of the effectiveness of the information security policies, procedures, and practices of the agency. 

Why This Is a Challenge

In light of increased occurrences of high-profile data breaches (public and private sector), the importance of safeguarding the 

Department’s information and information systems cannot be understated. Protecting this complex information technology 

infrastructure from constantly evolving cyber threats is an enormous responsibility and challenge. Without adequate 

management, operational, and technical security controls, the Department’s systems and information are vulnerable to 

attacks. Unauthorized access could result in lost data confidentiality and integrity, limited system availability, and reduced 

system reliability. For the last several years, information technology security audits and financial statement audits have 

identified security controls that need improvement to adequately protect the Department’s systems and data. 

Our recent reports on the Department’s compliance with FISMA, performed by the OIG with contractor assistance, noted that 

the Department and FSA made progress in strengthening their information security programs. However, as shown in Table 4, 

our FY 2017 and FY 2018 FISMA audits included findings and repeat findings across all five cybersecurity framework security 

functions developed by the Council of the Inspectors General on Integrity and Efficiency, OMB, and the Department of 

Homeland Security and within each of their related metric domains. Both audits concluded that the Department and FSA were 

not effective in any of the five security functions—Identify, Protect, Detect, Respond, and Recover. 

Identify Protect Detect Respond Recover

FY Risk 

Management

Contractor 

Systems

Configuration 

Management

Identity and 

Access 

Management

Data 

Protection 

and Privacy

Security 

and Privacy 

Training

Information 

Security 

Continuous 

Monitoring

Incident 

Response

Contingency 

Planning

2018 Repeat 

Finding1 N/A2 Repeat 

Finding

Repeat 

Finding Finding Repeat Finding

Repeat 

Finding

Repeat 

Finding

Repeat 

Finding

2017 Finding Finding Finding Finding N/A3 Finding Repeat 

Finding

Repeat 

Finding Finding

Table 4. Results of OIG FISMA Audits—Cybersecurity Framework Security Functions and Metric Domains 

with Findings and Repeat Findings

1 Repeat findings are current report findings with the same or similar conditions contained in prior OIG reports.

2 Contractor systems was not a metric domain for the FY 2018 FISMA audit.

3 Data protection and privacy was not a metric domain for the FY 2018 FISMA audit.
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Cybersecurity Framework Risk Scorecards that serve as a 

tool to prioritize and mitigate risks to the Department’s 

information systems. The Department added that the 

Cybersecurity Framework Risk Scorecard was enhanced 

during FY 2019 to allow for automated risk scoring, 

improved accessibility, more granular and user-friendly 

data filtering capabilities, and enhanced data modeling. 

The Department also stated that it had increased 

communication through targeted briefings for specific 

stakeholders on subjects that included Cybersecurity 

Framework Risk Scorecard results, phishing exercises, 

and current cyber threats. The Department believed that 

these processes enabled it to better prioritize resources 

to resolve identified vulnerabilities. The Department 

reported that this prioritization led to the closure of 

all past due Plans of Action and Milestones for the 

Department’s High Value Assets. The Department also 

noted that it had reduced total Plans of Action and 

Milestones by more than 83 percent and delayed Plans of 

Action and Milestones by 95 percent.

The Department stated that it had made substantial 

progress in the development of an enterprise Identity 

Credential and Access Management solution. The 

Department expects this solution will provide the ability 

to centrally and securely manage enterprise identity, user 

accounts, and user’s roles within and across Department 

systems and applications. The Department stated that 

it plans to deploy the Identity Credential and Access 

Management solution into the Department’s production 

environment in FY 2020.

The Department noted that it has worked with the 

Department of Homeland Security to mature its 

Continuous Diagnostics and Mitigation implementation 

by incorporating additional program elements of the 

Dynamic and Evolving Federal Enterprise Network 

Defense series of task orders. The Department reported 

that it also engaged with non-government organizations 

to expand and improve information sharing and 

communication to protect our nation’s students 

from cyber threats. The Department believes it has 

opportunities to contribute operationally, tactically, and 

strategically to strengthen cybersecurity protections within 

the educational community. For example, in FY 2019, 

the Department was able to leverage the relationship 

with the education community to quickly collaborate 

on a cybersecurity alert and enlist its assistance with 

promulgating the message. 

public accountants noted that the Department and FSA 

management demonstrated progress in addressing some 

of the deficiencies, they also generally concluded that 

ineffective information technology controls increase the risk 

of unauthorized use, disclosure, disruption, modification, 

or destruction of information and information systems that 

could impact the integrity and reliability of information 

processed in the associated applications. 

Our investigative work in this area identified a cyber-crime 

scheme targeting Federal student financial assistance funds. 

This involved the use of phishing to obtain student’s log 

in credentials and then using this information to access 

school’s systems to change the student’s direct deposit 

information. We issued a memorandum that informed 

the Department that the lack of two-factor authentication 

contributed to this incident and recommended the 

Department take steps to advise schools of this threat. 

The Department subsequently issued a public advisory 

regarding the scheme.

Planned projects in this area will determine whether the 

Department’s and FSA’s overall information technology 

security programs and practices were generally effective as 

they relate to Federal information security requirements.

Progress in Meeting the Challenge

The Department stated that it successfully completed 

an information technology migration that transitioned 

core services and capabilities to new service providers 

during FY 2019. The Department stated this included 

the deployment of new tools that make the Department’s 

information technology environment more secure. 

The Department cited specific improvements that 

included improved spam filtering, antiphishing, and 

geo-blocking capabilities.

The Department also noted that it revised its Information 

Security Program’s policy framework to include a new 

review and approval process for cybersecurity policies, 

standards, and instructions. The Department believed that 

multiple new features, including automated workflows and 

defined review timelines, will improve the Department’s 

ability to provide critical time sensitive guidance to 

Department information technology systems stakeholders.

The Department stated that it made significant progress 

to maintain an accurate system inventory, communicate 

the impact of identified cybersecurity risks, and actively 

manage its Plans of Actions and Milestones.3

 As part of 

this ongoing work, the Department continued to publish 

3 Plans of Action and Milestones are management tools for tracking the mitigation 

of cyber security program and system level findings and weaknesses.
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management strategy; (2) FSA has not fully implemented 

a process for identifying, managing, or tracking activity 

of privileged accounts; and (3) the Department did 

not remove terminated users from its network. For 

information security continuous monitoring, stakeholders 

are unable to perform monitoring functions in the Cyber 

Security Assessment and Management tool. 

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 information technology security 

deficiencies, continue to provide mitigating controls for 

vulnerabilities, and implement planned actions to correct 

system weaknesses. 

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: student financial assistance 

programs and grantees. 

Oversight and Monitoring—Student Financial 

Assistance Programs 

FSA, as a principal office of the Department, seeks to 

ensure that all eligible individuals can benefit from 

Federal financial assistance for education beyond high 

school. FSA is the nation’s largest provider of student 

financial aid and is responsible for implementing and 

managing the Federal student financial assistance 

programs authorized under Title IV of the Higher 

Education Act of 1965, as amended. These programs 

provide grants, loans, and work-study funds to students 

attending colleges or career schools. FSA also oversees 

about 6,000 postsecondary institutions that participate 

in the Federal student aid programs.

Finally, the Department stated that it has managed a 

significant amount of transition risk and made significant 

progress during FY 2019 to strengthen the Department’s 

information security program. It believed that the 

infrastructure, processes, and tools deployed in FY 2019 

created an environment for further growth in maturing its 

programs during FY 2020.

What the Department Needs to Do

The Department relies on information technology to 

manage its core business operations and deliver products 

and services to its many stakeholders. The OIG has 

consistently reported concerns regarding the overall 

effectiveness of the Department’s information technology 

security program through our annual FISMA audits, 

financial statement audits, and management challenges 

reports. While the Department reported significant 

progress towards addressing long-standing concerns, 

managing information technology security programs and 

practices to effectively reduce risk to the Department’s 

operations is a clear and ongoing management challenge. 

Specifically, we continue to identify significant 

weaknesses in our annual FISMA audits—despite the 

Department’s reported corrective actions to address our 

prior recommendations. 

We commend the Department for addressing these 

weaknesses and continuing to place a priority on 

improving its information technology security 

program. Our FISMA report for FY 2018 noted that 

the Department and FSA had made improvements in 

developing and strengthening their security programs, 

but also identified continued weaknesses. Overall, the 

Department needs to continue its efforts to develop and 

implement an effective system of information technology 

security controls, particularly in the areas of configuration 

management, identity and access management, and 

information security continuous monitoring. Within 

configuration management, we identified weaknesses 

where (1) the Department is not consistently ensuring 

the use of secure connections; (2) the Department 

and FSA continued to use outdated secure connection 

protocols; and (3) FSA is using unsupported operating 

systems, databases, and applications in its production 

environment. Within identity and access management, 

we identified weaknesses where (1) the Department has 

not fully implemented its identity, credential, and access 
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In FY 2018, FSA performed these functions with an administrative budget of $1.5 billion and 1,257 employees, along with 

contractors that provide outsourced business operations. As shown in Figure 17, FSA delivered an average of about $126.2 

billion in Federal student aid to more than 12.7 million students each year from FY 2014 to FY 2018.

Within the Department, FSA administers the Federal student assistance programs, and the Office of Postsecondary 

Education develops Federal postsecondary education policy and regulations for the Federal student assistance programs. 

The Office of Postsecondary Education also administers the review process for accrediting agencies to ensure that the 

Department recognizes only agencies that are reliable authorities for evaluating the quality of education and training 

postsecondary institutions and programs offer.

Why This Is a Challenge

The Department must provide effective oversight and monitoring of the student financial assistance programs to ensure 

that the programs are not subject to fraud, waste, and abuse. The Department’s responsibilities include coordinating and 

monitoring the activity of many Federal, State, nonprofit, and private entities involved in Federal student aid delivery, 

within a statutory framework established by Congress and a regulatory framework established by the Department. These 

entities include lenders, guaranty agencies, postsecondary institutions, contracted servicers, collection agencies, and 

accrediting agencies. 

