Functional Statements > Federal Student Aid

## E. Office of Partner Participation and Oversight

The Office of Partner Participation and Oversight (PPO) is responsible for activities that support and monitor FSA program participants and enforce compliance with laws and regulations governing student financial assistance programs. The activities within PPO cover the entire lifecycle of program participants. To accomplish the PPO mission, PPO is divided into five units, with an Immediate Office that reports directly to the Deputy Chief Operating Officer for PPO.

The Immediate Office provides management and oversight for day-to-day pre- and post-adjudication Borrower Defense (BD) functions. This element will execute "cradle-to-grave" BD operations and planning to include system management and design coordination for platform modifications and Next Gen systems transition; provide business analytics support to synthesize, validate, and report on BD data across multiple Departmental and loan servicer data platforms and repositories; and directly interface with loan servicer oversight, product management, and embedded liaison offices within the Office of Student Experience and Aid Delivery  to optimize BD stakeholder coordination and support BD claims production.

The five directorates are:

- Partner Outreach and Communications Directorate
- Partner Management and Support Services Directorate
- Policy Implementation and Oversight Directorate
- Partner Eligibility and Oversight Services Directorate
- Partner Enforcement and Consumer Protection Directorate

### Partner Outreach and Communications Directorate

The Partner Outreach and Communications Directorate is divided into four groups:

- Internal/External Communications Group
- Partner Training and Information Services Group
- Partner Technical Assistance Group
- Partner Engagement and Relationship Management Group

#### Internal/External Communications Group

This group has two primary responsibilities: (1) to coordinate executive, operational, and web communication related to FSA program participants; and (2) to facilitate communication within the PPO organization.

- Executive needs include congressional inquiries, media inquiries, control correspondence, and Freedom of Information Act (FOIA) requests
- Operational needs include communications that reach mass or targeted audiences in the financial aid community (Electronic Announcements, system-specific reference materials, email and system-generated communications, blog postings, FSATech list serve postings, and StudentAid.gov content related to program and system functioning)
- Web needs include day-to-day management of and long-term improvements to the Information for Financial Aid Professionals (IFAP) website (including the incorporation of software, other tools, and financial partner content into one location)
- PPO organizational needs include, but are not limited to, managing an internal SharePoint Site, the PPO staff contact directory, and orientation materials for PPO units

To accomplish this mission, the Group:

- Establishes working relationships with all PPO and Federal Student Aid areas;
- Ensures clear, consistent, coordinated, accurate, and timely communications that meet the needs of internal and external customers; and,
- Develops, implements, and monitors enhancements to communication platforms, including websites and internal SharePoint, to align with the priorities of FSA and PPO.

#### Partner Training and Information Services Group

This group is responsible for designing, developing, and delivering high quality learning products, publications and web products targeted to FSA program participants, and, as appropriate, Department of Education and operating staff.

The group is also responsible for interfacing with FSA program participants to respond to inquiries and requests for information. To accomplish this mission, the Training and Information Services Group provides the following services:

- Designs, develops, delivers, and evaluates Title IV program training to Title IV participants for national training programs and to internal FSA staff;
- Manages training logistics (i.e., space, registration, training related materials, supplies, and certificates);
- Convenes and manages internal stakeholder groups;
- Works with Federal Student Aid, schools, and other Title IV participants to identify and analyze participants’ learning needs and to develop and deliver training to meet those needs;
- Develops tools and guidelines to assist Title IV participants and Federal Student Aid staff to assess, attain, or improve compliance with Title IV program requirements; and,
- Receives and responds to email inquiries about Federal financial administration from financial aid professionals through the Ask-a-Fed mailbox.

#### Partner Technical Assistance Group

This group is responsible for proactively identifying the unique service needs of various types of institutions of higher education (IHEs), including Historically Black Colleges and Universities (HBCUs), Hispanic Speaking Institutions (HSIs), and Tribally Controlled Colleges and Universities (TCCUs), as prescribed in existing Presidential Executive Orders, and working collaboratively to provide the assistance required to ensure their continued participation in the Title IV programs. The Partner Technical Assistance Group is comprised of the following three divisions:

- Partner Special Initiatives Division
- Minority Serving and Under Resourced School Division
- Proprietary School Assistance Division

To accomplish this mission, these divisions provides program management, oversight, monitoring and targeted technical assistance to improve Title IV program compliance. The group develops tools and guidelines to assist Title IV program participants and Federal Student Aid staff to assess, attain, and improve compliance with Title IV program requirements. There are three strategic areas of concentration: minority serving and under-resourced schools, proprietary schools, and special initiatives.

#### Partner Engagement and Relationship Management Group

The group is responsible for executive partner engagement issues relating to the administration of the Federal Student Aid programs. The group champions institutional outreach activities on behalf of the Department. The group responds to programmatic issues involving FSA program participants and institutional requests involving matters and decisions arising from actions taken by units within PPO.

### Partner Management and Support Services (PMSS) Directorate

The PMSS Directorate consists of two groups and a front office. The PMSS Directorate is responsible for providing management services and support related to the performance of the Title IV portfolio and administering oversight of the institutions (i.e., schools, guaranty agencies, lenders, and servicers) participating in the Department of Education’s Federal Student Aid programs.

The PMSS Directorate front office (FO) allocates the available resources of the unit to achieve organizational goals. The basic function of FO is to supervise FO personnel & to ensure the proper and smooth operation of the FO.

