FEDERAL STUDENT 

LOANS

Better Oversight 

Could Improve 

Defaulted Loan 

Rehabilitation

Report to Congressional Requesters

March 2014

GAO-14-256

United States Government Accountability Office
United States Government Accountability Office

Highlights of GAO-14-256, a report to 

congressional requesters

March 2014

FEDERAL STUDENT LOANS

Better Oversight Could Improve Defaulted Loan 

Rehabilitation

Why GAO Did This Study

As of fiscal year 2013 about $94 

billion—over 11 percent of federal 

student loan volume in repayment—

was in default, which generally occurs 

when a borrower fails to make a 

payment for more than 270 days. Loan 

rehabilitation was established as an 

option to help Education collect 

defaulted student loans, and borrowers 

address the adverse consequences of 

default, such as repairing damaged 

credit. GAO was asked to review 

Education’s loan rehabilitation process. 

This report examines how: (1) 

Education assists borrowers in 

rehabilitating defaulted student loans; 

(2) the upgrade of its defaulted loan 

information system affected loan 

rehabilitation; and (3) Education 

oversees private collection agencies in 

implementing loan rehabilitation.

GAO reviewed Education’s policies, 

procedures and guidance; contracts 

and monitoring records for the 

defaulted loan information system 

contractor and 22 collection agencies; 

collections and rehabilitation data; and 

relevant federal laws and regulations. 

GAO interviewed Education officials, 

representatives of borrower advocacy 

groups, and visited 6 selected 

collection agencies, based on their 

loan volume and geographic location.

What GAO Recommends

GAO recommends that Education take 

steps to track loan rehabilitation 

performance data and improve 

oversight of its system contractor and 

collection agencies. Education agreed 

with GAO’s recommendations.

What GAO Found

The Department of Education (Education) relies on collection agencies to assist 

borrowers in rehabilitating defaulted student loans, which allows borrowers who 

make nine on-time monthly payments within 10 months to have the default 

removed from their credit reports. Education works with 22 collection agencies to 

locate borrowers and explain repayment options, including rehabilitation. From 

fiscal years 2011 to 2013, Education collected about $9 billion on over 1.5 million 

loans through rehabilitation, most of which was recovered by collection agencies. 

For more than a year after the October 2011 upgrade of its defaulted loan 

information system, Education was unable to provide most borrowers who 

completed rehabilitation with timely benefits, such as removing defaults from their 

credit reports. GAO found the delays largely attributable to gaps in Education’s 

oversight of its system contractor. For example, despite concerns about the 

contractor’s unreliable performance on previous system development efforts, 

Education conducted limited oversight until the contractor began missing 

deadlines. In addition, system testing was not sufficient for Education to detect 

key problems prior to the upgrade. As a result, no rehabilitations were processed 

until April 2012, and officials said they needed until January 2013 to clear the 

resulting backlog. During this time period, Education reported rehabilitating loans 

for about 200,000 borrowers, but it has not developed performance data to 

assess the number or extent of individual borrower delays. Further, Education 

has acknowledged that the system still requires workarounds and a substantial 

amount of development work will need to be completed under a new contract, 

which was awarded in September 2013, to address remaining system issues.

Number of Loan Rehabilitations Processed, Fiscal Years 2011 through 2013

Education has developed tools for overseeing collection agencies, but key 

weaknesses reduce its ability to effectively monitor their performance. 

Specifically, to ensure collection agencies provide borrowers with accurate 

information, Education monitors their interactions with borrowers through 

quarterly reviews of loan rehabilitation phone calls. However, GAO found that 

Education has not consistently completed such call reviews. While Education 

provides the results of its reviews to each collection agency, it does not ensure 

corrective actions are taken and does not systematically analyze results over 

time or across collection agencies to inform its oversight activities. As a result, it 

may be difficult for Education to ensure that borrowers receive accurate 

information regarding loan rehabilitation.

View GAO-14-256. For more information, 

contact Melissa Emrey-Arras at (617) 788-

0534 or emreyarrasm@gao.gov.
Page i GAO-14-256 Federal Student Loans

Letter 1

Background 3

Education Relies on Collection Agencies to Assist Borrowers in 

Rehabilitating Defaulted Student Loans 8

Limited Planning and Oversight of Education’s Defaulted Loan 

Information System Upgrade Adversely Affected Loan 

Rehabilitation 11

Oversight Weaknesses Reduce Education’s Ability to Effectively 

Monitor Collection Agency Performance 21

Conclusions 24

Recommendations 25

Agency Comments and Our Evaluation 25

Appendix I Comments from the Department of Education 28

Appendix II GAO Contact and Staff Acknowledgments 31

Tables

Table 1: Options to Repay Defaulted Federal Student Loans 3

Table 2: Risk Factors Associated with the Defaulted Student Loan 

System Upgrade 14

Figures

Figure 1: The Loan Rehabilitation Process 5

Figure 2: Ways Education Communicates Information about Loan 

Rehabilitation 8

Figure 3: Defaulted Loan Collections, Fiscal Years 2011 through 

2013 10

Figure 4: Defaulted Student Loan System Upgrade Timeline 13

Figure 5: Number of Loan Rehabilitations Processed, Fiscal Years 

2011 through 2013 18

Contents
Page ii GAO-14-256 Federal Student Loans

Abbreviations

CSB Common Services for Borrowers

Education Department of Education

FFEL Federal Family Education Loan

HEA Higher Education Act of 1965

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-14-256 Federal Student Loans

441 G St. N.W.

Washington, DC 20548

March 6, 2014

Congressional Requesters

To help students and their families pay for college, the Department of 

Education (Education) provides billions of dollars in federal student loans 

each year through programs authorized under Title IV of the Higher 

Education Act (HEA) of 1965, as amended.1 However, as of September 

2013, about one out of seven student loan borrowers had defaulted on 

their loan within 3 years of beginning repayment, and approximately $94 

billion of over $814 billion in outstanding federal student loans in 

repayment was in default.2 Education has acknowledged that as its 

student loan portfolio grows, more borrowers are expected to default, 

increasing the financial risk to the federal government. Borrowers who 

default on student loans face serious consequences, including damaged 

credit ratings and difficulty obtaining affordable credit in the future. 