Our audits involving the oversight and monitoring of student financial assistance programs continue to identify instances of 

noncompliance as well as opportunities for the Department to further improve its processes. The OIG’s audit related work 

within this area has covered a wide range of activities, including the following. 

 

Source: U.S. Department of Education Agency Financial Reports FY 2014–FY 2018
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The OIG’s investigative work continues to identify fraud, waste, and abuse of student financial assistance program funds. 

This includes the following areas. 

Activities Reviewed Review Results

Accreditation We found that the Department’s process for reviewing agency petitions for recognition did not provide reasonable 

assurance that Department recognized only agencies meeting Federal criteria. We also reported that OPE’s postrecognition oversight was not adequate to ensure agencies consistently and effectively carried out their responsibilities.

Contractor Oversight In our audit of FSA’s oversight of loan servicers, we found that FSA did not track all identified instances of loan servicer 

noncompliance and rarely held loan servicers accountable for noncompliance with requirements. We also noted that 

information that FSA collected was not always sufficient to ensure that loan servicers complied with requirements for 

servicing federally held student loans. 

In an audit of FSA’s contractor personnel security clearance process, we found that FSA had not effectively implemented 

Department requirements and ensured that all contractor employees had appropriate security screening.

Satisfactory Academic 

Progress

We found that FSA did not always ensure that schools completed corrective actions related to satisfactory academic 

progress findings that independent public accountants identified in compliance audits and FSA identified in program 

reviews.

School Closures We found that FSA could enhance its policies and procedures to help ensure that it takes timely and appropriate action to 

resolve schools’ composite score appeals. FSA should also implement controls to prevent schools from manipulating their 

composite scores to avoid sanctions or increased oversight.

School Compliance with 

the Higher Education 

Act and Tile IV 

Regulations

We found that a school became ineligible to participate in the Title IV programs because it did not comply with the 

institutional eligibility requirement that limits the percentage of regular students who may enroll in correspondence courses. 

We also found that the school did not always comply with the requirements governing disbursements or return of Title IV 

aid. 

Verification of Free 

Application for Federal 

Student Aid (FAFSA) 

Data

We found that FSA did not evaluate its process for selecting FAFSA data elements that institutions were required to 

verify and generally did not effectively evaluate and monitor its processes for selecting students for verification. We also 

performed a series of external audits of selected schools to assess their compliance with Federal verification and reporting 

requirements. Of five schools covered by these audits, two did not always complete verification of applicant data in 

accordance with Federal requirements, and one did not always accurately report verification results to FSA.

Area Example of Related Investigative Activity

Institutions An OIG investigation identified an instance where a school violated the Federal ban on incentive compensation. Title IV of 

the Higher Education Act prohibits any institution that receives Federal student aid from compensating student recruiters 

with a commission, bonus, or other incentive payment based on the recruiters’ success in securing student enrollment. 

The incentive compensation ban protects students against admissions and recruitment practices that serve the financial 

interests of the recruiter rather than the educational needs of the student.

School Officials OIG investigations identified improper activities of school officials that included falsifying student eligibility information, 

embezzling portions of student’s Federal student financial assistance awards, using a corporate credit card for personal 

benefit, and overriding academic holds on students’ financial aid records to allow improper award and disbursement of 

Federal student assistance. 

Program Participants OIG investigations identified instances where program participants gave kickback payments in exchange for unjustified 

financial aid payments, used fraudulently obtained social security numbers to obtain Direct Loans, and made false claims 

of earning a high school diploma to receive student financial assistance.

Distance Education 

Fraud Rings

Fraud rings are large, loosely affiliated groups of criminals who seek to exploit vulnerabilities in distance education 

programs. The OIG has investigated numerous instances where these groups use the identities of others (with or without 

their consent) in order to fraudulently obtain Federal student aid.
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performance, particularly from loan servicers. Under Next 

Gen FSA, FSA plans to take an enhanced approach to 

vendor oversight. 

Oversight and Monitoring of Schools 

To improve its oversight and monitoring of schools 

participating in Title IV programs, FSA stated that it 

has worked to address weaknesses in the single audit 

process in order to improve its use as an oversight and 

monitoring tool for schools’ disbursements of Pell Grants 

and Direct Loans. FSA further stated that it plans to 

deploy an analysis model, as early as the end of FY 2020, 

to continually monitor partner data and performance. 

FSA noted that this will improve its ability to identify 

schools most at-risk and allow it to more effectively use 

oversight and monitoring resources by informing and 

prioritizing support for schools. FSA also stated that it has 

implemented improvements in response to specific issues 

within this area that were identified by the OIG. 

Oversight and Monitoring of Accrediting Agencies 

According to the Department, over the course of the 

next several years, it will implement additional riskbased procedures to evaluate an accrediting agency’s 

ability to effectively determine and measure schools’ 

compliance with accreditation standards. Additionally, 

the Department will develop a risk-based methodology to 

identify agencies at higher risk of failing to meet statutory 

and regulatory requirements and additional procedures to 

prioritize oversight of those higher risk agencies. 

Oversight & Monitoring of Applicants, Aid 

Recipients, and Borrowers 

FSA stated that it has implemented an improved model 

for verification selection and evaluation of data elements 

from the Federal student aid application. According to 

FSA, this allows it to better identify applicants for which 

errors will result in a change in their Federal aid award, 

potentially reducing improper payments. FSA stated that 

it continually seeks to improve its verification process for 

the Federal student aid application and is seeking costeffective options to verify borrower income and family 

size reporting when borrowers apply for income driven 

repayment plans. The Department has worked with the 

Treasury Department and OMB to propose legislation for 

an exemption to the Internal Revenue Code that would 

allow FSA to directly access tax return information. The 

exemption would greatly reduce verification burden at 

the time of application for financial aid and would enable 

FSA to verify borrower’s information when applying 

for income-driven repayment plans. Additionally, FSA 

Our ongoing audit and inspection work in this area 

includes reviews of the Department’s compliance with 

regulations in its recognition of a selected accreditor, 

involvement in and oversight of activities related to the 

sale and operations of a chain of career colleges, and 

controls over institutional processes for completing 

verification and reporting results. Additional planned 

projects for FY 2020 include audits of schools’ 

compliance with career pathway programs and ability 

to benefit provisions, schools’ use of online program 

management providers, FSA’s transition to the Next 

Generation Financial Services Environment, and FSA’s 

implementation of its Next Generation Payment Vehicle 

Account Program pilot.

Progress in Meeting the Challenge

The Department and FSA stated that they continue 

to improve the risk-based oversight and monitoring 

of the student financial assistance programs, including 

the oversight and monitoring of servicers and vendors, 

schools, accrediting agencies, and the provision of aid to 

program participants. 

Oversight and Monitoring of Contractors, Including 

Servicers and Vendors 

FSA stated that its current oversight and monitoring 

environment includes policies and procedures that 

work to ensure high performance from contractors 

and to prevent fraud, waste and abuse. FSA added that 

it is focused on enforcing high-quality loan servicer 

performance to improve the value of products and 

services that FSA provides. According to FSA, its Chief 

Operating Officer has conducted onsite visits with all 

loan servicers to emphasize expectations for consistent 

and high-quality service. FSA stated that it conducts daily 

monitoring and oversight of all loan servicers, including 

regularly monitoring all servicers’ telephone interactions 

with borrowers. FSA stated that it compiles customer 

satisfaction survey scores and default prevention statistics 

for each Federal loan servicer every 6 months to determine 

each servicer’s allocation of loan volume. FSA also noted 

that it has implemented improvements in response to 

specific issues identified within this area by the OIG. 

According to FSA, because it continually strives to 

improve oversight and monitoring of contractors, it has 

launched the Next Gen FSA initiative. SFA stated that 

a key element of Next Gen FSA will be restructuring 

systems, processes, and contracts to introduce even greater 

accountability based on more target standards, metrics, 

and incentives and disincentives to drive outstanding 
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Oversight and Monitoring—Grantees

The Department is responsible for administering education 

programs that Congress authorized and the President signed 

into law. This responsibility includes awarding program 

funds to eligible recipients and monitoring their progress 

in meeting program objectives, ensuring that programs 

are administered fairly, ensuring grants are executed in 

conformance with both authorizing statutes and laws 

prohibiting discrimination in federally funded activities, 

collecting data and conducting research on education, and 

helping to focus attention on education issues of national 

importance. The funding for many grant programs flows 

through primary recipients, such as SEAs, to subrecipients, 

such as LEAs or other entities. The primary recipients must 

oversee and monitor the subrecipients’ activities to ensure 

compliance with Federal requirements.

The Department’s early learning, elementary, and 

secondary education programs annually serve about 

18,300 public school districts and over 55 million students 

attending more than 98,000 public schools and 34,000 

private schools. The Department awards discretionary 

grants using competitive processes and priorities and 

formula grants using formulas determined by Congress. 

In all cases, the Department’s activities are governed by 

the program authorizing legislation and implementing 

regulations. One of the key programs the Department 

administers is Title I, Part A. Under the President’s FY 

2020 budget request, this program would deliver more 

than $15.8 billion for local programs that provide extra 

academic support to help about 25 million students in 

high-poverty schools meet State academic standards. 

Another key program is the Individuals with Disabilities 

Education Act, Part B Grants to States. This program 

would provide more than $12.3 billion to help States and 

school districts meet the special educational needs of an 

estimated 7 million students with disabilities.

Why This Is a Challenge

Effective monitoring and oversight are essential to ensure 

that grantees meet grant requirements and achieve program 

goals and objectives. Our recent audits related to several 

grant programs identified weaknesses in grantee oversight 

and monitoring that included concerns with SEA and LEA 

controls and Department oversight processes. 

anticipates undertaking a 12-month pilot project to assess 

the incidence of error or fraud in determining monthly 

payment amounts under income-driven repayment 

plans. Based on the results of the pilot project, FSA will 

determine the additional procedures needed, if any, to 

review and verify income for borrowers reporting zero 

income on income-driven repayment plan applications 

and procedures to review and substantiate borrowers’ 

reported family size. 