Included in the FO are the following staff and responsibilities:

- Budget and Administrative Officer
- Audit resolution
- Internal & external communications
- Controlled Correspondence & FOIA Liaison
- Policy Implementation & Oversight Liaison

The two groups within the PMSS Directorate are:

- Program Technical and Business Support Group
- Program Delivery Services Group

#### Program Technical and Business Support Group

#### Program Contract Management Division

The Program Contract Management Division partners with the Acquisition Directorate’s PPO Contracts Group to manage and administer the PPO proposed, existing, and expiring contracts, computer matching agreements, interagency agreements and related financial responsibilities. The Division:

- Develops and maintains contract cost projections throughout the life of the contract;
- Monitors actual costs to ensure contract costs remain within the annual budgetary constraints;
- Supports acquisitions, procurements, and transitions; and,
- Manages acquisition requests through the automated processing system and ensures funding availability before requisitioning.

#### Partner Systems Integration Division (PSID)

The PSID is responsible for assessing, coordinating, and planning enterprise solutions for integrating processes and systems. The PSID systems include, the National Student Loan Data System (NSLDS), Postsecondary Education Participant System (PEPS), Electronic Records Management (ERM), Health Education Assistance On-Line Processing System (HOPS), Participation Management System (PM), eZ Audit, Integrated Partner Management Project (IPM), and EDExpress Software.

The Partner Systems Integration Division is organized into two branches, Partner Business Support Branch and Partner Technical Support Branch, that perform the following functions:

The Partner Business Support Branch performs the following functions:

- Operations management of NSLDS, PEPS, eZ Audit, PM, IPM, ERM and HOPS;
- Requirements gathering and authoring for contractor implementation;
- Developing, supporting, and managing change requests, enhancements, and maintenance changes through appropriate lifecycle management;
- Managing various user groups of Federal loan servicers (including HEAL servicers) guaranty agencies, lenders/lender servicers, schools and Department users;
- Ensuring data stored in NSLDS, PEPS, eZ Audit, PM, IPM, ERM and HOPS meet the informational requirements and business needs of the organization;
- Assessing current business processes and systems for data integration opportunities to streamline and standardize business operations data;
- Coordinating data collection enhancements with FSA operations and program oversight areas; and,
- Serving as subject matter experts and business analysts for integrating cross-program data.

The Partner Technical Support Branch performs the following functions:

- Managing processes for Cohort Default Rates, ScoreCards, and Gainful Employment rates;
- Budgeting and forecasting for PSID systems;
- Management of assigned internal and external interfaces; Aligning the re-engineering of PSID’s enterprise systems in accordance with enterprise data strategy and emerging technology standards;  Managing software requirements for EDExpress (a financial aid management software package for schools);  Ensuring that periodic certification and accreditation (C&A) of IPM systems are done in a timely manner and corrective actions are executed for all identified findings and vulnerabilities; and,  Gathering high-level business requirements for integrating enterprise solutions and systems and support implementations of enterprise solutions and systems.  Change Management Division  The Change Management Division, which includes the Business Analysis Branch, performs the following functions:    - Oversees and manages the requirement change management process at a project and organization level, integrates new and changed requirements across FSA systems/services, maintains the project inventory for individual change requests;
  - Aligns with the FSA Enterprise Change Management process adhering to FSA Lifecycle Management Methodology (LMM) and standards (the Change Management process fulfills Management Stage Gate 2);
  - Ensures the alignment of scheduling for requirement changes aligns with FSA’s target state vision, Next Gen FSA program initiatives and master release schedule;
  - Communicates requirement changes to Service/Program Directors, managing an escalations process and the decision points for requesting/identifying funds;
  - Serves as a liaison to the Contracting Officer's Representative (COR)/contract process regarding the Change Management process and procedures ensuring consistent practices across contracts;
  - On-boards new FSA employees and contractors/vendors regarding the Change Management and LMM plans and processes; Manages the requirements gathering/elicitation process fostering enterprise-wide solutions;  Analyzes legislative/regulatory changes and proposed policies/regulations for operational impacts at the project and individual system/service level;  Manages the testing/servicer validation process including the coordination with the Department’s Accessibility Team of compliance testing performed under Sections 508 and 504 of the Rehabilitation Act; and,  Responds to audit requests for change management regarding systems/services.  Additionally, the Change Management Division manages change requests for all systems/services and provides business analysis for each change, creates cross-functional teams to assess business need, impacts, criticality/priority, level of effort and recommends the appropriate course of action. The Change Management Division manages and documents change request validation and assessment reviews. The Change Management Division also performs the following functions:      - Manages the Business Operations Change Management (BOCM) database that records the status and actions for each change request, including user access;
    - Participates in the contract process for requirement changes, articulates requirements to contractors and works with the contractors to support the requirement process;
    - Manages testing processes for systems including test readiness reviews and the plans for User Acceptance Testing (UAT) and Inter-system Testing (IST);
    - Manages the servicers’ validation process collecting and storing validation artifacts; and,
    - Collaborates with the Enterprise Technology Directorate to coordinate technology and security requirement changes impacting systems/services.  Partner Production Division  The Partner Production Division monitors and oversees daily/weekly production activity of systems and provides full oversight of system development and management of the releases. Additionally, the division ensures that the security posture of the systems is maintained and that Federal/ED/FSA standards are implemented for systems. This includes ensuring that appropriate consideration is given to security impacts of planned changes. This requires working with business and technology staff to oversee various system and security activities. The Partner Production Division also performs the following functions:      - Reviews and coordinates infrastructure or other changes with the support contractors;
    - Oversees incident/problem management to prevent problems and resulting incidents, to eliminate recurring incidents, and to minimize the impact of incidents that cannot be prevented;
    - Manages systems development, testing and implementation of the release using Lifecycle Management Methodology (LMM);
    - Coordinates design reviews with the Enterprise Technology Directorate;
    - Scores the risk of the changes to the system and the user community to determine if a Production Readiness Review is required (done in conjunction with the Technical Review Board);
    - Conducts the Production Readiness Review;
    - Maintains system documentation;
    - Monitors and oversees the security of the assigned systems and validates that they are addressed by appropriate support contractors;
    - Ensures Information System Security Officers (ISSOs) review all proposed changes for security issues, and ensure that the security impact of the proposed changes is addressed prior to the changes being deployed in the production environment; and,
    - Conducts periodic and annual reviews of security documents like System Security Plan (SSP), Interconnection Security Agreement (ISA), Memorandum of Understanding (MOU), Computer Matching Agreements (CMA), Privacy Threshold Analysis (PTA), Privacy Impact Assessment (PIA), and Business Impact Analysis (BIA).  Program Delivery Services Group  The Program Delivery Services Group is divided into the following three divisions:      - Grants/Campus Based Partner Division
    - Direct Loans Partner Division
    - Funds Management/School Reconciliation Partner Division  Grants and Campus Based Partner Division  The Grants and Campus Based Partner Division is responsible for providing program management for the grants provided under Title IV of the HEA (Pell Grants, Iraq, Afghanistan Service Grants, and Children of Fallen Heroes Scholarship) and the three Title IV Campus-Based programs -- the Federal Supplemental Education Opportunity Grant (FSEOG), Federal Work Study (FWS), and the Federal Perkins Loan programs.  Key functions of the Grants and Campus Based Partner Division are to:      - Formulate new program management standards and provide program management and oversight for Title IV Grants and Campus-Based programs;
    - Provide expert guidance to assist in formulation of operational policy and procedures related to Title IV Grants and Campus-Based programs and create business rules for the administration of the programs;
    - Develop innovative ideas and provide recommendations for program improvements and/or enhancements for Title IV Grants and Campus-Based programs;
    - Support operational activity related to Title IV Grants and Campus-Based programs; and,
    - Provide support to funds management activities regarding business rules for Title IV Grants awards and Campus-Based award allocations.  Direct Loans Partner Division  The Direct Loans Partner Division manages the William D. Ford Direct Loan (Direct Loan) Program and the TEACH Grant Origination and Disbursement processes maintained on the Common Origination and Disbursement (COD) System and the COD Website, including functionality available to FSA, schools and servicers. The division is responsible for Direct Loan and TEACH Grant origination and disbursement requirements through implementation including, but not limited to, front end editing, credit check functionality, borrower correspondence, and the overall reporting of Direct Loan and TEACH Grant records maintained by the COD System and booked to loan servicing. The division is also responsible for Direct Loan and TEACH Grant specific school eligibility edit requirements. Additional duties include managing paper promissory note processing, subsidized usage inquiries, managing PLUS credit check appeals, and approving COD System data cleanups and production code fixes.  The division also manages the functionality and content available to borrowers on StudentLoans.gov. The functionality and content on StudentLoans.gov include material on loan counseling, income-driven repayment, loan consolidation, and other processes specifically supporting the Direct Loan Program and the TEACH Grant Program.  Direct Loans Partner Division staff initiates and manages updates to system and web site functionality and content arising from FSA’s business needs and changing laws and regulations.  Specific duties include gathering and defining requirements for change, monitoring testing of contractor’s updates, and recommending implementation of all new functionality and content. The Division works with other functional areas to ensure that each system has the information it needs to perform its part to ensure the programs functions effectively overall.  Specific to school partners – the division is responsible for:      - Assisting schools with the development of delinquency management plans and recommending enforcement of quality control and quality assurance reviews (impacting school participation in the Direct Loan Program). As an adjunct to the division, the Default Prevention Group recommends new and innovative operational policy, procedures, and program improvements to prevent loan defaults.