However, one way borrowers can get their loans out of default is through 

loan rehabilitation, a repayment option in which borrowers who make nine 

on-time monthly payments within 10 months have the default removed 

from their credit reports. The federal government has an interest in 

ensuring that the loan rehabilitation process works well given the potential 

savings from returning defaulted loans to repayment. However, when 

Education upgraded its defaulted loan information system in October 

2011, there were reports that some loans remained in default after 

borrowers had made enough payments to rehabilitate the loans, raising 

questions about Education’s ability to rehabilitate loans. In addition, 

because Education relies on information in the system to manage the 

work of collection agencies, questions have been raised about the impact 

of the system upgrade on its ability to oversee debt collection activities. In 

light of these questions, you asked us to examine Education’s 

rehabilitation of defaulted student loans. This report examines: (1) how 

 1

Pub. L. No. 89-329, 79 Stat. 1232-1254, codified at 20 U.S.C. §§ 1070-1099d and 42 

U.S.C. §§ 2751-2756b. 

2

Default generally occurs when a borrower fails to make a payment for more than 270 

days; 20 U.S.C. § 1085(l); 34 C.F.R. §§ 682.200(b) and 685.102(b). However, Education 

generally identifies defaulted loans as those that are 360 days or more past due, because 

the department allows loan servicers 90 days to transfer Direct Loans to Education’s 

Default Resolution Group and Federal Family Education Loan (FFEL) lenders up to 90 

days to file a default claim.
Page 2 GAO-14-256 Federal Student Loans

Education assists borrowers in rehabilitating defaulted student loans; (2) 

how the upgrade of Education’s defaulted loan information system 

affected loan rehabilitation; and (3) how Education oversees collection 

agencies in implementing loan rehabilitation.

In conducting this work, we focused our review on loans included in 

Education’s defaulted loan information system.3 We reviewed the 

contract, contract modifications, and monitoring records for Education’s 

system contractor. We also reviewed contract documentation applicable 

to all 22 collection agencies. We reviewed relevant federal laws and 

regulations to gain an understanding of requirements related to loan 

default and rehabilitation and debt collection as well as Education’s 

policies, procedures, and guidance related to defaulted student loans. We 

interviewed officials from Education, its defaulted student loan system 

contractor, and borrower advocacy and consumer protection groups. 

During these interviews we examined issues related to Education’s 

system upgrade, debt collection process, contractor management and 

oversight, and communication with borrowers. We also reviewed 

Education’s collections and rehabilitation data, from fiscal year 2011 

through 2013, to gain a better understanding of rehabilitation before and 

after the system upgrade. We assessed the reliability of these data by (1) 

performing electronic testing of required data elements, (2) reviewing 

existing information about the data and the system that produced them, 

and (3) interviewing agency officials knowledgeable about the data. We 

determined that the data were sufficiently reliable for the purpose of this 

report. Finally, we conducted site visits to a nongeneralizable sample of 

six collection agencies, selected based on factors such as loan volume 

and geographic location, and reviewed Education’s monitoring records for 

them.

We conducted this performance audit from August 2012 to March 2014 in 

accordance with generally accepted government auditing standards. 

Those standards require that we plan and perform the audit to obtain 

sufficient, appropriate evidence to provide a reasonable basis for our 

 3

According to Education, this includes about $55 billion in Direct and FFEL program loans 

held by the department. We determined that the $39 billion in defaulted FFEL loans held 

and serviced by guaranty agencies—state or nonprofit entities that perform certain 

administrative functions in the FFEL program—were outside the scope of this review, 

because they are not included in Education’s defaulted loan information system. Guaranty 

agencies usually transfer defaulted FFEL loans that are not in repayment to Education for 

collection after 4 years.
Page 3 GAO-14-256 Federal Student Loans

findings and conclusions based on our audit objectives. We believe that 

the evidence obtained provides a reasonable basis for our findings and 

conclusions based on our audit objectives.

Once a student loan goes into default the entire unpaid balance of the 

loan plus accrued interest becomes due.4 The federal government has 

several voluntary and involuntary methods for collecting on defaulted 

loans (see table 1).

Table 1: Options to Repay Defaulted Federal Student Loans

Voluntary options – borrower agrees to repayment

Option Definition

Payment in full Borrower agrees to pay the entire balanced owed.

Compromise Borrower agrees to a reduced overall payment to satisfy the debt(s) in full and 

generally must submit the payment within 90 days.

Loan consolidation Borrower agrees to combine multiple federal student loans into one loan and 

resume repayment.

Loan rehabilitation Borrower agrees to make nine on-time monthly payments within 10 months.

Involuntary options – federal government takes action to collect from the borrower

Option Definition

Treasury offset program After notification from Education, the Department of the Treasury or states (through 

agreements with the Department of the Treasury) offset certain federal or state 

payments owed to the borrower, such as federal or state income tax refunds.

Wage garnishment Education requires borrower’s employer to withhold funds from borrower’s pay and 

send the funds to Education.

Litigation After referral from Education, Department of Justice begins litigation against the 

borrower.

Source: GAO summary of Education documents.

Borrowers who are unable to repay defaulted loans in full may be able to 

negotiate a lower amount as a part of a compromise agreement with the 

department. Education also provides borrowers with options to resolve 

their defaulted loans through loan consolidation or loan rehabilitation by 

 4

Borrowers are also obligated to repay late fees and collection costs. 34 C.F.R. §§ 

682.102(e)(1) and 685.207(a)(1).

Background

Student Loan Default 

Resolution, Including Loan 

Rehabilitation
Page 4 GAO-14-256 Federal Student Loans

making a series of voluntary on-time monthly payments. For example, 

borrowers who make at least three on-time monthly payments can pay off 

defaulted loans by consolidating one or more loans into a single loan with 

a fixed interest rate.5 Borrowers who make nine on-time monthly 

payments within 10 months may be eligible for loan rehabilitation, which 

entitles them to have the default removed from their credit report.6

However, borrowers may rehabilitate a loan only once.7 The loan 

rehabilitation process is shown in figure 1.

 5

34 C.F.R. §§ 682.200(b) and 685.102(b).

6

20 U.S.C. §1078-6(a)(1)(A); 34 C.F.R. §§ 682.405(a)(2) and 685.211(f)(1). To be 

considered on time, the borrower must make the payment within 20 days of the due date 

each month. Borrowers who default on FFEL or Direct Loan programs loans are not 

eligible for Title IV federal student aid. However, Title IV eligibility may be reinstated after 

the borrower makes six on-time monthly payments or if the borrower resolves the default 

through other means, such as loan consolidation or paying the loan in full.