FSA stated that it implemented a case management 

platform to improve the processing of OIG distance 

education fraud ring referrals during FY 2019. FSA stated 

that this platform allows it to more easily obtain and 

analyze the data from the referrals to better detect and 

prevent fraud. 

What the Department Needs to Do

Through the Next Gen FSA initiative, FSA seeks to create 

an improved, world-class customer experience for FSA’s 

millions of customers. FSA envisions that this initiative 

will create a more agile, flexible model that will streamline 

FSA’s existing operations, improve the integrity of the Title 

IV programs, and transform how it provides oversight 

of organizations that support its mission. The Next Gen 

FSA initiative involves a multistage procurement process 

intended to identify vendors most capable of supporting 

the implementation. While the Next Gen FSA initiative 

has significant potential to improve FSA’s ability to oversee 

and hold accountable its key contractors servicing Federal 

student aid, the initiative is still in its early phases of 

implementation. It will be important for FSA to ensure that 

this initiative is effectively implemented and that it follows 

through to hold its contractors accountable for effectively 

administering their responsibilities. The Department should 

position itself to clearly demonstrate the effectiveness of 

its initiatives to improve oversight of student financial 

assistance programs by setting goals for and measuring 

results that demonstrate progress of its efforts. 

Our audits and investigations of student financial 

assistance program participants and audits of the 

Department’s related oversight and monitoring processes 

will continue to assess a variety of effectiveness and 

compliance elements, with a particular focus on FSA’s 

implementation of its Next Gen initiative. This area 

remains a management challenge given our continued 

findings in this area. 
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Our recent audits of the Department’s oversight and monitoring processes over several grant programs identified internal 

control weaknesses and opportunities for improvement. These weaknesses could limit the Department’s ability to ensure 

that grantees demonstrated progress towards meeting programmatic objectives and properly safeguarded and used Federal 

education funds. Our work included audits within the following areas.

Our recent audits at the SEA and LEA levels identified weaknesses that could have been limited through more effective 

oversight and monitoring. The internal control issues identified within these areas could impact the effectiveness of the 

entities reviewed and their ability to achieve intended programmatic results. This included work related to the following 

programs and activities.

Area Reviewed Review Results

Adult Education We identified opportunities for an SEA to better ensure that it used funds in compliance with applicable laws and 

regulations and obtained and reviewed single audit reports of subgrantees.

Auditee Response to 

Prior Audit Findings

In our series of work on the status of corrective actions on previously reported Title I findings at four school districts, we 

found weaknesses in the design or implementation of related procedures at three of the four districts.

Disaster Recovery We have issued two reports relating to disaster recovery funding authorized under the Bipartisan Budget Act of 2018. 

We identified weaknesses at two SEAs in areas that included programmatic monitoring processes, internal audit division 

staffing, processes to assess fraud risks, internal controls over procurement, and segregation of duties.

McKinney-Vento 

Homeless Assistance 

Act

We found that an SEA generally provided effective oversight of LEAs and coordinated with other entities to implement 

selected requirements related to identifying and educating homeless children and youths. However, we noted that the SEA 

could improve its internal controls by better documenting policies, procedures, and roles.

Statewide Longitudinal 

Data Systems

We found that an SEA’s Statewide Longitudinal Data System and data warehouse did not meet minimum security 

requirements. This increased the risk of breaches that could compromise any stored personally identifiable information. We 

identified similar issues in earlier audits of two other SEAs’ internal controls to protect personally identifiable information in 

their Statewide Longitudinal Data Systems. 

Single Audit Resolution We issued a management information report to highlight areas of concern related to work performed in three States. 

The report included suggested actions that the Department should take to improve SEA oversight of the LEA single audit 

resolution process.

Area Reviewed Review Results

Federal Funding for 

Charter Schools

We found that the Department’s oversight and monitoring efforts were not effective to ensure that the SEAs performed 

charter school closure processes in accordance with Federal laws and regulations. The Department did not provide 

adequate guidance to SEAs on how to effectively manage charter school closures and did not monitor SEAs to ensure that 

they had an adequate internal control system for the closure of charter schools.

Indian Education We identified weaknesses in the Department’s monitoring activities that included a lack of policies and procedures on 

monitoring grantees’ performance and use of funds. We found that monitoring efforts were primarily limited to ensuring that 

grantees spent funds by established deadlines.

Rehabilitative Services We identified weaknesses in controls over the data quality of case service reports in areas that included monitoring 

procedures, data certifications, and procedures related to the use of edit check programs.

Statewide Longitudinal 

Data Systems

We found that the Department lacked controls to ensure that grantees followed grant requirements regarding the protection 

of personally identifiable information in their Statewide Longitudinal Data Systems. This included a lack of monitoring 

to ensure that grantees followed their State laws and regulations regarding IT system security to prevent and detect 

unauthorized access and disclosure of personally identifiable information.
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Ongoing work in this area includes reviews of the Charter School Program Grants for Replication and Expansion of HighQuality Charter Schools, Immediate Aid to Restart School Operations and Temporary Emergency Impact Aid for Displaced 

Students programs, and oversight of virtual charter schools’ implementation of selected requirements under IDEA. Planned 

projects for FY 2020 include work on statewide accountability systems under the Every Student Succeeds Act, controls over 

Student Support and Academic Enrichment Program grants, and the oversight and implementation of requirements related 

to annual determinations for LEAs under IDEA.

Progress in Meeting the Challenge

The Department stated that it focused on several key milestones in FY 2019 to improve grantee oversight and monitoring 

at the SEA and LEA levels and to improve oversight and monitoring of grant programs. The Department reported 

accomplishments in grantee oversight and monitoring across multiple offices. These efforts included actions to implement 

risk-based oversight and monitoring and improving processes to provide timely and effective guidance and technical 

assistance. For example, according to the Department, the Risk Management Services division continued its long-standing 

efforts to identify and mitigate risk across the Department’s formula and discretionary grant programs. In addition, the 

Department reported it took actions to monitor the timely publishing of State report cards and also took actions across 

multiple offices to identify employee skill gaps in grants administration and then to develop strategies to close those gaps. 

The Department also noted that the Office of Special Education and Rehabilitative Services revised the Differentiated 

Monitoring and Support component of its accountability system, Results Driven Accountability, in order to improve its 

focus and efficiency before the release of the OIG’s audit report. It also has developed written policies and procedures that 

further address the OIG’s recommendations. 

The Department stated that the Institute of Education Sciences has provided more effective guidance and technical 

assistance to grantees on privacy issues related to their Statewide Longitudinal Data Systems in several ways that resulted 

in (1) expanded technical assistance from information security and data privacy experts to help States address the technical 

issues raised in the OIG’s audit report; and (2) revised application requirements for new Statewide Longitudinal Data 

Systems awards to provide information on compliance with applicable Federal and State data privacy and information 

technology security requirements up front. These requirements allow applicants to request infrastructure support to meet 

security requirements. The Institute of Education Sciences is also collecting and maintaining data security and privacy 

documentation (policy and processes) as part of its grantee site visit preparation process.

What the Department Needs to Do

The Department’s oversight and monitoring of grantees remains a management challenge given our continued findings 

in this area. However, the Department continues to report progress in enhancing its grantee oversight processes, citing 

numerous actions it has taken to address risks, including those identified in a number of OIG audit reports, and to improve 

outcomes across multiple program offices. The Department should periodically assess the results of these efforts, identify the 

most promising approaches, and determine whether these best practices can be effectively applied in other program offices. 

The OIG’s investigative work continues to identify fraud relating to Federal education grant programs. This includes the 

following areas.

Subject Area Example of Related Investigative Activity

Contractors OIG investigations identified instances were contractors invoiced for services that it did not perform, fraudulently obtained 

contracts, committed bribery, and made kickback payments.

LEA Officials OIG investigations identified instances where LEA officials allowed fraudulent credit card use in exchange for kickbacks, 

embezzled cash, and executed a scheme to obtain funds for personal use by creating false invoices and issuing 

fraudulent checks. 

Charter School Officials OIG investigation identified instances where charter school officials improperly awarded a no-bid contract for equipment on 

campus that had not been constructed in exchange for cash payments, embezzled funds intended for the operation of a 

charter school, and used school credit cards to purchase items for personal use.
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The Department should also continue its efforts to offer common training, encourage effective collaboration and 

communication within and across program offices, and take steps to ensure that its program offices are consistently providing 

effective risk-based oversight of grant recipients—to include both technical assistance and monitoring. Given the flexibilities 

offered by the Every Student Succeeds Act, the Department needs to ensure that its monitoring approaches support State and 

local efforts while providing effective oversight of financial stewardship and ensuring progress towards positive program 

outcomes. Further, 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, including those conducting single audits under OMB 2 C.F.R. 200, Subpart 

F, given its generally limited staffing in relation to the amount of Federal funding that it oversees. 

MANAGEMENT CHALLENGE 4—DATA QUALITY AND REPORTING 

The Department collects, analyzes, and reports on data for many purposes that include enhancing the public’s ability 

to access high-value education-related information, reporting on programmatic performance, informing management 

decisions, and improving education in the United States. The Department collects data from numerous sources, including 

States, which compile information relating to about 18,300 public school districts and 98,000 public schools; over 7,300 

postsecondary institutions, including universities and colleges, as well as institutions offering technical and vocational 

education beyond the high school level; and surveys of private schools, public elementary and secondary schools, students, 

teachers, and principals. 

Why This Is a Challenge

The Department, its grantees, and its subrecipients must have effective controls to ensure that reported data are accurate and 

complete. The Department relies on program data to evaluate program performance and inform management decisions. 

Our recent audit work identified a variety of weaknesses in the quality of reported data and recommended improvements at 

the Department and at SEAs and LEAs. This included the following areas.

Area Reviewed Review Results

Adult Education We found that an SEA used incomplete data obtained from two educational regions, two adult education centers, and a 

subgrantee to prepare its program performance report. 

Borrower Defense We found that FSA did not have an adequate information system to manage borrower defense claim data. We also 

identified weaknesses with FSA’s procedures to review and process borrower defense claims. 