    - Assisting and monitoring contractor research and response to inquiries regarding subsidized usage (SULA), which schools and third-party servicers submit through the COD Website. Outreach is conducted to explain SULA processing and/or guide schools into proper SULA-related reporting to the COD System and NSLDS. The contractor escalates issues to the division and others within FSA on a limited basis.
    - Direction and business rules to support reconciliation of Direct Loan Program funds among financial management system, at schools, and on how to collect Direct Loan funds from schools for prior years.  Funds Management/School Reconciliation Partner Division  This division is responsible for the Funds Control and the Program & School Reconciliation activities related to program funding, program reconciliation, and school reconciliation concerning business operations origination and disbursement of Federal student aid.  To accomplish its mission, the Funds Management/School Reconciliation Partner Division performs the following Funds Control and School Reconciliation functions:      - Establishes new award year set up schemas in the COD System and the G5 Payment system to ensure accurate funding of the Title IV programs;
    - Tests the program and school funding components of various system releases in the COD System;
    - Provides obligation and funding authority, when appropriate, through global program wide funding jobs and individual school funding adjustments in the COD System;
    - Resolves program funding and financial-related data discrepancies in various financial systems such as the G5, the COD System, and the Financial Management System (FMS);
    - Manages Pell Grant program award year closing to minimize the lapse of program funds as well as manage funds cancelation five years after the end of the award year;
    - Supports FSA Finance Directorate’s responses to audit requests and the annual OMB Circular A-123A Internal Review by providing documentation such as monthly reconciliations;
    - Monitors school accountability of program funds based on the calculation of funds drawn down by schools minus disbursements reported by schools at the school level, and provides escalated outreach to schools;
    - Monitors resolution of balances prior to Direct Loan and Teacher Education Assistance for College and Higher Education (TEACH) program year-end closing and reconciliation of Pell balances prior to closing/funding cancellations, and forwards remaining balances for establishment of liability;
    - Coordinates manual account adjustments for Direct Loan borrowers and school cash balances in award years no longer available for update in the COD System; and,
    - Provides guidance to schools for meeting their cash management and financial reconciliation requirements.  Policy Implementation and Oversight Directorate  The Policy Implementation and Oversight Directorate (PIOD) serves as the principal advisor to the PPO Deputy Chief Operating Officer, FSA’s other Deputy Chief Operating Officers, and the Chief Operating Officer (COO) on all Title IV student assistance programs policy issues, collaborating with units and offices across FSA in accomplishing its work. As FSA’s liaison, the PIOD leads and facilitates FSA’s involvement in the development, implementation, and dissemination of Title IV student aid policy by providing information and advice about program administration and operations to other ED offices and Federal agencies. It designs, manages and monitors innovative approaches in the delivery of student aid under the Experimental Sites authority provided by the HEA and develops and maintains the Federal Student Aid Handbook which provides detailed guidance for IHEs.  The PIOD assists PPO directorates, groups, divisions, and branches by informing, advising, assisting and assuring the proper implementation of statutory, regulatory, and other policy requirements in administrating and operating the student aid programs by, among other things, developing and refining procedures and training, and reporting to the PPO Deputy COO on program participants’ compliance with requirements.  It also assists PPO units in ensuring PPO has the information and data needed to conduct its work efficiently and in maintaining quality control.  The PIOD consists of four groups:      - Policy Implementation and Liaison Group (PILG);
    - Policy Innovation and Dissemination Group (PIDG);
    - Performance Management Group (PMG);
    - Reporting and Analysis Group (RAG).  Policy Implementation and Liaison Group (PILG)  The PILG facilitates PPO’s and FSA’s involvement in the development and implementation of Title IV student aid policy and assists in the PIOD’s liaison responsibilities in addition to other critical functions.  The ED offices that the PILG routinely interacts with on behalf of PPO and FSA include the Office of the Under Secretary (OUS); the Office of Postsecondary Education (OPE); the Office of Planning, Evaluation and Policy Development (OPEPD); the Office of the General Counsel (OGC); and the Office of Legislation and Congressional Affairs (OLCA). Other Federal agencies PILG interacts with include: the Office of Management and Budget (OMB); the U.S. Department of the Treasury and the Internal Revenue Service; the U.S. Department of Veterans Affairs; the Departments of Defense; the Department of Homeland Security; the Social Security Administration; and the offices of members of Congress and Congressional committees in collaboration with OCLA.  Specifically, the PILG:      - Identifies policy issues affecting the student financial assistance programs for consultation with PPO and other FSA officials as well as Departmental policy offices (namely OUS, OPE, and OPEPD);
    - Provides advice on behalf of PPO and other FSA officials to Departmental policy offices in the development of regulations, policies, administrative policy guidance, and procedures affecting the Title IV student assistance programs;
    - Formulates policy options based on research and studies of the impact of proposed courses of action;
    - Assists in developing recommended statutory and regulatory changes for improving the Title IV student assistance programs to improve their efficiency and integrity;
    - Drafts policy-related Electronic Announcements for review by senior FSA and Departmental officials;
    - Collaborates with the PIOD Performance Management Group to support FSA program operations and by assisting management in implementing Title IV student aid policy decisions and serving as liaison in resolving issues related to policy implementation;
    - Collaborates with the PIOD Performance Management Group and Reporting and Analysis Group to ensure the consistency and integration of Title IV student aid policy across all PPO units and divisions and other FSA units;
    - Collaborates with the PIOD Performance Management Group and Reporting and Analysis Group in the preparation of reports on the status of the implementation of policy decisions;
    - Assists PPO and other FSA units in preparing and publishing Federal Register Notices for Computer Matching Agreements, Systems of Records, etc.; and,
    - Develops and prepares various forms for OMB clearance required for the Title IV student aid programs.  Policy Innovation and Dissemination Group (PIDG)  The PIDG leads FSA’s efforts to field and monitor innovative, performance-based approaches in the delivery of Federal student aid in accordance with the HEA and policy guidance provided by senior ED officials.  It is also responsible for developing, updating, and disseminating detailed and comprehensive guidance for the approximately 6,000 institutions of higher education that participate in the Federal student financial aid programs. The PIDG also assists other PPO and FSA units and groups in implementing and overseeing statutory and regulatory policies and requirements concerning the delivery of Federal student aid, such as FAFSA processing and verification, cash management, and loan servicing, and issues with the systems used to deliver aid, such as the Central Processing System and the COD System. Specifically, the PIDG:      - Develops and recommends innovative policy options and approaches;
    - Manages the Quality Assurance Program authorized by section 487A(a) of the HEA and provides policy direction and liaison with Departmental offices on FAFSA verification processes and requirements;
    - Designs, manages, and monitors innovative performance-based approaches in student aid delivery under the Experimental Sites Initiative authorized by section 487A(b) of the HEA;
    - Disseminates policy information; and,
    - Develops and publishes the annual update of the Federal Student Aid Handbook (FSAH). This includes:
    Monitoring negotiated rulemaking sessions, proposed and final rules, Electronic Announcements, and other documents to determine if changes need to be made to the FSAH;
Drafting the annual updated FSAH;
Submitting FSAH revisions to reviewing offices, including PPO units and divisions, other operational offices within FSA, and other Departmental offices (e.g., OPE, OUS, OGC, OIG); and,
Consulting with the reviewing offices to address any comments and suggested edits.