7

20 U.S.C. § 1078-6(b); 34 C.F.R. §§ 682.405(a)(3) and 685.211(f)(4).
Page 5 GAO-14-256 Federal Student Loans

Figure 1: The Loan Rehabilitation Process

Education has additional tools to collect on defaulted loans when 

borrowers do not make voluntary repayment arrangements. For example, 

the Treasury Offset Program allows the federal government to collect on 

defaulted student loans by withholding money from certain federal or 

state payments to borrowers, including federal or state income tax 

refunds and Social Security benefits. Through wage garnishment, 

Education is generally able to collect up to 15 percent of a borrower’s 

disposable pay and apply those funds toward the defaulted loan.8 Before 

using wage garnishment, Education must notify the borrower and provide 

him or her with the opportunity to have a hearing to object to the 

 8

20 U.S.C. § 1095a. For these purposes, disposable pay is defined as the part of an 

individual’s compensation from an employer that remains after the deduction of any 

amounts required to be withheld by law. Id. at § 1095a(e).
Page 6 GAO-14-256 Federal Student Loans

garnishment by showing, for example, that it would cause a financial 

hardship. Payments made through involuntary collections do not count 

toward payments borrowers must make to rehabilitate their loans. Also, 

there is no limit on how long the government can attempt to collect on 

defaulted student loans and, unlike other types of consumer debt, student 

loans cannot be eliminated during bankruptcy proceedings unless the 

court finds that repayment would constitute an undue hardship on the 

borrower and the borrower’s dependents.9

In 2003, Education entered into a 5-year, performance-based contract10

known as Common Services for Borrowers (CSB) to improve the 

management of student loans following disbursement, including loan 

servicing, which includes tracking loans and accepting payments from 

borrowers. The CSB contractor was the sole loan servicer for the 

department’s Direct Loan program and was also expected to modernize 

and integrate four separate information systems for loan servicing, 

consolidation, disability discharge requests,11 and debt collection. The 

base contract had an estimated cost of over $1 billion and allowed the 

government to extend the contract up to 5 more years, increasing the 

potential cost to about $2 billion.

After the CSB contract was awarded in 2003, we reported that Education 

had not yet fully determined how the department would integrate the four 

information systems.12 In response, Education officials said they would 

rely on the contractor to develop these solutions. However, the 

department’s CSB contractor experienced significant software 

development delays and did not identify and resolve problems in a timely 

manner. As a result, in fiscal year 2005 the department issued a cure 

 9

11 U.S.C. § 523(a)(8).

10Performance-based contracts specify the desired outcomes and allow the contractor to 

determine how best to achieve those outcomes, rather than prescribe the methods 

contractors should use.

11A borrower who becomes totally and permanently disabled may be eligible to have their 

student loans discharged thereby releasing the borrower from the obligation to repay the 

loan. 20 U.S.C. § 1087(a); 34 C.F.R. §§ 682.402(c)(1) and 685.213. 

12GAO, Office of Federal Student Aid: Better Strategic and Human Capital Planning 

Would Help Sustain Management Progress, GAO-05-31 (Washington, D.C.: October 

2004).

Education’s Common 

Services for Borrowers 

Contract
Page 7 GAO-14-256 Federal Student Loans

notice, which informs the contractor that the government considers the 

contractor’s failure to make progress as endangering performance of the 

contract or the contractor has failed to perform contractual provisions 

other than delivery of supplies or performance of services.13

Subsequently, the department canceled the systems integration effort in 

May 2007 through a contract modification and the remaining contract 

work focused on loan servicing and maintenance and operation of the 

separate systems.

The CSB contractor was the department’s sole loan servicer until 2009, 

when Education entered into contracts with four additional servicers to 

handle increased loan volume following passage of the Ensuring 

Continued Access to Student Loans Act of 2008.14 Education began 

allocating Direct Loans to the additional servicers in 2010 following 

passage of the SAFRA Act, which terminated the authority to make or 

insure new FFEL loans after June 30, 2010. 15 In addition, the SAFRA Act

required Education to award contracts to eligible not-for-profit servicers to 

assist the department with servicing the increased number of Direct 

Loans.16

 13The cure notice specifies a period (typically 10 days) for the contractor to remedy the 

condition. If the condition is not corrected within this period, the cure notice states that the 

contractor may face the termination of its contract for default. 48 C.F.R. § 49.402-3.

14Pub. L. No. 110-227, 122 Stat. 740. The act provided Education with the authority to 

purchase or enter into commitments to purchase Federal Family Education loans (FFEL) 

from lenders and secondary markets to help ensure continued access to federally 

guaranteed student loans in the wake of the economic downturn. Id. at § 7, 122 Stat. 746.

15Pub. L. No. 111-152, § 2201, 124 Stat. 1029, 1074. The SAFRA Act was enacted as 

part of the Health Care and Education Reconciliation Act of 2010. Education will continue 

to administer FFEL loans until the loans are repaid or discharged.

16Id. at § 2212, 124 Stat. 1029, 1078. The Bipartisan Budget Act of 2013 eliminated the 

requirement that Education contract with eligible not-for-profit servicers. Pub. L. No. 113-

67, Div. A, § 502, 127 Stat. 1165, 1187. However, the explanatory statement 

accompanying the Consolidated Appropriations Act, 2014, Pub. L. No. 113-76, directed 

Education to continue to comply with the terms of its existing contracts with not-for-profit 

servicers through Fiscal Year 2014. 
Page 8 GAO-14-256 Federal Student Loans

Education provides information about loan rehabilitation and relies on 

collection agencies to assist borrowers in rehabilitating defaulted student 

loans. Education provides general information about loan rehabilitation on 

its website, through its call center, and in written notices it sends to 

borrowers when they default (see figure 2).

Figure 2: Ways Education Communicates Information about Loan Rehabilitation

Borrowers who contact Education and make repayment arrangements 

within 65 days of being notified of a default can rehabilitate their loans 

without being turned over to a collection agency and incurring collection 

costs. Education contracts with 22 collection agencies to locate and 

explain repayment options to borrowers who do not make such 

repayment arrangements. Collection agency representatives we 

interviewed told us they use information from Education (e.g., home and 

work phone numbers, mailing address) and proprietary databases to 

locate borrowers. However, they said it can be difficult to contact 

defaulted borrowers, because their contact information on file with 

Education may be out-of-date or they may not answer the collection 

agency’s phone calls.17 Education has taken steps to establish a data 

 17Borrowers are required to maintain current contact information; see 34 C.F.R. §§ 

682.401(b)(5)(iv) and 685.206(b).