Graduation Rates In a series of three reports on SEAs’ processes to calculate and report graduation rates, we concluded that internal 

controls at each of the three SEAs reviewed did not provide reasonable assurance that reported graduation rates were 

accurate and complete during our audit period. We identified specific weaknesses that included lack of oversight of LEA 

controls over data quality and processes. Specifically, some LEAs improperly included or excluded students from graduate 

rate calculations based on Federal requirements. 

Income-Driven 

Repayment Plans

We found that the Department could have provided more detailed information on specific income-driven repayment 

plans and its loan forgiveness programs to fully inform decision makers and the public about current and future program 

management and financial implications of these plans and programs.

McKinney-Vento 

Homeless Assistance 

Act

We found that an SEA conducted edits and reasonableness checks of data that LEAs submitted, but it did not review LEA 

homeless student data when conducting monitoring reviews. We also noted that LEAs were not required to certify that 

controls over the data were working as intended and known issues were disclosed. 

Ongoing work in this area includes multiple reviews of the accuracy and completeness of displaced student count data 

provided by SEAs to the Department along with multiple reviews of the accuracy and completeness of campus crime 

statistics provided to the Department under the Clery Act. Planned projects for FY 2020 include work to assess the 

effectiveness of the Department’s processes to assist State Vocational Rehabilitation Program grantees in improving their 

financial reporting.
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data verification process in FY 2019 by expanding data 

quality checks, including at the LEA level, and increasing 

standardization. 

According to the Department, the EDFacts Data 

Governance Board consolidated all business rules used 

within the EDFacts system into a Business Rules Single 

Inventory document available to States to support their 

efforts to build internal controls. The Department stated it 

also continues to improve coordination and collaboration 

among offices using submitted data on graduation rates, 

the subject of multiple recent OIG audit reports. The 

Department noted that this has resulted in consistent 

feedback back to States in a more timely fashion, and has 

helped identify questionable data resulting in follow up 

with State data submitters. The Department reported that 

during this past year, the EDFacts data governance process 

resulted in 37 States receiving a total of 300 data quality 

questions or comments from stakeholder program offices 

related to Adjusted Cohort Graduation Rates. According 

to the Department, all identified issues were resolved 

through resubmission or explained through data quality 

comments from the State explaining the observed issue.

What the Department Needs to Do

The Department’s efforts to improve the overall quality 

of data that it collects and reports remain important 

to its program management and reporting. While the 

Department has made progress in strengthening both 

grantees’ data quality processes and its own internal 

reviews of grantee data, findings from our recent audit 

reports show that this area remains an ongoing challenge. 

The Department’s efforts to promote strong data 

management practices across its program offices, which 

include building on data verification processes by 

expanding data quality checks at all levels and increasing 

standardization, are important steps to improving data 

quality. In addition, efforts to perform outreach to States 

and other entities that report data to the Department are 

critical to reinforcing 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 continue its implementation of requirements 

under the Evidence Act, the Information Quality Act, and 

other laws and regulations whose principal aims include 

improving data quality and reporting.

Progress in Meeting the Challenge

The Department noted that under Goal 3 of its Strategic 

Plan, it is committed to strengthening the quality, 

accessibility, and use of education data. In response 

to additional authorities granted by the President and 

Congress to manage education data as a strategic asset, 

the Department stated it is developing a coherent 

and coordinated approach to data governance, data 

management, and data quality to ensure that education 

data provide high value for internal decision makers 

and external stakeholders. Additionally, the Department 

reported that in response to Evidence Act requirements, 

it has named a chief data officer, statistical official, and 

evaluation officer, each of whom has responsibility for 

data quality within their own sphere of authority. Further, 

to facilitate coordination and in adherence with OMB 

guidance, the Department stated it has established an 

agency-wide Data Governance Board which will be 

chaired by the chief data officer and meet regularly 

beginning in November 2019 to set and enforce policies 

for managing data as a strategic asset. The chief data officer 

also leads the Department’s new Office of the Chief Data 

Officer, which is responsible for managing and improving 

the Department’s ability to leverage its data routinely for 

program operations and to inform policy. The chief data 

officer, with the Data Governance Board, is beginning 

the process of selecting a data maturity assessment model 

which will be used to evaluate the current state of the 

Department’s data and data-related infrastructure. 

The Department also noted that it continues to support 

complementary data governance initiatives, including a 

Data Strategy Team and the EDFacts Data Governance 

Board. The Department stated that during FY 2019, the 

Data Strategy Team offered 10 data management trainings 

to 15 program offices on topics including improving data 

quality, understanding differential privacy protections, 

and using data visualization, among others. According to 

the Department, the Data Strategy Team developed eight 

data governance and management tools and templates for 

Department offices, including an example data dictionary, 

a data terms glossary, and a data quality documentation 

guide. The Department further stated that The Data 

Strategy Team also assists the Office of Elementary and 

Secondary Education in planning and managing its Data 

Governance Team, which was created to better understand 

the data collected by the office and to create Office of 

Elementary and Secondary Education-wide strategies and 

standards for use throughout the data lifecycle. Finally, 

the Department stated that the Office of Elementary 

and Secondary Education continued to improve its 
FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION 113

SUMMARY OF FINANCIAL STATEMENT AUDIT AND 

MANAGEMENT ASSURANCES

The following tables provide a summarized report on the Department’s financial statement audit and its management 

assurances. For more details, the auditors’ report can be found beginning on page 82 and the Department’s management 

assurances on page 17.

SUMMARY OF FINANCIAL STATEMENT AUDIT

Audit Opinion: Unmodified

Restatement: No

Material Weaknesses Beginning Balance New Resolved Consolidated Ending Balance

Total Material Weaknesses 1 0 0 0 1

SUMMARY OF MANAGEMENT ASSURANCES

Effectiveness of Internal Control over Financial Reporting—Federal Managers’ Financial Integrity Act 

(FMFIA) 2

Statement of Assurance: Unmodified

Material 

Weaknesses Beginning Balance New Resolved Consolidated Reassessed Ending Balance

Total Material 

Weaknesses 0 0 0 0 0 0

The Department had no material weaknesses in the design or operation of the internal control over financial reporting.

Effectiveness of Internal Control over Operations—FMFIA 2 

Statement of Assurance: Unmodified

Material 

Weaknesses Beginning Balance New Resolved Consolidated Reassessed Ending Balance

Total Material 

Weaknesses 0 0 0 0 0 0

Conformance with Financial Management System Requirements—FMFIA 4

Statement of Assurance: The Department systems conform to financial management system requirements.

Nonconformances Beginning Balance New Resolved Consolidated Reassessed Ending Balance

Total 

Nonconformances 0 0 0 0 0 0

Compliance with Federal Financial Management Improvement Act (FFMIA)

Agency Auditor

1. System Requirements No lack of compliance noted No lack of compliance noted

2. Federal Accounting Standards No lack of compliance noted No lack of compliance noted

3. United States Standard General Ledger at Transaction Level No lack of compliance noted No lack of compliance noted
114 FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION

PAYMENT INTEGRITY

I. PAYMENT REPORTING

OMB Memorandum M-18-20 defines an improper 

payment as any payment that should not have been made 

or that was made in an incorrect amount under statutory, 

contractual, administrative, or other legally applicable 

requirements. Incorrect amounts are overpayments 

or underpayments that are made to eligible recipients 

(including inappropriate denials of payment or service, any 

payment that does not account for credit for applicable 

discounts, payments that are for an incorrect amount, and 

duplicate payments). An improper payment also includes 

any payment that was made to an ineligible recipient or 

for an ineligible good or service, or payment for goods or 

services not received (except for such payments authorized 

by law). In addition, when an agency’s review is unable 

to discern whether a payment was proper as a result of 

insufficient or lack of documentation, this payment should 

also be considered an improper payment.

The Department places a high value on maintaining the 

integrity of all types of payments made to ensure that the 

billions of dollars in federal funds it disburses annually 

reach intended recipients in the right amount and for the 

right purpose. The Department ensures payment integrity 

by establishing effective policies, business processes, 

systems, and controls over key payment activities, 

including those pertaining to: payment data quality, cash 

management, banking information, third-party oversight, 

assessments of audit reports, and financial reporting. 

The number and dollar value of improper payments 

are key indicators of payment integrity. Accordingly, 

the Department maintains a robust internal control 

framework that includes internal controls designed to 

help prevent, detect, and recover improper payments. In 

designing controls, the Department attempts to strike 

the right balance between making timely and accurate 

payments and ensuring that controls put in place are 

not too costly or overly burdensome and thereby deter 

intended beneficiaries from obtaining funds they are 

entitled to receive. Additionally, the Department must rely 

heavily on controls established by external entities that 

receive Department payments, including federal, state, and 

private organizations and institutions, because they further 

distribute funds they receive from the Department to 

subordinate organizations and individuals. Because these 

“third-party” controls are outside of the Department’s 

operational control, they present a higher risk to the 

Department, as evidenced by our root cause analysis. 

When control deficiencies are detected, either within the 

Department or at external entities, the Department seeks 

to identify their root causes, develop corrective action 

plans, and track corrective actions through to completion.

To further promote payment integrity, the Department 

continues to develop its Payment Integrity Monitoring 

Application, which detects anomalies in grants payment 

data. Case management files for payment anomalies 

are established within the application for follow-up 

investigation by the Department’s grants program officials 

to validate improper payments and determine root causes. 

Additionally, the Department continues to develop its 

internal control framework to address gaps, strengthen 

internal control processes, and align assessments with 

enterprise risk management. Both efforts reflect the 

Department’s recognition of the critical importance 

that payment integrity plays in demonstrating financial 

stewardship to the American taxpayer.

Readers can obtain more detailed information on 

improper payments at https://paymentaccuracy.gov.

DESCRIPTION OF RISK-SUSCEPTIBLE 

AND HIGH-PRIORITY PROGRAMS 

In FY 2019, the Pell Grant and Direct Loan programs 

continued to be susceptible to significant improper 

payments and remained OMB-designated high priority 

programs. Also, in FY 2019, the Department began 

monitoring outlays of grant programs receiving funding 

for disaster relief. According to OMB Memorandum 

M-18-14, Implementation of Internal Controls and Grant 

Expenditures for the Disaster-Related Appropriations, 

any disaster-related program with $10 million or more 

in outlays in a given fiscal year is deemed susceptible 

to significant improper payments. The Department 

identified two programs that met this criterion: the 
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PAYMENT INTEGRITY | OTHER INFORMATION

Temporary Emergency Impact Aid for Displaced Students 

(Emergency Impact Aid) and Immediate Aid to Restart 

School Operations (RESTART) programs. 