    - Responds to policy queries submitted by internal and external parties either directly or through other PPO units and divisions or FSA operating units; and,
    - Supports FSA training for institutional financial aid administrators and other interested parties.  Performance Management Group (PMG)  The PMG provides support to the Partner Eligibility and Oversight Services Directorate (PEOSD), and other PPO directorates, groups, divisions, and branches through the development and review of policy, procedure development and refinement, training, documenting business procedures, providing subject matter expertise for internal and external audits, and the resolution of difficult matters. This group also works closely with other units in planning, structuring, and delivering guidelines and training. Specifically, the PMG:      - Collaborates with the PILG to provide recommendations for policy development and communicating policy decisions to PEOSD and other PPO units;
    - In collaboration with the PILG, represents PEOSD in addressing regulatory and statutory changes with OPE and other Departmental offices;
    - Creates and maintains National Standards for School Eligibility and Oversight Service Group (SEOSG) and Financial Institution Oversight Services Group (FIOSG) business processes (Eligibility, Financials, Compliance Audit, Method of Payment, and Program Review);
    - Conducts quality assurance evaluations to determine the effectiveness of PEOSD (i.e., SEOSG and FIOSG) procedures;
    - Assists PEOSD Groups in drafting, refining, and communicating changes in business process procedures;
    - Coordinates with other units in the development and training of SEOSG and FIOSG staff in the use of automated systems;
    - Reviews and evaluates programmatic publications for consistency with established policies and procedures (e.g., Federal Student Aid Handbook, Audit Guide, Federal Student Aid Coach, Blue Book, etc.). Creates and maintains National Standards for SEOSG and FIOSG business processes (Eligibility, Financials, Compliance Audit, Method of Payment and Program Review);
    - Serves as subject matters experts for internal and external audits (A-123, OIG and GAO); and,
    - Responds to internal programmatic inquiries based on procedures  Reporting and Analysis Group (RAG)  The RAG is responsible for assessing, coordinating, and planning enterprise data solutions for the integration of PPO processes and for the requirements gathering, query development, oversight, quality control, and tracking of internal and external data requests from Federal Student Aid systems.  The Reporting and Analysis Group consists of two divisions, Data Quality and Integrity Division, and TBSSG Support Division.  The Data Quality and Integration Division performs the following functions:      - Ensuring the accuracy, completeness, and consistency of the data across the PPO systems (including Postsecondary Education Participants System (PEPS), eZ-Audit, and National Student Loan Data System (NSLDS));
    - Suggesting ways to improve the data quality of PPO systems;
    - Understanding how and when data are collected and how the data are recorded and stored across PPO systems;
    - Working with other units to gather high-level business requirements for integrating enterprise solutions and systems and support implementation of enterprise solutions and systems; and,
    - Providing expertise and knowledge in the development of queries and data extraction from PPO enterprise systems and serving as subject matter experts and business analysts for integrating cross-program data.  The TBSSG Support Division performs the following functions:      - Monitoring data collection to ensure PPO systems have the quality data necessary for the oversight of institutional eligibility and FSA-serviced loan portfolios and that the data are available and accurate;
    - Serving as members of the FSA Data Review Team to ensure that external data requests from Enterprise Systems can be fulfilled to meet requirements, that expected due dates can be met, and that the results are fully validated prior to delivery;
    - Maintaining benchmarks, dashboards and data monitoring for customer performance and portfolio oversight;
    - Performing quality control reviews to ensure business needs are met and conduct data integrity and reconciliation activities to consistently provide and maintain reliable data and reporting (including Borrower Defense data); and,
    - Providing support to the Risk Analysis Model and trigger and provide reports and data to other Department and external parties as required.  Partner Eligibility and Oversight Services Directorate (PEOSD)  The PEOSD is responsible for providing services and support related to the performance of the Title IV portfolio and administering a program of monitoring and oversight of the institutions (i.e., schools, guaranty agencies, lenders, and servicers) participating in the Department of Education’s Federal Student Aid programs.  The Partner Eligibility and Oversight Services Directorate Immediate Office (IO) allocates the available resources of the unit to achieve the organizational goals. The basic function of IO is to supervise all the IO personnel and to ensure the proper and smooth operation of the IO. Included in the IO are the following staff and responsibilities:      - Budget and Administrative Officer
    - Audit Resolution Liaison
    - Internal & external communications
    - Policy Implementation & Oversight Liaison
    - School closure & emergency response oversight  To accomplish its mission, the PEOSD is divided into the following three groups:      - School Eligibility and Oversight Service Group
    - Financial Institution Oversight Services Group
    - Cohort Default Rate Group  School Eligibility and Oversight Service Group  The School Eligibility & Oversight Service Group (SEOSG) is responsible for administering a program of eligibility, certification, financial analysis, and oversight of schools participating in Federal Student Aid programs.  To accomplish this mission, the School Eligibility & Oversight Service Group is divided into the following School Participation Divisions (SPDs) that specialize in the business processes necessary for managing accountability in campus administration of the Federal student financial aid programs. There are eight School Participation Divisions – seven for domestic schools and one that focuses on both domestic and foreign schools:      - New York/Boston School Participation Division
    - Philadelphia School Participation Division
    - Chicago/Denver School Participation Division
    - Kansas City School Participation Division
    - San Francisco/Seattle School Participation Division
    - Atlanta School Participation & Financial Analysis Division
    - Dallas School Participation & Critical Response Division
    - Multi-Regional and Foreign School Participation Division  **Each of the Regional Participation Divisions (New York/Boston, Philadelphia, Chicago/Denver, Kansas City, San Francisco/Seattle, Atlanta, and Dallas)** has responsibility for the oversight and management improvement services of specific schools assigned to them. These Divisions have the following common responsibilities:      - Examine, analyze, and make determinations on the initial and renewal eligibility applications submitted by schools for participation in the Federal Student Aid programs;
    - Collaborate with the PPO Partner Enforcement and Consumer Protection Directorate regarding decisions to place schools that are under review or investigation on heightened cash monitoring or to impose other necessary participation restrictions;
    - Collaborate and assist the PEOSD IO regarding school closure and disaster responses;
    - Process and maintain records of schools’ Program Participation Agreements and notices of eligibility to participate in the Federal Student Aid programs;
    - Monitor schools and their agents through on-site and off-site reviews and analysis of various reports to provide early warning of program compliance problems and take appropriate actions;
    - Conduct heightened cash monitoring actions and monitor schools’ method of payment;
    - Manage and monitor missing/late audits and financial submissions;
    - Schedule and conduct risk assessment reviews, as needed; Perform audit resolution;  Identify closed, bankrupt, and troubled schools and notify appropriate Department offices;  Work with state agencies and accrediting agencies on closed schools and other issues;  Identify requirements for tuition recovery programs and coordinate the fulfillment of these requirements;  Evaluate and act upon the findings, conclusions, and recommendations produced by other FSA units, e.g., negative cash, compliance referrals;  Determine liabilities owed by schools and/or recommend administrative actions against schools as necessary;  Work closely with and/or refer matters to the Office of Inspector General, the PPO Partner Enforcement and Consumer Protection Directorate, and other offices; and,  Review and update pertinent databases.   In addition, two of the Regional Participation Divisions (Atlanta and Dallas) carry additional responsibilities coordinated centrally for SEOSG.  Atlanta School Participation & Financial Analysis Division  In addition to the common services listed above, this Division also:        - Conducts Financial Analysis and reviews the financial responsibility of schools;
      - Completes detailed analysis of school 90/10 reporting; Conducts fiscal reviews and forensic audits;  Coordinates consistent review of school financial responsibility for all SEOSG Divisions; and  Coordinates analysis outcomes with SEOSG’s decision-making framework.   Dallas School Participation & Critical Response Division  In addition to the common services listed above, this Division also:          - Executes FSA playbook for managing emergency response activities for natural disasters;
        - Coordinates disaster communication with affected schools; Assists disaster-affected schools with special assistance;  Coordinates with other FSA/ED units on unique disaster circumstances and disaster status reporting;  Manages handling of critical school closure activities;Coordinates strategy for assisting students affected by school closures (e.g., webinars, transfer fairs, etc.);
Coordinates communication strategy across FSA in communicating to students affected by school closures (e.g., student website updates, school fact sheets, directed emails, etc.); and,
Provides closure management status report to FSA/ED senior leadership and executives.
Multi-Regional and Foreign Schools Participation Division
The Multi-Regional and Foreign Schools Participation Division is responsible for the oversight and management of the evaluation and certification of publicly traded corporations which own or operate participating IHEs and large school groups (PTCLSG) and foreign schools that apply to participate in the FSA programs.