Education Relies on 

Collection Agencies 

to Assist Borrowers in 

Rehabilitating 

Defaulted Student 

Loans
Page 9 GAO-14-256 Federal Student Loans

matching agreement with the Internal Revenue Service to obtain mailing 

addresses on borrowers with defaulted loans, and officials said they plan 

to implement the agreement after making system changes. Education 

officials also said they plan to use that agreement as the basis for 

reestablishing an agreement with the Department of Health and Human 

Services to obtain employer address and borrower salary information

through the National Directory of New Hires.

18

When collection agencies make contact with borrowers—usually by 

phone—they discuss options for addressing default, including loan 

rehabilitation. For example, representatives of five collection agencies we 

interviewed said that, in speaking to such borrowers, they emphasize that 

rehabilitating a defaulted student loan also removes the default from the 

borrower’s credit report, a key benefit to the borrower. Officials from two 

borrower advocacy associations agreed that removing the default is 

indeed a key benefit of rehabilitation, but it may not be as advantageous 

as some believe since the borrower’s history of missed payments remains 

on the credit report. Collection agency representatives said they also 

explain that a loan can only be rehabilitated once. The representatives 

also said that borrowers they make contact with are generally receptive to 

learning about loan rehabilitation, particularly once they understand there 

are affordable payment options.

In July 2012, Education developed additional guidelines to better ensure 

borrowers could rehabilitate their loans based on reasonable and 

affordable monthly payments.19 While a standard monthly payment would 

be about one percent of the loan balance, Education’s guidelines allow 

certain borrowers to qualify for lower monthly payments. Depending on 

their income and family size, borrowers’ monthly payments may be as low 

as $5. In March 2013, Education also modified its contracts with collection 

agencies to help ensure that they offer borrowers reasonable and 

affordable payments. Previously, collection agencies earned a $150 

 18At the time Education’s agreement expired in 2010, the Department of Health and 

Human Services had made changes to the security requirements and safeguards 

agencies must have in place to obtain the data.

19Education issued regulations in November 2013, with an effective date of July 1, 2014, 

addressing reasonable and affordable payments: Student Assistance General Provisions, 

Federal Perkins Loan Program, Federal Family Education Loan Program, and William D. 

Ford Federal Direct Loan program, 78 Fed. Reg. 65,768 (Nov. 1, 2013) (codified at 34 

C.F.R. pts 668, 674, 682 and 685). 
Page 10 GAO-14-256 Federal Student Loans

administrative fee for lower payments. Representatives of a borrower 

advocacy group we interviewed expressed concern that this practice 

created an incentive for collection agencies to tell borrowers they had to 

pay more than was actually required. Education now pays collection 

agencies a flat commission for rehabilitated loans based on the type of 

loan regardless of payment size. Education also lowered the commission 

rates for rehabilitated loans from 12.5 to 11.75 percent for Direct Loans 

and 15 percent to 13.25 percent for FFEL and other types of loans. 

Education officials said the department lowered the commission rates 

after observing a substantial increase in loan rehabilitation enrollment 

following the introduction of the guidelines, explaining that if it is easier for 

collection agencies to enroll borrowers they may incur lower costs.

From fiscal year 2011 through 2013, loan rehabilitation accounted for 

more than half of the $15.6 billion Education collected on defaulted 

loans—more than all other repayment options combined. With regard to 

loan rehabilitation collections, collection agencies recovered 97 percent of 

$9 billion collected on over 1.5 million defaulted loans, and collections in 

fiscal year 2013 represented more than half of all rehabilitation collections 

during the 3-year period (see figure 3).

Figure 3: Defaulted Loan Collections, Fiscal Years 2011 through 2013

Note: Borrowers who contact Education and make repayment arrangements within 65 days of being 

notified of a default can rehabilitate their loans without being turned over to a collection agency.
Page 11 GAO-14-256 Federal Student Loans

As a result of limited planning and oversight, Education was unable to 

provide most borrowers who completed loan rehabilitation with timely 

benefits, such as removing defaults from their credit reports, for more 

than a year following the October 2011 upgrade of its defaulted loan 

information system. Education reported that the system, which had been 

in place since 1989, had become costly to maintain and many manual 

workarounds had been developed over the years to address emerging 

requirements. Education officials said it was also necessary to upgrade 

the system to handle increased loan volume the department was 

responsible for servicing.20 Education began exploring options for 

upgrading the system in 2009, and selected six firms to participate in the 

second phase of a two-phase request for proposals in December 2009. 

The original CSB contractor, which was among the firms selected to 

submit a proposal, subsequently offered to upgrade the system at no 

additional cost to the government. The offer stipulated that Education 

would guarantee the contractor a minimum of 5 million non-defaulted 

borrowers to service through the end of the CSB contract. Despite 

previous concerns about the contractor’s performance related to systems 

development work, Education accepted the offer. Education officials 

explained that their decision was based on the contractor’s experience 

with the original system, its proposal to develop the upgrade in 6 months, 

the ease of upgrading through an existing contract, and the contractor’s 

willingness to perform the work at no additional cost to the government. In 

June 2010, Education modified the original system contract to include the 

 20Education anticipated an increase in the number of borrowers with Direct Loans, from 

about 7 million borrowers to about 13 million borrowers. 

Limited Planning and 

Oversight of 

Education’s Defaulted 

Loan Information 

System Upgrade 

Adversely Affected 

Loan Rehabilitation

Education’s Limited 

Planning and Oversight 

Did Not Address Risks of 

System Upgrade
Page 12 GAO-14-256 Federal Student Loans

upgrade and canceled the request for proposals. Figure 4 presents a 

timeline of key milestones related to the system upgrade discussed in this 

report.
Page 13 GAO-14-256 Federal Student Loans

Figure 4: Defaulted Student Loan System Upgrade Timeline
Page 14 GAO-14-256 Federal Student Loans

In moving forward with the upgrade, Education did not have plans for 

monitoring the contract to ensure successful completion of the work and 

increased its oversight only after the contractor began missing deadlines 

for developing the system. Education’s Departmental Directive: Contract 

Monitoring for Program Officials identifies several risk factors that indicate 

greater contract oversight may be needed, and we found three of seven 

risk factors were applicable to the system upgrade (see table 2).21

Table 2: Risk Factors Associated with the Defaulted Student Loan System Upgrade

Risk factor Explanation

Contractor with no performance history or an unreliable 

or unstable performance history or financial condition

CSB contractor had an unreliable performance history and received a cure 

notice in 2005. The CSB contractor was subsequently acquired by a 

company that had no performance history with the department.