The Department continues to place additional emphasis to 

ensure payment integrity and minimize improper payments 

in these important programs as required by OMB guidance. 

Details on improper payment estimates, root causes, and 

corrective actions for the programs are included within the 

Improper Payment Estimates, Payment Reporting - Root 

Cause Categories, and Improper Payment Corrective 

Actions sub-sections that follow.

PELL GRANT 

The Pell Grant program, authorized under Title IV 

of the Higher Education Act of 1965 (HEA), provides 

need-based grants to low-income undergraduate and 

certain post-baccalaureate students to promote access to 

postsecondary education. 

DIRECT LOAN 

The Direct Loan program, added to HEA in 1993 by 

the Student Loan Reform Act of 1993, authorizes the 

Department to make loans through participating 

schools to eligible undergraduate and graduate 

students and their parents.

TEMPORARY EMERGENCY IMPACT AID FOR 

DISPLACED STUDENTS

The Temporary Emergency Impact Aid for Displaced 

Students (Emergency Impact Aid) program awards 

emergency impact aid funding to State educational 

agencies (SEAs). SEAs provide subgrants to local 

educational agencies (LEAs) to reimburse the costs of 

educating students enrolled in public schools (both 

traditional and charter) and non-public elementary and 

secondary schools, who were displaced by a covered 

disaster or emergency.

IMMEDIATE AID TO RESTART 

SCHOOL OPERATIONS 

The Immediate Aid to Restart School Operations 

(RESTART) program awards grants to eligible SEAs 

to assist eligible LEAs and non-public schools with 

expenses related to the restart of elementary schools 

and secondary schools in areas impacted by a covered 

disaster or emergency. Funds may be used to assist 

school administrators and personnel in restarting school 

operations, re-opening schools, and reenrolling students.

IMPROPER PAYMENT ESTIMATES

In FY 2019, the Department used statistically valid and 

rigorous sampling and estimation methodologies to 

estimate the improper payment rates for the Pell Grant, 

Direct Loan, Emergency Impact Aid and RESTART 

programs. Please refer to Section VII, Sampling and 

Estimation Methodology, for additional details about 

these methodologies. 

In FY 2018, the Department collaborated with 

stakeholders to identify an approach to overcome 

previously identified challenges with implementing a 

statistically valid estimation methodology for the Pell 

Grant and Direct Loan programs, and in FY 2019, 

FSA implemented a new statistically valid and rigorous 

estimation methodology. This new methodology improves 

the accuracy of the improper payment estimates. The 

prior, non-statistical methodology relied on non-random, 

limited-size sampling of the 100-300 annual FSA Program 

Compliance reviews which target high-risk schools of the 

approximately 5,700 schools that receive Title IV aid. The 

new methodology implemented in FY 2019 is based on a 

larger, random sample of the universe of schools receiving 

Title IV aid. As this is the first year implementing the 

new methodology, modest reduction targets were set. The 

reduction target for the Pell Grant program is 2.22 percent 

and the reduction target for the Direct Loan program is 

0.51 percent. 

According to OMB guidance, reduction targets for 

programs are not expected to be published until a full 

baseline has been established and reported. Baselines for 

the Emergency Impact Aid and RESTART programs will 

not be established until the conclusion of a 24-month 

reporting cycle in FY 2020.

Readers can obtain more detailed information on 

reporting improper payment estimates in FY 2019 and 

prior years at https://paymentaccuracy.gov.
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The FY 2019 Pell Grant estimates include results from the Free Application for Federal Student Aid (FAFSA®) Internal 

Revenue Service (IRS) Data Statistical Study which estimates Pell Grant improper payment rates based on a comparison 

between information reported by applicants on the FAFSA and income details reported to the IRS. Rates from the Study 

are included in the Pell Grant improper payment estimate as a proxy for improper payments associated with misreported 

income. This proxy of misreported income accounts for approximately 77% of the estimated FY 2019 Pell Grant 

improper payments.

 

The source of the FY 2019 Pell Grant and Direct Loan outlay amounts is FSA’s Financial Management System (FMS). The source of Emergency Impact Aid and 

RESTART outlay amounts is the Office of Finance and Operations (OFO)’s Grants Management System (G5). Emergency Impact Aid and RESTART outlays are 

taken from prior year program data. No improper payments were identified in FY 2019 for the RESTART program.
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Program Overpayments

(Dollars in Millions)

Overpayments

(%)

Underpayments

(Dollars in Millions)1

Underpayments

(%)

Unknown

(Dollars in Millions)2

Unknown

(%)

Pell Grants $380.04 58.82% $211.18 32.68% $54.92 8.50%

Direct Loans $199.34 41.26% $40.47 8.38% $243.33 50.36%

Emergency 

Impact Aid $3.87 100% $0 0% $0 0%

RESTART $0 0% $0 0% $0 0%

Total $583.25 51.47% $251.65 22.21% $298.25 26.32%

Table 5. FY 2019 Improper Payments for Risk-Susceptible Programs

1

 In FY 2019, Emergency Impact Aid’s estimated underpayments totaled just $39.50 (not in millions) resulting in an improper payment rate of <0.01%.

2

 For the Pell Grant and Direct Loan programs, “Unknown” improper payments include overpayments and underpayments where the exact amount of the 

overpayment and underpayment is unknown due to lack of supporting documentation maintained by third parties. 

 
118 FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION

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Figure 22 and Figure 23 summarize the estimated amount of improper payments made directly by the Department and 

the amount of improper payments made by recipients of federal money. For additional details, please refer to the Payment 

Reporting – Root Cause Categories section. 

PAYMENT REPORTING - INSUFFICIENT OR LACK OF DOCUMENTATION

Of the $646.14 million and $483.14 million in estimated improper payments for the Pell Grant and Direct Loan programs, 

respectively, approximately 8.50% and 50.36%, respectively, are categorized as improper due to inability to discern whether 

the payment was proper as a result of insufficient or lack of documentation.

Documentation deficiencies for the Pell Grant and Direct Loan programs include but are not limited to inadequate tracking 

of attendance by schools, including inadequate tracking of students’ last date of attendance or withdrawal date, lack of 

other supporting eligibility documentation retained by schools, and lack of evidence to support a school completed required 

verification of information reported by an applicant on their FAFSA.

PAYMENT REPORTING - MONETARY LOSS, NON-MONETARY LOSS, AND UNKNOWN 

This section presents the portion of the improper payment estimates that are attributed to monetary loss, non-monetary 

loss, or unknown. Monetary loss, non-monetary loss, and unknown are defined by OMB. 

 Monetary loss to the Federal Government: An amount that should not have been paid and in theory should/could 

be recovered. 

 Non-monetary loss to the Federal Government: Either an underpayment or a payment to the correct recipient for the 

correct amount where the payment process fails to follow applicable regulation and/or statute. 

 Unknown: The estimated amount within the improper payment estimate that could be either proper or improper 

but the Department is unable to discern whether the payment was proper or improper as a result of insufficient or lack 

of documentation. 

The monetary loss, non-monetary loss, and unknown amounts reported in Table 6 are estimates. Not all monetary loss 

is recoverable. 
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Program Reporting Category Reporting Sub-Category Amount 

(Dollars in Millions)

Percentage of 

Improperly Paid 

Estimate (%)

Pell Grants

Monetary Loss, Non-Monetary 

Loss and Unknown

Estimated Monetary loss to the Government $380.04 58.82%

Estimated Non-Monetary loss to the Government $211.18 32.68%

Estimated Unknown improper payments $54.92 8.50%

Total $646.14 100.00%

Monetary Loss Control

Estimated Monetary loss Within Agency Control $0.00 0.00%

Estimated Monetary loss Outside Agency Control $380.04 58.82%

Direct Loan

Monetary Loss, Non-Monetary 

Loss and Unknown

Estimated Monetary loss to the Government $189.03 39.13%

Estimated Non-Monetary loss to the Government $50.78 10.51%

Estimated Unknown improper payments $243.33 50.36%

Total $483.14 100.00%

Monetary Loss Control

Estimated Monetary loss Within Agency Control $4.91 1.02%

Estimated Monetary loss Outside Agency Control $184.12 38.11%

Emergency 

Impact Aid

Monetary Loss, Non-Monetary 

Loss and Unknown

Estimated Monetary loss to the Government $2.88 74.42%

Estimated Non-Monetary loss to the Government $.99 25.58%

Estimated Unknown improper payments $0.00 0.00%

Total $3.87 100.00%

Monetary Loss Control

Estimated Monetary loss Within Agency Control $0.00 0.00%

Estimated Monetary loss Outside Agency Control $2.88 74.42%

RESTART

Monetary Loss, Non-Monetary 

Loss and Unknown

Estimated Monetary loss to the Government $0.00 0.00%

Estimated Non-Monetary loss to the Government $0.00 0.00%

Estimated Unknown improper payments $0.00 0.00%

Total $0.00 0.00%

Monetary Loss Control

Estimated Monetary loss Within Agency Control $0.00 0.00%

Estimated Monetary loss Outside Agency Control $0.00 0.00%

Table 6. FY 2019 Monetary and Non-Monetary Loss for Risk-Susceptible Programs
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Of the estimated monetary loss for the Pell Grant and Direct Loan programs, the majority is outside of the agency’s 

control. As explained previously, the Department must rely heavily on controls established by external entities that receive 

Department payments, including federal, state, and private organizations and institutions, because they further distribute 

the funds they receive from the Department to subordinate organizations and individuals. These “third-party” controls are 

outside of the Department’s operational control. Examples of root causes outside of the Department’s operational control 

are defined further in the following sections.