The Multi-Regional and Foreign Schools Participation Division focuses on monitoring for-profit schools owned by publicly traded corporations, which operate participating, for-profit schools at many eligible locations across States and School Participation Division boundaries. American students can apply for Federal Direct Loans for attendance at approved foreign schools. The Multi-Regional and Foreign Schools Participation Division staff work closely with participating PTCLSG and foreign schools and provide necessary training and technical assistance and perform the oversight functions. The Multi-Regional and Foreign Schools Participation Division examines and conducts analysis to determine the approval or denial of the initial and renewal eligibility applications submitted by schools for participation in the Federal Student Aid programs. The Multi-Regional and Foreign Schools Participation Division also:
- Coordinates with the PPO Partner Enforcement and Consumer Protection Directorate when the school is the subject of an investigation;
- Processes and maintains records of schools’ Program Participation Agreements and notices of eligibility to participate in the Federal Student Aid programs;
- Monitors schools and their agents through on-site and off-site reviews and analysis of various reports to provide early warning of program compliance problems and takes appropriate actions;
- Conducts heightened cash monitoring actions and monitors school’s method of payment;
- Coordinates with the PPO Partner Enforcement and Consumer Protection Directorate when the school is the subject of an investigation;
- Manages and monitors missing/late audits and financial submissions;
- Schedules and conducts compliance initiatives reviews, as needed;
- Performs audit resolution;
- Identifies closed, bankrupt, and troubled schools and notifies appropriate Department of Education offices;
- Works with state agencies and accrediting agencies on closed schools and other issues;
- Identifies requirements for tuition recovery programs and coordinates the fulfillment of these requirements;
- Evaluates and acts upon the findings, conclusions, and recommendations produced by other FSA units, e.g., negative cash;
- Determines liabilities owed by schools and/or recommends administrative actions against schools;
- Works closely with and/or refers matters to the Office of Inspector General, the PPO Partner Enforcement and Consumer Protection Directorate, and other offices; and,
- Reviews and updates pertinent databases.
Financial Institution Oversight Services Group
The Financial Institution Oversight Services Group (FIOSG) is responsible for administering a program of oversight of guaranty agencies, lending institutions, and servicers participating in the Department of Education’s Title IV loan programs. The oversight activities are administered in accordance with policies and procedures established by the Department. To further accomplish its oversight mission, FIOSG is divided into the following divisions:
- New York Division Chicago DivisionDallas Division