Whether multiple subcontractors provided services to the 

contractor

Multiple subcontractors provided a range of services to the contractor during 

the upgrade.

Degree of interrelatedness with other contracts or 

projects

The system is set up to receive transfers of defaulted student loans from 

Education’s loan servicers and provides reports that are used to calculate 

compensation for collection agencies.

Source: GAO analysis of Education documentation.

Note: Education’s directive identifies four additional potential risk factors which we determined did not 

apply to the system upgrade: (1) a variable-price contract (the contract was fixed-price, presenting 

less cost risk to the government); (2) newly-incorporated or emerging organizations; (3) a high dollar 

amount (the contractor agreed to upgrade the system at no-additional cost to the government as part 

of broader negotiations on this contract); and (4) a contract with poorly defined objectives, unclear 

acceptance criteria, or contract requirements that are constantly changing.

Two of the three risks were associated with the selection of the CSB 

contractor to perform the system upgrade. For example, the contractor 

had an unreliable performance history on the contract. From 2004 to 

2006, Education documented concerns regarding the contractor’s ability 

to identify and resolve software development issues. After issuing a cure 

notice in 2005 requiring the contractor to complete certain steps or risk 

defaulting on the contract, Education modified the contract in 2007 to 

remove the systems development work. In addition, the contractor was 

acquired by another company that had no prior experience working with 

Education in February 2010, a few months before the contract was 

modified. Also, the contractor reported that it relied on nine subcontractors to provide a range of services for the upgrade, including 

project management, database administration, and system development.

 21U.S. Department of Education, OCFO 02-108 (Washington, DC: 2009).
Page 15 GAO-14-256 Federal Student Loans

The degree to which the system was interrelated with other contracts 

presented a third risk that would have supported greater monitoring. 

Specifically, Education’s loan servicers are contractually required to 

transfer defaulted loans that are 360 days past due to the system. 

Education officials said they expected additional loan servicers would be 

needed to handle the increased volume of Direct Loans following the 

termination of the authority to make or insure new FFEL loans after June

30, 2010. Education instructed the new not-for-profit loan servicers that 

were expected to begin servicing loans in October 2011 to ensure their 

systems were compatible with the specifications for the upgraded 

defaulted loan information system. In addition, Education relies on the 

system to support its contracts with 22 collection agencies. Specifically, 

information in the defaulted student loan information system is critical for 

managing collection activities, including compensating collection agencies 

and assessing their performance.

Despite these risks, Education officials said they did not create a formal 

monitoring plan for the system upgrade. While Education had a 

monitoring plan in place for the 2003 CSB contract, officials 

acknowledged that it was not relevant for overseeing the upgrade work. 

Education updated its contract monitoring plan in 2011, about a year after 

the upgrade work began and performance problems, such as missed 

deadlines, had occurred. For example, the system development work the 

contractor was scheduled to complete in December 2010 was not finished

until February 2011, and the system was launched 3 months later than 

scheduled. Education reported increasing its oversight during this time 

period, for example, by getting more frequent updates from the 

contractor.

However, we found limited evidence of oversight in our review of contract 

documentation related to the upgrade. Federal regulations require the 

government to conduct quality assurance activities, such as monitoring, to 

ensure that the services received conform to contract requirements.22

Education’s Directive also outlines contract monitoring activities, such as 

reviewing or inspecting deliverables, reviewing invoices, and placing 

telephone calls, among other things. This guidance also notes that 

Education officials must document any instances where the official learns 

the contractor is failing to perform as required or make sufficient progress. 

 22See generally, 48 C.F.R. § 46.401.
Page 16 GAO-14-256 Federal Student Loans

Education officials said they initially monitored the upgrade by tracking 

the contractor’s progress in meeting deadlines. However, they said they 

shifted their focus to reviewing the quality and timeliness of deliverables 

after the contractor expressed concern that progress reporting, among 

other things, affected its ability to focus on the required work. Education 

officials also acknowledged that they did not document many of these 

monitoring activities.

In 2011, we reported that Education had not developed and implemented 

detailed procedures essential to ensuring that its contract monitoring 

policy directives are effectively carried out, including documenting 

contract monitoring activity.23 Based on our recommendation, Education 

issued a new policy in June 2011 that outlined how contract monitoring 

activities and results should be documented, retained, and shared. In our 

review of contract files related to the system upgrade, which included files 

from May 2007 through December 2012, we found emails in which 

Education officials questioned the contractor’s justifications for specific 

tasks in their proposals; however, we did not find documentation of status 

reports, deliverables received, or plans for addressing upgrade-related 

problems as required by Education’s Directive and June 2011 policy.

Education began pilot testing the upgraded information system with 

several thousand borrower accounts in February 2011 to ensure the 

system worked correctly. According to officials, Education did not expect 

to test every function through its full lifecycle before going live, but instead 

focused on testing key functions with a limited number of new borrower 

accounts to reduce the potential for account duplication between the new 

and old systems. While the system was tested to ensure that monthly 

billing was correctly established for borrower accounts entering 

rehabilitation, its ability to identify and process loans that were eligible for 

rehabilitation was not tested. Officials reported that using accounts for 

new defaulted borrowers and conducting testing in a 7-month time frame 

did not allow loan rehabilitation to be fully tested because a borrower 

would need to make nine on-time payments in 10 months before the loan 

could be rehabilitated. While some system issues were found during the 

pilot tests, Education officials reported that key functions, such as loan 

 23GAO, Improved Oversight and Controls Could Help Education Better Respond to 

Evolving Priorities, GAO-11-194 (Washington, D.C.: Feb. 10, 2011). 

System Testing Was 

Insufficient to Detect Loan 

Rehabilitation Problems
Page 17 GAO-14-256 Federal Student Loans

rehabilitation, were working sufficiently to justify proceeding with the 

launch to ensure the system was ready by October 2011. Officials said 

the timing was intended to coincide with the department’s conversion to a 

new loan servicing system for non-defaulted borrowers and 

implementation of contracts with the not-for-profit servicers.