PAYMENT REPORTING - ROOT CAUSE CATEGORIES

Our analysis indicated that the underlying root causes of improper payments for the Pell Grant and Direct Loan programs 

in FY 2019 were “Failure to Verify—Financial Data”, “Administrative or Process Errors Made by—Other Party” and 

“Insufficient Documentation to Determine” using categories of error as defined in OMB Circular A-123, Appendix C 

(OMB Memorandum M-18-20). Specific root causes associated with the “Failure to Verify—Financial Data” category 

include, but are not limited to, a school’s failure to perform or properly complete verification, the process by which 

schools confirm the accuracy of select data reported by students on their FAFSA, failure of schools to resolve conflicting 

information reported by applicants, and incorrect self-reporting of an applicant’s information that leads to incorrect awards 

based on Expected Family Contribution (EFC). Specific root causes associated with the “Administrative or Process Errors 

Made by—Other Party” category include, but are not limited to, credit balance errors; Satisfactory Academic Progress not 

achieved; student withdrawal deficiencies; disbursement of funds to ineligible recipients; disbursement of funds to students 

attending ineligible institutions, programs, or locations; incorrect disbursement amounts; disbursements in excess of 

students’ maximum eligibility; documentation deficiencies; improper use of funds; and processing errors at the servicer level. 

Specific root causes associated with the “Insufficient Documentation to Determine” category include, but are not limited 

to, inadequate tracking of attendance by schools, including inadequate tracking of students’ last date of attendance or 

withdrawal date, lack of supporting eligibility documentation retained by schools, and lack of evidence to support a school 

completed required verification of information reported by an applicant on their FAFSA.

 

1

 Improper payment estimates attributed to Insufficient Documentation to Determine are reported as overpayments in accordance with OMB reporting requirements.
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IMPROPER PAYMENT CORRECTIVE ACTIONS

This section presents the corrective actions for the Pell Grant and Direct Loan programs. 

The Department has established an integrated system of complementary oversight functions to help prevent, detect, and 

recover improper payments, and ensure compliance by all participating parties. FSA’s Program Compliance annually 

conducts approximately 100–300 Program Reviews of the approximately 5,700 eligible schools to assess institutions’ 

compliance with Title IV regulations. Program Compliance evaluates a school’s compliance with federal requirements, 

assesses liabilities for errors in performance, and identifies actions the school must take to make the Title IV, HEA programs, 

or the recipients, whole for any funds that were improperly managed and to prevent the same problems from recurring. A 

school with serious violations may be placed on heightened cash monitoring (HCM) for disbursements, lose funding for 

specific programs, or be terminated from participation in all Title IV programs for noncompliance.

FSA’s Program Compliance monitors annual compliance audits of schools. A school that participates in any Title IV 

program must at least annually have a compliance audit of its administration of that program unless an allowable waiver 

or exemption has been granted or, for Single Audit filers, the Title IV programs (major program) have been determined 

low-risk. Independent auditors perform the compliance audits to monitor schools’ administration of FSA programs. If 

any deficiencies are identified, the school must develop a corrective action plan that addresses the audit report findings. 

Auditors are required to evaluate whether the school has taken appropriate corrective action to address findings and 

recommendations from prior audits. FSA’s Program Compliance also performs audit resolution. This includes reviewing 

and evaluating the effectiveness of a school’s corrective action and mitigation efforts for noted exceptions in audit reports.

Figure 25 below shows Emergency Impact Aid root causes for improper payments were attributed to “Administrative or Process 

Error Made by – State Agency” and “Failure to Verify – Other Eligibility Data”, also done at the SEA level. Overpayments for 

the Emergency Impact Aid program resulted in $0.98 million in estimated improper payments attributed to the “Failure to 

Verify – Other Eligibility Data” root cause and $2.89 million to the “Administrative or Process Error Made by – State Agency”. 

Estimated underpayments for Emergency Impact Aid totaled $39.50 (not in millions) and was attributed to the “Administrative 

or Process Error Made by – State Agency” root cause. Root Causes for improper payments include, but are not limited to, the 

program statutory design that specifically authorizes these types of occurrences. The timeline for dispersing the funds is short 

and the program statute allows for upward and downward adjustments to student counts as the data are reviewed through either 

monitoring or audits (even if that review period is beyond the date provided by the state for amending the application). State 

required audits identified issues in the data and funds were returned to the state based upon downward adjustments. 
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Corrective 

Action Status (Including Planned or Actual Completion Dates)1 Root Cause Category

Pursue 

legislation that 

would provide 

an exemption 

to the IRS Tax 

Code Section 

6103 

Long-term. The Department is coordinating with the Treasury Department and OMB 

to pursue legislation that would provide an exemption to the IRS Tax Code Section 

6103 to further streamline FSA’s ability to receive and verify applicants’ and borrowers’ 

income data. FSA expects this to have a meaningful impact on improper payments, 

reduce burden on applicants and schools, and reduce burden on borrowers, helping 

them avoid delinquency and default. Several bills have been introduced in Congress 

that would amend the Internal Revenue Code to allow IRS to disclose tax return 

information to authorized Department officials for purposes of determining eligibility 

for, and amount of, federal student financial aid. 

FSA does not have control over the completion date as this corrective action is 

dependent on the legislative process. The corrective action will be re-assessed at 

the end of FY 2020. Therefore, the planned completion date is tentatively set as 

September 30, 2020.

Misreported income – Information 

reported by an applicant on its FAFSA 

is used to calculate EFC. Schools use 

the EFC to determine federal student 

aid eligibility and financial aid award in 

accordance with Title IV requirements.

Verification Deficiencies – Verification is 

the process where schools, in partnership 

with FSA, confirm the accuracy of 

select data reported by students on 

their FAFSA. FSA’s Central Processing 

System selects which applications are 

to be verified. Schools also have the 

authority to verify additional students. 

Students selected for verification are 

placed in one of several verification 

tracking groups to determine which 

FAFSA information must be verified. 

Items verified include Adjusted Gross 

Income (AGI), taxes paid, and other tax 

data. Income verification helps detect and 

prevent misreported income.

Continue to 

utilize and 

promote the IRS 

Data Retrieval 

Tool (DRT)

On-going. The IRS DRT enables Title IV student aid applicants and, as needed, 

parents of applicants, to transfer certain tax return information from an IRS website 

directly to their online FAFSA. The IRS DRT remains the fastest, most accurate way 

to input tax return information into the FAFSA form. To increase IRS DRT usage, 

and thereby reduce improper payments associated with misreported income, FSA

has taken action to vigorously increase access to and promote the tool. As part of 

the ongoing effort to expand usage of the IRS DRT by applicants and parents, FSA 

publishes information about the benefits and use of the IRS DRT, including on its blog, 

and sends electronic announcements via Information for Financial Aid Professionals 

(IFAP) urging institutions to promote the use of the IRS DRT. FSA actively monitors 

the impact of its promotion of the IRS DRT. For example, FSA reports IRS DRT usage 

figures, disaggregated by dependency status and tax filing status on a quarterly 

basis. FSA also conducts an annual FAFSA/IRS Data Statistical Study (Study). This 

Study includes an analysis of Pell applicants based on IRS DRT usage. Additionally, 

FSA monitors reports from schools and IRS DRT users via annual surveys, usability 

studies, and the FSA Feedback System, among other mechanisms.

The planned completion date is September 30, 2020. The corrective action will be 

re-assessed at the end of FY 2020 and may be renewed, intensified, or expanded for 

FY 2021.

Analyze 

verification data 

to inform the 

upcoming award 

year cycle

On-going. In FY 2019, FSA completed an analysis of the verification data to inform 

the upcoming award year cycle before launch (to allow for system changes) using the 

most recently available data at that time. 

FSA also conducts a monthly review of the verification percentages to determine what 

percentage of applicants were selected for verification. Through this process, FSA 

verifies that the selection process is working as intended.

In FY 2020, FSA will continue to refine the verification selection process. As with prior 

years’ verification selection, data-based statistical analysis will continue to be used 

by FSA to select for verification the 2020–2021 FAFSA applicants with the highest 

statistical probability of error and the impact of such error on award amounts.

The planned completion date is September 30, 2020. The corrective action will be 

re-assessed at the end of FY 2020 and may be renewed, intensified, or expanded for 

FY 2021.

The corrective actions listed below are specific to the root causes of improper payments identified from FY 2019 improper 

payment fieldwork, and are tailored to reflect the unique processes, procedures, and risks involved with the Pell Grant and 

Direct Loan programs.

Table 7. Pell Grant and Direct Loan Improper Payment Corrective Actions—Root Cause Category

1

 FSA does not attempt to quantify the reduction of the improper payment estimates in terms of percentage or amount due to these corrective actions. The 

quantification of results is not feasible because this is FSA’s first year using a statistically valid estimation methodology. Therefore, there are no prior year results to 

compare against. Also, FSA has multiple corrective actions for several of the root causes.
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Publish an 

updated listing 

of FAFSA 

information 

schools and 

applicants may 

be required to 

verify 

Reoccurring (annually). FSA published an updated listing of FAFSA information 

schools and applicants may be required to verify for the 2020–2021 award year. 

This notice was published in the Federal Register on May 24, 2019. Reevaluating 

the FAFSA information schools and applicants may be required to verify helps target 

higher-risk areas while reducing the documentation burden on schools and students. 

In FY 2020, FSA will continue to enhance verification procedures, requiring selected 

schools to verify specific information reported on the FAFSA by student aid applicants. 

FSA will publish an updated notice in the Federal Register announcing the FAFSA 

information schools and financial aid applicants may be required to verify, as well as 

the acceptable documentation for verifying FAFSA information.

The planned completion date is June 30, 2020. The corrective action will be reassessed in FY 2020 and may be renewed, intensified, or expanded for FY 2021.

Misreported income – Information 

reported by an applicant on its FAFSA 

is used to calculate EFC. Schools use 

the EFC to determine federal student 

aid eligibility and financial aid award in 

accordance with Title IV requirements.

Verification Deficiencies – Verification is 

the process where schools, in partnership 

with FSA, confirm the accuracy of 

select data reported by students on 

their FAFSA. FSA’s Central Processing 

System selects which applications are 

to be verified. Schools also have the 

authority to verify additional students. 