These Divisions are responsible for the oversight of guaranty agencies, lenders, and third-party servicers participating in the Title IV loan programs, including conducting nationwide program review initiatives. The FIOSG New York Division has the lead for guaranty agency oversight. The FIOSG Chicago Division has the lead for lender and lender servicer oversight. The FIOSG Dallas Division has the lead for Third Party Servicers (Schools). The Divisions:
- Conduct risk assessment of financial institutions and third-party servicers participating in the Title IV programs;
- Conduct comprehensive and/or focused program reviews of guaranty agencies, lenders, and third-party servicers;
- As required, monitor guaranty agencies, lenders, and third-party servicers to obtain early warning and/or confirmation of issues related to program compliance and financial stability;
- Evaluate and act upon the findings, conclusions, and recommendations produced by audit resolution;
- Determine liabilities owed by guaranty agencies, lenders, or servicers and /or recommend fines that may be imposed against them;
- Monitor the Common Review Initiative process;
- Monitor the Common Claim Initiative;
- Work closely with or refers matters to Office of the Inspector General and the PPO Partner Enforcement and Consumer Protection Directorate; and,
- Review and update pertinent databases.
Cohort Default Rate Group
The Cohort Default Rate (CDR) Group is responsible for the review, analysis, and determination of CDR challenges, adjustments, and appeals.
- Serves as the Department’s data manager responsible for the review and determination of school challenges and appeals of CDR data for loans held by the Department and/or its contracted servicers;
- Manages the electronic appeal system (i.e., ecdr).  Provides technical expertise for system enhancements and modifications;
- Manages the challenge and appeal process in order to ensure accuracy of default data including loan record detail information;
- Performs CDR analysis and data quality examinations;
- Complies CDR data, develops and distributes CDR briefing documents, press packages, and web-site materials; and
- Analyzes, evaluates, and prepares documentation on trending of unduplicated, Federal, commercial, and shared CDR data and develops reports identifying the impact of cohort default rates on schools, guaranty agencies, and lenders.
Partner Enforcement and Consumer Protection Directorate
The Partner Enforcement and Consumer Protection Directorate (“Enforcement”) enforces the HEA and the Department’s regulations as they apply to IHEs. The work is designed to protect students, borrowers, and taxpayers and to enforce compliance with laws and regulations governing student financial assistance programs administered by FSA.