Education realized shortly after the launch that two key functions 

necessary for loan rehabilitation were not working as intended. The 

system was not accepting transfers of defaulted loans from Education’s 

loan servicers, which delayed the start of collection activities, including 

rehabilitation. In December 2012, Education’s Office of Inspector General 

reported that servicers accumulated more than $1.1 billion in loans that 

should have been transferred to Education for management and 

collection. Also, while Education continued collecting on defaulted loans 

that were already in the system, loans were not being rehabilitated 

because the system did not recognize when borrowers had satisfied the 

requirements.

As a result of the system challenges, no loan rehabilitations were 

processed from September 2011 through March 2012, and Education 

officials said they needed until January 2013 to clear the resulting 

backlog. Education processed about 20,000 to 30,000 loan rehabilitations 

a month in fiscal year 2011, prior to the upgrade (see fig. 5). While 

Education was not able to track loan rehabilitations by borrower prior to 

the upgrade, officials estimated that approximately 80,000 borrowers 

were affected during the time the system was not processing 

rehabilitations.

24

 24Education officials said they have estimated that borrowers who use loan rehabilitation 

typically have two to three defaulted loans.
Page 18 GAO-14-256 Federal Student Loans

Figure 5: Number of Loan Rehabilitations Processed, Fiscal Years 2011 through 2013

While Education worked with its CSB contractor to identify and correct the 

problems, it also took steps to assist borrowers. Although Education could 

not process rehabilitated loans through the system, it established 

procedures in November 2011 to assist eligible borrowers by removing 

defaults from their credit reports or reinstating their eligibility for student 

aid. However, borrowers had to contact the department or their collection 

agency in order to receive the assistance. Education officials said they 

provided such benefits to about 7,600 borrowers beginning in November 

2011, but the rehabilitations were not processed through the system until 

April 2012 or later. Moreover, Education officials acknowledged they did 

not systematically track when this assistance was provided.

Education took some steps to hold the contractor accountable for the 

system problems. In September 2011, Education began assessing the 

contractor financial penalties due to implementation delays, as specified 

in the contract modification for the upgrade. While the system upgrade 

was completed at no additional cost to the government, the contractor 

also provided other services under the contract, such as loan servicing, 

operating the defaulted loan information system and providing Education 
Page 19 GAO-14-256 Federal Student Loans

with access to its data centers. In February 2012, when the problems 

were still not resolved, Education notified the contractor via a cure notice 

that it could default on the contract unless adequate progress was made 

on the upgrade issues. Education officials reported that the cure notice 

resulted in increased contractor efforts, such as the contractor providing 

weekly status updates on the most critical upgrade issues at meetings 

between senior contractor and department officials. As of November 

2013, Education reported that it has withheld approximately $14 million 

from total payments to the contractor for other services rendered under 

the contract.

25 Education also planned to continue withholding $125,000 

per month until the contractor made the agreed-upon system 

enhancements and upgrades.

When Education’s upgraded information system began processing loan 

rehabilitations in April 2012, the system still did not always recognize that 

eligible accounts had satisfied the requirements for loan rehabilitation. As 

a result, Education began manually processing loan rehabilitations. This 

required collection agencies to identify and provide the department with 

information on borrowers eligible for rehabilitation, which Education staff 

then verified before recording the rehabilitation in the system. According 

to officials, the system was processing 90 percent of all eligible borrowers 

for rehabilitation by October 2012, with the remaining 10 percent being 

processed through a workaround that required some manual processing. 

Education officials reported that they used manual processing until the 

workaround was automated in September 2013. They acknowledged that 

a substantial amount of development work needs to be completed to 

address the remaining issues; work they expect to be completed under 

the new contract. For example, officials reported that the new system 

contractor will need to complete development work to ensure that the 

system identifies all rehabilitation-eligible borrowers. While Education 

awarded a new contract in September 2013, a bid protest challenging the 

contract award was filed with GAO in November 2013.26 At the time of our 

review, the new contract award had not been finalized, and Education did 

 25Education documented the settlement agreement it reached for withholding payments 

from the contractor based on implementation delays in a December 2012 contract 

modification.

26B-409249.2. The protest was withdrawn on February 19, 2014, prior to a decision being 

issued.

Education Has Made 

Progress Addressing 

Problems since System 

Upgrade, but Lacks Data 

to Measure Its 

Performance
Page 20 GAO-14-256 Federal Student Loans

not have timelines for when work might begin or a final contract 

monitoring plan in place that we could review. To help manage the 

transition of the system to the new contractor, Education extended the 

CSB contract through June 2014 through a contract modification.

While Education has made progress in developing data on the number of 

borrowers it has assisted with loan rehabilitation since the upgrade, it 

lacks data that would inform its performance with respect to its strategic 

goals for providing superior service and information to borrowers and 

safeguarding taxpayer interests. According to The Office of Federal 

Student Aid’s Fiscal Year 2011-2015 Strategic Plan, Education needs to 

be able to collect, analyze, and use customer data to achieve its goals of 

providing superior service and information to students and ensuring 

program integrity and safeguarding taxpayers’ interests. For instance, 

while Education reported rehabilitating about 600,000 loans for 200,000 

borrowers from April 2012 to January 2013, it does not have other data to 

track its loan rehabilitation performance, such as the number of borrowers 

that experience delays in having their loans rehabilitated or the length of 

delays. Similarly, Education does not have data on the extent to which 

borrowers who rehabilitate their loans stay out of default. Without these 

data and related performance measures, Education cannot assess its 

performance in serving borrowers using loan rehabilitation or how 

effective rehabilitation is in minimizing the risk defaulted loans present to 

the federal government.
Page 21 GAO-14-256 Federal Student Loans

Education has developed several mechanisms for overseeing collection 

agencies, but key weaknesses reduce its ability to effectively monitor their 

performance related to loan rehabilitation and other collection activities. 

Education tracks the overall performance of collection agencies using 

data that measures loan rehabilitations as well as other collection

activities.27 Specifically, Education calculates a performance score for 

each agency based on the total dollars collected, the number of accounts 

serviced, and the number of accounts that are resolved through other 

means such as administrative resolutions.28 The department uses these 

data to determine how efficiently collection agencies manage the 

borrower accounts they are allocated and to allocate more accounts to 

higher-performing collection agencies. However, Education has 

experienced delays in assessing collection agencies’ performance 

because quarterly data on the number of accounts managed by each 

collection agency have been unavailable since the defaulted loan 

information system was upgraded in October 2011. As a result, Education 

has not been able to measure collection agency performance on a 

quarterly basis as contractually required. In addition, there have been 

implications for Education’s ability to accurately determine collection 

agency compensation. In May 2013, Education’s Office of the Inspector 

General issued an Alert Memorandum raising concerns that Education 

paid commissions and bonuses to collection agencies based on 

estimated data.