Students selected for verification are 

placed in one of several verification 

tracking groups to determine which 

FAFSA information must be verified. 

Items verified include Adjusted Gross 

Income (AGI), taxes paid, and other tax 

data. Income verification helps detect and 

prevent misreported income.

Publish updates 

to questions and 

answers about 

verification 

requirements, if 

identified

On-going. FSA published questions and answers about verification on its website. 

Questions and answers were updated in FY 2019 to help clarify verification 

requirements. These questions and answers provide clarity on verification 

requirements, reducing the risk of verification deficiencies.

FSA will continue to update the frequently asked questions and answers, if updates 

are identified.

The planned completion date is September 30, 2020. The corrective action will be 

re-assessed at the end of FY 2020 and may be renewed, intensified, or expanded for 

FY 2021.
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Publish and 

deliver updated 

free training, 

guidance, and 

resources

Ongoing. The Department annually publishes and delivers updated free training, 

guidance, and resources. This content is annually updated, if not more frequently, 

to target the root causes of improper payments and other frequently identified 

compliance issues. These free training, guidance, and resources include the:

- FSA Training Conference for Financial Aid Professionals. From November 27 to 

November 30, 2018, FSA held its annual FSA Training Conference for Financial 

Aid Professionals to provide training and technical assistance to financial aid 

professionals charged with administering the Title IV student financial assistance 

programs. More than 2,000 unique schools registered for the conference. All 50 

states were represented as well as the U.S. territories to include Guam, Puerto 

Rico, and U.S. Virgin Islands. More than 200 Foreign School officials also attended 

from countries all over the world. The FY 2019 Training Conference included 

sessions related to the root causes of improper payments. The session recordings 

are publicly available. The FSA Training Conference also provides schools direct 

access to federal staff, and one-on-one time with subject matter specialists. In FY 

2020, FSA will again hold and promote the FSA Training Conference. 

- FSA Handbook. FSA annually updates and publishes the FSA Handbook for 

college financial aid administrators and counselors. The FSA Handbook includes 

an Application and Verification Guide, and Volumes on Student Eligibility, School 

Eligibility and Operations, Calculating Awards and Packaging, Processing Aid and 

Managing FSA Funds, and Withdrawals and the Return of Title IV Funds. Each 

volume provides examples and guidance to help schools appropriately administer 

federal student aid. 

- FSA Coach. FSA offers free training via FSA Coach, a suite of interactive courses 

for new and experienced financial aid administrators in the essential knowledge 

and skills needed to successfully administer the federal student aid programs. 

FSA annually updates training content to address annual updates for the new 

award year, provide interactive exercises and self-assessments, and target the 

root causes of improper payments and other frequently identified compliance 

issues. New for 2019, the Department launched the Financial Aid Administrator’s 

Tool Kit. The new FAA Tool Kit, included within FSA Coach, offers quick access 

to Federal Student Aid resources, reference guides, and training material, and is 

designed to assist financial aid professionals in administering the federal student 

aid programs in compliance with federal regulations. In addition to providing 

links to key FSA resources, the Tool Kit also includes short videos to assist with 

navigating several FSA products.

- FSA Assessments. FSA designed, in collaboration with financial aid professionals, 

FSA Assessments that help schools with compliance and improvement activities 

associated with each of the root causes of improper payments. The FSA 

Assessments contain links to applicable laws and regulations as well as guidance, 

worksheets, and checklists to help schools comply with these requirements.

- HomeRoom, the Department’s official blog. The Department maintains a 

blog to provide insights on the activities of schools, programs, grantees, and 

other education stakeholders to promote continuing discussion of educational 

innovation and reform, including activities to help address the root causes of 

improper payments. For example, on September 10, 2019, the Department 

published an article about 7 Things You Need to Know Before You Fill Out the 

2020-21 FAFSA Form. 

FSA solicits input on the effectiveness of these training and resources, and invests in 

improving these critical sources of information to better serve program participants, as 

described above.

The planned completion date is September 30, 2020. The corrective action will be 

re-assessed at the end of FY 2020 and may be renewed, intensified, or expanded for 

FY 2021.

Multiple root causes: verification 

deficiencies; credit balance deficiencies; 

Satisfactory Academic Progress 

deficiencies; student withdrawal 

deficiencies; ineligible recipients; 

ineligible institutions, programs, 

or locations; incorrect amounts; 

documentation deficiencies; improper use 

of funds; maximum eligibility deficiencies; 

and misreported income.
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Initiate an 

assessment 

of the 

feasibility and 

effectiveness 

of servicers 

implementing 

additional 

levels of quality 

assurance over 

processing of 

Loan Verification 

Certificates 

(LVCs)

Completed. In FY 2019, FSA surveyed the Title IV Additional Servicers (TIVAS) 

and reviewed their Direct Loan Consolidation procedures. FSA identified a flawed 

automated TIVAS process which was causing improper payments. The process was 

revised to address the root cause of improper payments. This corrective action will 

eliminate improper payments associated with the flawed automated process.

The actual completion date was May 2019.

Incorrect processing of Loan Verification 

Certificates (LVCs)

Meet with 

the TIVAS 

to discuss 

incorrect 

processing of 

LVCs

Completed. In FY 2019, FSA met with the TIVAS to solicit ideas on how to best 

address incorrect processing of LVCs. No additional or alternative corrective actions 

were identified.

The actual completion date was September 12, 2019.

Update TIVAS 

Direct Loan 

Consolidation 

procedure

Completed. The TIVAS updated its Direct Loan Consolidation procedures to help 

mitigate the risk of Direct Loan Consolidation manual errors.

The actual completion date was September 24, 2019.

Incorrect Direct Loan Consolidation 

manual entry or oversight

Implement 

a new 

reconciliation 

process to 

mitigate 

the risk of 

incorrect Direct 

Loan Refund 

calculations

Completed. The new process was implemented at the TIVAS. As a result, issues 

identified from the new reconciliation process are researched, and any incorrectly 

processed Direct Loan Refunds are cancelled and corrected prior to resulting in 

improper payments.

The actual completion date was July 23, 2019.

Incorrect calculation of Direct Loan 

Refund

Corrective actions are required when a program’s improper payments exceed statutory thresholds, which did not apply to the 

Emergency Impact Aid and RESTART programs in FY 2019.
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III. AGENCY IMPROVEMENT OF 

PAYMENT ACCURACY WITH THE

DO NOT PAY (DNP) INITIATIVE

The Department continues its efforts to prevent and detect 

improper payments via the Department of Treasury’s 

Do Not Pay (DNP) Business Center Portal as required 

by the Improper Payments Elimination and Recovery 

Improvement Act of 2012 (IPERIA), as amended by the 

Bipartisan Budget Act of 2013 and the Federal Improper 

Payments Coordination Act of 2015 (FIPCA). During FY 

2019, 1,607,013 payments, totaling $184.3 billion, were 

reviewed for possible improper payments through the DNP 

Portal screening, which includes the Death Master File 

and the System for Award Management File (SAM). The 

Department continues to validate that potential improper 

payments identified through this screening process were 

properly adjudicated and reported to Treasury timely.

Readers can learn more about DNP at 

https://fiscal.treasury.gov/DNP/.

IV. BARRIERS

The Department must rely on controls established 

by fund recipients who make payments on behalf of 

the Department. These controls are outside of the 

Department’s operational authority. In designing controls, 

the Department strives to strike the right balance 

between providing timely and accurate payments to grant 

recipients and students, while at the same time ensuring 

that the controls are not too costly and burdensome to 

II. RECAPTURE OF IMPROPER 

PAYMENTS REPORTING

Agencies are required to conduct recovery audits for all 

programs and activities that expend more than $1 million 

in a fiscal year, if conducting such audits would be costeffective. The Department determined that payment 

recapture audits would not be cost effective for any of its 

loan and grant programs or for contracts. A comprehensive 

report on the cost effectiveness of the various recapture 

audit programs can be found in the Department’s FY 

2012 Report on the Department of Education’s 

Payment Recapture Audits.

The Department identifies and recovers improper 

payments through sources other than payment recapture 

audits. The Department works with grantees and Title 

IV (FSA) program participants to resolve and recover 

amounts identified in compliance audits, OIG audits, 

and Department-conducted program reviews. The 

Department also analyzes the return of grant funds 

from recipients to determine if they are due to improper 

payments. When an improper payment is detected 

and deemed collectable, the Department establishes an 

account receivable and pursues collections. Recoveries 

are also made through grant program, payroll, and 

other offsets. Recipients of Department funds can 

appeal management’s decisions regarding funds to be 

returned to the Department or they may go bankrupt 

before the Department can collect, thereby delaying or 

decreasing the amounts the Department is able to collect. 

Additionally, the Department has wide discretion to 

decide not to collect improper payments from grantees 

in cases where it determines that pursuing collections 

would cause more harm to the federal interest. For 

these and other reasons, not all identified improper 

payments will ultimately be collected and collections will 

not necessarily be made in the same year as when the 

improper payments were identified.

In FY 2019, the Department identified $220.48 million 

in improper payments and recovered $58.70 million 

in improper payments (or 27 percent), as depicted in 

Figure 26. For detailed information on identified and 

recovered improper payments, readers can visit https://

paymentaccuracy.gov. The Department continues to work 

to improve its methods to identify, collect, and report on 

improper payment collections.

 
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Audit Follow-up

The Department gathers and manages thousands of audits 

of grantees related to our loan and grant programs. Audit 

records are managed, maintained, and analyzed in the 

Department’s automated audit tracking systems. Audits 

are a key source of identifying risks and in identifying 

potential improper payments made by outside entities. 

The Department has demonstrated tremendous success 

in working with grant recipients to resolve audit findings 

timely. The Department is continuously looking for 

options to gain further insight from audit reports and is 

partnering with OMB and others to do so.