Enforcement carries out its responsibilities through five groups:
- Administrative Actions and Appeals Service Group
- Clery Group
- Investigations Group
- Borrower Defense Group
- Resolution and Referral Management Group

Through one or more of its groups, Enforcement may take or collaborate with other operational business units on the following administrative actions:
- Terminate, suspend, or limit the participation of an IHE in the Title IV programs;
- Impose fines on an HEA for violations of Title IV requirements;
- Debar or suspend the ability of a party to contract with or receive or manage grants from Federal agencies; and
- Require a party to pay for losses incurred by the Department on account of the acts or omissions of the IHE.

These administrative enforcement actions are subject to appeal to the Office of Hearings and Appeals and ultimately the Secretary and constitute final agency actions of the Department. An enforcement action that imposes any of these consequences or requirements often relies on timely collaboration with the Department’s Office of the General Counsel (OGC).

The Chief Enforcement Officer relies on each of the groups to advise on law, in consultation with OGC, that provides legal advice that is the basis for enforcement recommendations provided to Department policymakers.
Administrative Actions and Appeals Service Group
The Administrative Actions and Appeals Service Group (AAASG) implements the Secretary’s authority to fine, limit, suspend, terminate, and impose emergency actions against IHEs that participate in the Department’s Federal Student Aid programs. The AAASG also initiates such actions against guaranty agencies, lenders, and servicers. The AAASG further initiates administrative enforcement actions regarding a school’s eligibility under 34 C.F.R. § 668.13, (i.e., denial of recertification or reinstatement applications; revocation of provisional Program Participation Agreements (PPAs)). The AAASG implements the Secretary’s authority to initiate debarment and suspension proceedings against individuals and other parties. The AAASG also implements the Secretary’s authority to resolve appeals of final audit and final program review determinations. The AAASG’s activities include:
- Developing, initiating, and imposing Emergency/Termination/Limitation/Suspension/Fine actions and assisting OGC in settlement negotiations related to such actions;
- Developing, drafting, and issuing notices revoking provisional PPAs or denying applications for recertification or reinstatement to the student financial assistance programs;
- Participating in on-site reviews and, in coordination with the Investigations Group, OGC, and other FSA compliance staff, conducting interviews, obtaining witness testimony, and obtaining documents in support of administrative enforcement actions;
- Coordinating the resolution of appeals by program participants from final audit and final program review determinations;
- Initiating debarment and suspension proceedings against parties in connection with the student financial assistance programs;
- Issuing warning letters to participating IHEs for non-reporting violations prior to initiating administrative enforcement actions/imposing sanctions; and,
- Collaborating with appropriate FSA staff in advising on compliance measures and potential administrative enforcement actions to ensure consistency across FSA and compliance with procedural, legal, and other guidance.
Clery Group
The Clery Group has oversight responsibility for Campus Safety and Security Reporting by IHEs participating in the Title IV programs. The Clery Group conducts reviews of IHEs’ Annual Security Reports and Annual Fire Safety Reports to ensure the reports contain required safety and security related policy statements, crime and fire statistics, and that the reports are distributed annually to students and employees. The Clery Group also checks to ensure that IHEs report crime and fire statistics to the Department annually and comply with the Drug Free Schools Community Amendment Act of 1989. The Clery Group staff’s responsibilities include:
- Scheduling and conducting Clery Act compliance initiative reviews;
- Managing and performing data analysis on annual Clery Act reports and other law enforcement data;
- Examining how IHEs define their campus geography and classifies and counts reportable crimes;
- Reviewing IHE procedures for the collection of crime statistics from campus security authorities and local police;
- Determining that an IHE maintains a Daily Crime Log and a Fire Log, if it has campus housing facilities;
- Evaluating an IHE’s Timely Warning policy and Emergency Response and Evacuation procedures;
- Reviewing an IHE’s required campus crime and safety policy statements; and,
- Reviewing an IHE’s drug and alcohol abuse prevention program to ensure that the IHE distributes the program annually to each student and employee and that it conducts a biennial review of its program to measure effectiveness and make recommendations.
Investigations Group
The Investigations Group is responsible for identifying and coordinating the investigation of, and response to, indicators of potential misconduct or high-risk conduct on the part of IHEs and third-party servicers (TPSs). The work of the Investigations Group may include the following: 
- Identifying problematic issues at IHEs and TPSs, independently and through coordination with other FSA and ED offices, and other Federal and State agencies;
- Working with Departmental offices and FSA offices such as the Enterprise Data and Analytics Directorate, Enterprise Risk Management Directorate, and other units within FSA to evaluate indicators of potential risk activity at IHEs;
- Conducting targeted investigations, using interviews and administrative subpoenas, to compel production of documents and responses to interrogatories, in order to develop administrative enforcement actions in collaboration, as appropriate, with AAASG, OGC, and other appropriate FSA staff;
- Collaborating actively with other agencies that have complementary enforcement resources, such as the Department of Justice, the Federal Trade Commission, the Securities and Exchange Commission, and States Attorneys General, in building cases against IHEs, and coordinating with the Partner Eligibility and Oversight Services Directorate regarding how such evidence affects ongoing program reviews;
- Providing support to the Office of the General Counsel as needed, including witness testimony, documents, and data analysis, in litigation involving challenges to administrative enforcement actions undertaken at the recommendation of Enforcement;
- Coordinating with the Partner Eligibility and Oversight Services Directorate and the Office of the General Counsel to advise on thorough financial responsibility reviews and appropriate Letters of Credit (LOCs);
- Recommending appropriate amounts for the LOCs from schools to protect ED if these institutions fail, including with respect to accountability related to liability for borrower defense claims;
- Working with the Partner Eligibility and Oversight Services Directorate to review applications for certification, eligibility, and expansion from IHEs that are under investigation by the Investigations Group, and place restrictions on Program Participation Agreements (PPAs) as necessary to address concerns;
- Investigating IHEs in connection with borrower defense claims;
- Analyzing the Department’s ability to make recoveries against IHEs based on evidence obtained from borrower defense claims and other appropriate evidentiary sources; and,
- Coordinating with enforcement divisions of other Federal and State agencies regarding borrower defense claims.
Borrower Defense Group
The Borrower Defense Group considers and issues decisions on claims by individual borrowers who assert a defense to repayment of Federal student loans based on an act or omission of an IHE that gives rise to a cause of action under State law or Federal regulations, as applicable. The work includes the following:
- Conducting legal research and analysis of borrower defense claims and assessing injury;
- Corresponding with IHEs and third parties to obtain information and records needed to evaluate borrower defense claims;
- Consulting with the Investigations Group as needed to gather additional information regarding individual borrower defense claims and referring to the Investigations Group those claims that appear to indicate a pattern, practice, or repeated instances of conduct giving rise to borrower defense claims;
- Issuing written notices of the Department’s decision on the individual’s borrower defense claim to the borrower after timely collaboration with the Office of the General Counsel; and,
- Coordinating with enforcement divisions of other Federal and State agencies regarding individual borrower defense claims.
Resolution and Referral Management Group
The Resolution and Referral Management Group has the primary responsibility for the tracking and resolution of Title IV compliance complaints, referrals, suspicious activity, and/or allegations concerning non-Federal individuals or institutions that participate in the Title IV, HEA Programs. Complaints, suspicious activity and referrals are received from sources that include, but are not limited to, the general public, students, school officials, external oversight partners, other FSA entities and partners such as the OIG, the Department’s Office for Civil Rights (OCR), the U.S. Department of Defense, the U.S. Department Veterans Affairs, and the Consumer Financial Protection Bureau. Complaints, suspicious activity and referrals are primarily received via the Federal Student Aid (FSA) Feedback System, but may also be submitted via email, telephone, inter-office mail and the postal service. 
  Last Modified: 04/29/2020