29 In the absence of quarterly data, Education established 

a temporary workaround and modified collection agency contracts in June 

2013 to retroactively assess collection agencies’ fiscal year 2012 

performance based on the cumulative number of accounts assigned to 

each collection agency throughout the year. As of November 2013, 

Education officials reported plans to retroactively assess collection 

agencies’ fiscal year 2013 quarterly performance after completing and 

validating system repairs in April 2014.

 27Information generated through the performance assessment process is used to 

compensate collection agencies for work they complete each quarter and reward high 

performing agencies with bonuses.

28Examples of administrative resolutions include canceling the debt due to the borrower’s 

death, disability, or incarceration.

29United States Department of Education, Office of Inspector General, Federal Student 

Aid Paid Private Collection Agencies Based on Estimates, ED-OIG/L02N0002 (May 15, 

2013).

Oversight 

Weaknesses Reduce 

Education’s Ability to 

Effectively Monitor 

Collection Agency 

Performance
Page 22 GAO-14-256 Federal Student Loans

Beyond tracking quantitative measures of performance, Education also 

monitors the quality of collection agency interactions with borrowers by 

reviewing borrower complaints against collection agencies. When 

collection agencies receive a verbal or written complaint from borrowers 

they are required to suspend collection activity on the account and 

forward a copy of the complaint and their response to Education for 

review. However, Education’s Office of Inspector General issued an Alert 

Memorandum in May 2013 after finding that three collection agencies it 

visited were not reporting verbal complaints to the department as 

contractually required.30 Education subsequently addressed the Inspector 

General’s recommendations to develop a quality assurance program to 

verify that it is receiving all verbal complaints and begin enforcing contract 

requirements related to verbal complaints.

While Education also monitors collection agencies’ interactions with 

borrowers by reviewing their phone conversations with borrowers, its 

approach to conducting these reviews limits its ability to determine if 

collection agencies are providing borrowers with accurate information 

about loan rehabilitation.31 For example, Education has not conducted 

quarterly reviews of each collection agency as stated in its guidance and 

procedures since it began reviewing loan rehabilitation calls in 2011. 

Specifically, we examined call review reports issued between September 

2011 and March 2013 for the six collection agencies we visited. Although 

Education officials told us that quarterly reviews should have been 

conducted during this period, they were unable to provide documentation 

for 11 of the 42 reviews that should have been performed. Education 

officials said the reviews may not have been completed due to competing 

priorities, such as needing to reassign staff to manually process loan 

rehabilitations following the system upgrade. In addition, we found 

Education’s guidance for conducting rehabilitation call reviews was limited 

in that it did not specify key information, such as how calls should be 

selected or the number of calls that should be reviewed. In contrast,

 30United States Department of Education, Office of Inspector General, Verbal Complaints 

Against Private Collection Agencies, ED-OIG/L06M0012 (May 8, 2013).

31Education’s call review guidance specifies that the call review process is to assure (1) 

that collection agencies are placing and answering calls in compliance with the Fair Debt 

Collection Practices Act and the Privacy Act of 1974; (2) that information provided to 

borrowers and others is accurate and appropriate to the nature of the call; and (3) that the 

contents of borrower calls are accurately updated to collection agencies information 

systems.
Page 23 GAO-14-256 Federal Student Loans

Education’s guidance for reviewing all other collection agency 

conversations with borrowers says that staff should randomly select an 

initial sample of 40 calls per agency and review 30 of those calls. 

Education staff we interviewed did not use a consistent approach for 

selecting calls for the initial sample, and not all were using random 

sampling techniques. In addition, staff varied in the number of calls they 

reviewed, from as few as 10 to as many as 30. After we discussed these 

issues with the department in November 2013, Education revised its 

guidance to specify that staff should typically review 20 calls from an 

initial sample of at least 40 calls randomly selected from a list of all calls 

made by each collection agency on one day in the prior quarter.

32

We also found that Education is not making full use of the results of call 

reviews to inform its oversight. The 31 call review reports we examined 

documented a range of errors for each of the six collection agencies we 

visited, including providing borrowers with inaccurate or misleading 

information about rehabilitation program requirements and options. 

Among other things, Education documented instances where collection 

agency representative(s):

• did not explain rehabilitation provisions such as the one-time 

opportunity to rehabilitate a loan, that payments must be made within 

20 days of the due date to be considered on time, or options for 

obtaining a reasonable and affordable payment;

• continued to push loan rehabilitation after the borrower said he was 

unemployed and was unable to make payments; and

• provided false or misleading information, such as incorrectly telling 

borrowers that a down payment or debit card was required to 

rehabilitate a loan.

While Education provides feedback on the results of its call reviews to 

each collection agency, it does not ensure that collection agencies take 

corrective actions or use the information to assess collection agencies’

performance. Education officials reported that the department monitors 

collection agencies to ensure corrective actions are taken. However, 

Education’s call review guidance does not include procedures for such 

monitoring, and Education staff we interviewed told us they rely on 

collection agencies to address problems identified during the call review 

 32The guidance states that workload issues and other priorities may require an adjustment 

to the final number of calls to be reviewed.
Page 24 GAO-14-256 Federal Student Loans

process. Education officials reported that its process for assessing 

collection agency performance relies on objective metrics, such as the 

amount of collections and the number of borrowers reached. Officials said 

that while the current collection agency contracts were established with 

the main goal of maximizing collections for the government, they expect 

new contracts to be awarded in 2014 to include additional language about 

call monitoring and actions the department can take against a collection 

agency if problems are identified in the call review process. Education 

officials told us they have examined call review results for selected 

agencies to determine the types of errors agencies are making, although 

they acknowledged that they have not done so systematically for all 

collection agencies. Without a systematic approach to monitoring the 

results of call reviews, Education may be missing opportunities to target 

its oversight and improve program performance by identifying 

performance issues across collection agencies or over time.