VII. SAMPLING AND ESTIMATION METHODOLOGY 

For FY 2019 AFR reporting, the Department used a 

statistically valid and rigorous estimation methodology 

for estimating improper payments for the Pell Grant and 

Direct Loan programs. The Department submitted the 

statistically valid and rigorous estimation methodology 

to OMB on June 26, 2019. This statistical methodology 

uses a random sample of annual compliance audits. A 

small population of schools may apply for and receive 

a waiver or exemption from the compliance audit 

requirements. FSA accounts for these disbursements 

through a statistically valid sampling process. 

Additionally, on June 27, 2019, the Department 

submitted its statistically valid and rigorous 

methodologies for estimating improper payments for 

the Emergency Impact Aid and RESTART programs. 

The Department selected statistical payment samples 

to estimate the percentage and dollar value of improper 

payments for each program’s disbursements associated 

with supplemental disaster relief funding. Sample design 

was developed in accordance with the Improper Payments 

Elimination and Recovery Improvement Act (IPERIA) of 

2012, the Improper Payments Elimination and Recovery 

Act (IPERA) of 2010, the Improper Payments Information 

Act (IPIA) of 2002, and the sampling guidance provided 

in OMB Circular A-123, Appendix C (as revised by 

OMB document M-18-20, Requirements for Payment 

Integrity Improvement). The Department obtained FY 

2018 disbursement data for all disaster-related programs 

via the Department’s grants management system (G5). 

These data were based on amounts distributed from 

fund recipients. Additionally, there are limitations to the 

availability of data necessary to verify FAFSA information 

without increasing the burden on schools and students. 

For example, the Internal Revenue Code does not 

currently permit a database match with the IRS. Such a 

match would eliminate the need to rely on tax transcripts 

submitted by the applicant (and the applicant’s parent, if 

the applicant is a dependent) to verify income data in cases 

where the IRS DRT is not used to transfer tax information 

directly into the FAFSA form.

A detailed discussion of program-specific barriers can be 

found in the FY 2012 Report on the Department of 

Education’s Payment Recapture Audits.

V. ACCOUNTABILITY

The Department offices, managers, and staff are held 

accountable for promoting payment integrity by being 

held accountable for maintaining effective controls in 

their day-to-day jobs and key management officials have 

specific expectations related to payment integrity included 

in their annual performance plans. Additionally, Senior 

Accountable Officials are identified for the Department 

and FSA.

VI. AGENCY INFORMATION SYSTEMS AND 

OTHER INFRASTRUCTURE

FSA Programs

FSA has the internal controls, human capital, and 

information systems and other infrastructure to reduce 

Pell Grant and Direct Loan improper payments. However, 

as noted in Section IV. Barriers, the Department must 

also rely on controls established by fund recipients who 

make payments on behalf of the Department. These 

controls are outside of the Department’s operational 

control. Additionally, there are limitations on FSA’s ability 

to obtain data necessary to verify FAFSA information 

without increasing the burden on schools and students. 

In its most recent budget submission, the Department 

included information on pursuing legislation to aid an 

income data match between FSA and the Internal Revenue 

Service. Such a match would eliminate the need to rely on 

tax transcripts submitted by the applicant and allow FSA 

to verify income directly with the IRS.
128 FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION

OTHER INFORMATION | PAYMENT INTEGRITY

that is not reporting an improper payment estimate. In 

FY 2019, the Department assessed improper payment risk 

for 266 grant activities (formula grants and discretionary 

grant competitions) under approximately 120 program 

authorities identified with disbursements in FY 2018. This 

risk assessment did not identify any additional Education 

programs as being susceptible to significant improper 

payments. In FY 2019, the Department did not conduct 

risk assessments of FSA-managed programs, as all FSAmanaged programs and activities were previously assessed 

for risk in FY 2017. 

SEAs to LEAs. For each state, the sampling timeframe 

represents the list of prior FY payments from which the 

statistical samples were selected.

The methodologies used for each of these programs 

are described in detail on the Department’s improper 

payments website.

VIII. RISK ASSESSMENTS

As required by OMB Circular A-123, Appendix C, the 

Department assesses the risk of improper payments at 

least once every three years for each program and activity 
FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION 129

within the existing Customer Engagement Management 

Systems (CEMS) infrastructure. The fraud referral module 

went live in December 2018, and data migration of 

historical referral information was completed in July 2019. 

This module will enable more comprehensive analysis 

across all OIG fraud referrals and provide better tracking 

of referrals and possible recoveries of resultant improper 

payments. This common and interactive case processing 

tool will also reduce fraud review/case processing time and 

provide analytics to allow for better fraud detection and 

prevention. FSA is also exploring ways to leverage data 

analytics to better detect and combat fraud in operations. 

In FY 2019, the Department revised its improper payment 

risk assessment methodology to include a fraud risk factor 

to assist in identifying fraud risk in non-FSA programs. 

This revised methodology was used to assess the improper 

payment risk of 266 grant activities (formula grants and 

discretionary grant competitions) under approximately 

120 program authorities in FY 2019. The Department 

has also catalogued internal controls related to fraud 

prevention and detection, which includes over 150 

detective and preventive controls related to its grant and 

administrative payments.

Finally, to combat improper use of federal funding under 

the Every Student Succeeds Act (ESSA), the Department 

requires that each recipient and subrecipient publicly 

display the contact information of the Department’s OIG 

hotline to facilitate the reporting of suspected improper 

use of ESSA funding. Furthermore, in accordance with 

2 CFR 200 (Uniform Guidance), each recipient and 

subrecipient provides assurances of truthfulness and 

accuracy of the information they provide in applications 

and in response to monitoring and compliance reviews.

FRAUD REDUCTION REPORT

The Department continues to participate actively 

with OMB and other agencies in a governmentwide workgroup that is collaborating on an 

implementation plan for the Fraud Reduction and Data 

Analytics Act (FRDAA) of 2015. The Department will 

continue to work with OMB to implement the FRDAA.

The Department recognizes the challenges that often 

surround fraud risk management and is taking action to 

address each challenge. These challenges include limited 

resources to conduct fraud risk management activities 

and difficulties in definitively separating fraud from other 

negative outcomes.

The Department is exploring ways to refine or enhance 

its business processes to be in a better position to define, 

deter, detect, and take action on fraud. For Title IV 

programs, FSA has established a Fraud Risk Group 

(FRG) within its Enterprise Risk Management Office to 

build capacity and expertise for and to dedicate resources 

to fraud risk identification and mitigation. The FRG 

established an Enterprise Fraud Risk Advisory Group 

to promote the integration of fraud risk management 

practices and processes into the daily operations of FSA 

to assist in achieving FSA’s strategic goals and objectives. 

Its primary responsibility is to provide oversight, 

planning, and coordination of enterprise fraud risk 

management activities. 

In 2018, responsibility for receiving, processing, and 

taking action on fraud referrals from the Department’s 

Office of the Inspector General (OIG) was transferred 

from FSA’s Finance Office to FRG. FRG launched a new 

initiative to implement workflow and case management 

capabilities to perform analysis of all OIG fraud referrals 
130 FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION

THE DEPARTMENT STRATEGY IS TO:

 Renew workspaces including sit-stand desks and 

ergonomic chairs.

 Allow more natural light into workspaces by providing 

more open workspace.

 Improve use of shared, common, and multi–

functional spaces.

 Enhance technology.

 Provide electronic file storage and reduce paper file 

storage, resulting in a reduced footprint.

The square footage totals are for the office and warehouse 

domestic assets, which are assets located in the 50 states, 

Washington, D.C., and United States territories. The 

square footage total includes owned and leased assets. The 

Department does not own any assets; they are all leased. 

Updated square footage information is posted on the 

performance.gov website.

REDUCE THE FOOTPRINT

The Department’s Space Modernization Program 

strives to bring a new approach to its workplaces: 

by building greater employee performance and 

productivity through innovative space designs and 

technology enhancements, while reducing the agency’s space 

footprint and associated out-year costs. The Reduce the 

Footprint effort will allow the agency to meet the federal 

space guidelines (150–180 usable square footage per person 

vs. the current usable square footage per person of 338).

THE DEPARTMENT CHALLENGES ARE:

 If requested funding is not received, future planned 

projects will be at risk. As a result, the Department 

may be faced with future increased rent payments while 

continuing to occupy oversized, inefficient space. 

 Existing lease terms of several properties restrict the 

Department’s movement to more efficient space.

Table 8. Reduce the Footprint Baseline Comparison

FY 2015 Baseline FY 2018 Change (FY 2015 Baseline to FY 2018)

Usable Area, or 

Usable Square 

Footage per Person

1,548,425 1,382,553 (165,872)
FY 2019 AGENCY FINANCIAL REPORT | U.S. DEPARTMENT OF EDUCATION 131

CIVIL MONETARY PENALTY ADJUSTMENT FOR INFLATION

The Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015, as amended, requires agencies to make 

regular and consistent inflationary adjustments of civil monetary penalties to maintain their deterrent effect. To 

improve compliance with the act, and in response to multiple audits and recommendations, agencies should report 

annually in the Other Information section the most recent inflationary adjustments to civil monetary penalties to ensure 

penalty adjustments are both timely and accurate.

Location for Penalty Update Details:

https://www.federalregister.gov/documents/2019/02/01/2019-00670/adjustment-of-civil-monetary-penalties-for-inflation

Table 9.

Penalty Authority Date of Previous 

Adjustment

Date of Current 

Adjustment

Current Penalty 

Level

Failure to provide information for cost of higher education 20 USC 

1015(c)(5) 15-Jan-18 2-01-19 $38,549

Failure to provide information regarding teacherpreparation programs20 USC 

1022d(a)(3) 15-Jan-18 2-01-19 $32,110

Violation of Title IV of the HEA 20 USC 1082(g) 15-Jan-18 2-01-19 $57,317

Violation of Title IV of the HEA 20 USC 

1094(c)(3)(B) 15-Jan-18 2-01-19 $57,317

Failure to disclose information to minor children and parents 20 USC 

1228c(c)(2)(E) 15-Jan-18 2-01-19 $1,692

Improper lobbying for government grants and contracts 31 USC 

1352(c)(1) 15-Jan-18 2-01-19 $20,134 to $201,340

False claims and statements 31 USC 3802(a)(1) 15-Jan-18 2-01-19 $11,463