Education collects more funds on defaulted loans through loan 

rehabilitation than any other collection method, making rehabilitation an 

important tool for helping borrowers get out of default and reducing the 

financial risk to the federal government. Given the challenges Education 

has in reaching borrowers who have defaulted on their loans and the onetime opportunity rehabilitation presents, it is important to ensure that 

borrowers seeking to rehabilitate their loans have a seamless experience 

throughout the process. As Education worked with its contractor to 

address problems following the upgrade of its defaulted loan information 

system, it monitored overall loan rehabilitation levels and took steps to 

process the backlog of loans eligible for rehabilitation. However, absent 

accurate data regarding the timeliness of loan rehabilitation and the 

number of borrowers affected by rehabilitation delays it will be difficult for 

Education to assess its progress in addressing system challenges related 

to loan rehabilitation.

Education relies substantially on contractors and collection agencies to 

provide key functions in support of the management and collection of 

defaulted loans, including loan rehabilitation. To ensure that Education is 

addressing its strategic goals for providing the highest levels of customer 

service to borrowers and safeguarding taxpayer interests, it is critical for 

Education to effectively oversee contract performance. The substantial 

delays that many borrowers experienced getting their loans out of default 

after satisfying the requirements for rehabilitation are largely attributable 

to Education not providing oversight appropriate for the risks associated 

with the system upgrade. Without incorporating a risk-based approach to 

Conclusions
Page 25 GAO-14-256 Federal Student Loans

oversight into its planning for systems contracts and modifications, the 

department may continue to receive products and services that are 

delivered late and of unacceptable quality. Moreover, as Education is 

transitioning the defaulted loan information system to a new contractor, 

the ongoing system challenges the new contractor will be expected to 

resolve provide a compelling case for Education to take steps to 

strengthen its oversight. Education’s oversight is also important to 

ensuring that collection agencies provide accurate information to 

borrowers. However, the results of Education’s reviews of selected 

recorded phone calls between collection agencies and borrowers provide 

little such assurance, given the number of incomplete call reviews and the 

limited use of the information.

To strengthen Education’s oversight of the loan rehabilitation process, we 

recommend the Secretary of Education direct the Office of Federal 

Student Aid’s Chief Operating Officer to take the following three actions:

1. develop an approach for tracking loan rehabilitation performance. This 

approach could include options for developing data and related 

performance measures for tracking timely rehabilitation of loans;

2. take steps to ensure that the final monitoring plan for the new 

defaulted loan information system contract identifies risks presented 

by the contractor or contract work and the oversight activities planned 

to address those risks; and

3. take steps to improve its collection agency call review process. For 

example, Education could take steps to ensure that quarterly 

rehabilitation call reviews are completed, establish procedures for 

monitoring collection agency corrective actions, and utilize call review 

results to inform its oversight of collection agencies activities.

We provided a draft copy of this report to Education for review and 

comment. In written comments, Education agreed with our 

recommendations, stating that it shares the concerns raised in the report 

and recognizes its key role in ensuring borrowers receive high-quality 

service and serving as an effective steward in managing the student loan 

portfolio. Education stated that it has already taken some actions in 

response to the recommendations and has plans in place to further 

improve its oversight of the loan rehabilitation process. For example, 

Education reported it has begun developing additional metrics for 

overseeing loan rehabilitation performance, including information on the 

extent to which borrowers with rehabilitated loans default again and 

Recommendations

Agency Comments 

and Our Evaluation
Page 26 GAO-14-256 Federal Student Loans

statistics to help it more quickly identify and resolve rehabilitation process 

issues. To strengthen its oversight of the defaulted loan information 

system, Education stated that it has established a contract monitoring 

plan that tracks key risk areas and identifies risk mitigation strategies, and 

is implementing new project management tools to enhance its monitoring. 

Finally, Education highlighted steps it has taken to strengthen its 

oversight of the collection agency call review process, including revising 

its procedures to improve documentation of corrective actions taken by 

collection agencies and developing a database to track collection agency 

errors and associated corrective actions. While these are positive steps, 

given their preliminary nature, it will be important to track how Education 

builds upon and sustains these actions over time to ensure it is providing 

appropriate levels of oversight. Education’s written comments appear in 

appendix I. Education also provided technical comments which we 

incorporated into the report as appropriate.

As agreed with your offices, unless you publicly announce the contents of 

this report earlier, we plan no further distribution until 30 days from the 

report date. At that time, we will send copies to the Secretary of 

Education, relevant congressional committees, and other interested 

parties. In addition, this report will be available at no charge on GAO’s 

Web site at http://www.gao.gov.

If you or your staff have any questions about this report, please contact 

me at (617) 788-0534 or emreyarrasm@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff who made key contributions to this

report are listed in appendix II.

Melissa Emrey-Arras, Director

Education, Workforce, and

Income Security Issues
Page 27 GAO-14-256 Federal Student Loans

List of Requesters

The Honorable Lamar Alexander

Ranking Member

Committee on Health, Education, Labor, and Pensions

United States Senate

The Honorable John Kline

Chairman

Committee on Education and the Workforce

House of Representatives

The Honorable Virginia Foxx

Chairwoman

Subcommittee on Higher Education and Workforce Training

Committee on Education and the Workforce

House of Representatives

The Honorable Tom Coburn, M.D.

United States Senate

The Honorable Michael B. Enzi

United States Senate
Appendix I: Comments from the Department of 

Education

Page 28 GAO-14-256 Federal Student Loans

Appendix I: Comments from the Department 

of Education
Appendix I: Comments from the Department of 

Education

Page 29 GAO-14-256 Federal Student Loans
Appendix I: Comments from the Department of 

Education

Page 30 GAO-14-256 Federal Student Loans
Appendix II: GAO Contact and Staff 

Acknowledgments

Page 31 GAO-14-256 Federal Student Loans

Melissa Emrey-Arras, (617) 788-0534 or emreyarrasm@gao.gov

In addition to the contact named above, individuals making key 

contributions to this report were Debra Prescott, Assistant Director; Kurt 

Burgeson; Maria Gaona; and Jason Palmer. In addition, key support was 

provided by James Bennett, Deborah Bland, Jessica Botsford, Jason 

Bromberg, Timothy DiNapoli, Holly Dye, Hedieh Fusfield, Kristine 

Hassinger, Anne McDonough-Hughes, Melissa Jaynes, Lara Laufer, 

Charlene Lindsay, Jean McSween, Christie Motley, Kathryn O’Dea 

Lamas, Dae Park, David Perkins, Kenneth Rupar, Linda Sanders, Sylvia 

Schatz, Brian Schwartz, and Charles Youman.

Appendix II: GAO Contact and Staff 

Acknowledgments

GAO Contact

Staff 

Acknowledgments

(131197)
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