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Federal Student Aid's Use of Pandemic Assistance Student Aid Administration Funds (ED-OIG/F21DC0081)

Summary

A U.S. Department of Education Office of Inspector General Final Flash Report, Federal Student Aid's Use of Pandemic Assistance Student Aid Administration Funds, Control Number ED-OIG/F21DC0081, dated August 1, 2023. The report states that as of November 30, 2022, FSA obligated nearly 100 percent of the $161.1 million in appropriations it received for these funds from the three major coronavirus response and relief laws. It states that nine FSA business units obligated approximately $157.8 million, 98 percent, and that approximately $3.2 million in unobligated ARP funds remained. It states that the funds were used for personnel, information technology systems and contractual services.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Issuer
Congressional materials
Document type
Ed Oig Fsa Pandemic Admin Funds Federal Student Aid S Use Of Pandemic Assistance Student A
Case
Ed Oig Fsa Pandemic Admin Funds Federal Student Aid S Use Of Pandemic Assistance Student Aid Administration Fund

Cite this document

“Federal Student Aid's Use of Pandemic Assistance Student Aid Administration Funds (ED-OIG/F21DC0081).” Original at oig.ed.gov. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/ed-oig-fsa-pandemic-admin-funds-federal-student-aid-s-use-of-pandemic-assistance-student-aid-administration-fund/, SHA-256 949fc3f10c7cb8be8e66e193a5a7ade826305c7f886f66b9bee8c9f064d5bc55.

Full text

                 U.S. Department of Education
                 Office of Inspector General




Federal Student Aid’s Use of
Pandemic Assistance Student Aid
Administration Funds
August 1, 2023
ED-OIG/F21DC0081

ED OIG Oversight of Coronavirus Response Funds

FLASH REPORT
NOTICE
In accordance with Freedom of Information Act (Title 5, United States Code,
Section 552), reports that the Office of Inspector General issues are available to
members of the press and general public to the extent information they contain is not
subject to exemptions in the Act.
                           UNITED STATES DEPARTMENT OF EDUCATION
                                          OFFICE OF INSPECTOR GENERAL

                                                                                                                       Audit Services




August 1, 2023


TO:           Richard Cordray
              Chief Operating Officer
              Federal Student Aid

FROM:         Bryon Gordon /s/
              Assistant Inspector General for Audit

SUBJECT:      Final Flash Report, “Federal Student Aid’s Use of Pandemic Assistance Student Aid
              Administration Funds,” Control Number ED-OIG/F21DC0081

Attached is the subject final flash report that consolidates the results of our review of Federal Student
Aid’s use of pandemic assistance student aid administration funds. We have provided an electronic copy
to your audit liaison officer. We received your comments responding to our draft report.

We appreciate your cooperation during this review. If you have any questions, please contact Michele
Weaver-Dugan, Regional Inspector General for Audit, Internal Operations/Philadelphia Audit Team at
(202) 245-6941 or Michele.Weaver-Dugan@ed.gov.

Attachment




                                 400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510

                 Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
                Purpose
                The purpose of this flash report is to share with Federal Student Aid (FSA), a principal
                office of the U.S. Department of Education (Department), our observations of its use of
                student aid administration funds authorized by coronavirus response and relief laws.

                Background
                In response to the coronavirus pandemic, three major coronavirus response and relief
                laws were enacted in fiscal years 2020 and 2021: the Coronavirus Aid, Relief, and
                Economic Security Act (CARES Act), in March 2020; the Coronavirus Response and Relief
                Supplemental Appropriations Act, 2021 (CRRSAA), in December 2020; and the American
                Rescue Plan Act of 2021 (ARP), in March 2021. The pandemic relief legislation enabled
                FSA to provide various flexibilities to help students through the pandemic, which
                included the temporary suspension of nearly all Federal student loan payments,
                collections, and accrual of interest on most Federal student loans.

                To support its efforts in providing relief to student loan borrowers as a result of the
                coronavirus pandemic, FSA was provided with $161.1 million under these three major
                coronavirus response and relief laws to prevent, prepare for, and respond to
                coronavirus, domestically or internationally:

                •   The CARES Act provided FSA with $40 million in student administration funds with
                    funds remaining available through September 30, 2021.

                •   CRRSAA provided an additional $30 million in student administration funds with
                    funds remaining available through September 30, 2022.

                •   ARP provided an additional $91.1 million in student aid administration funds with
                    funds remaining available through September 30, 2023. 1

                Student aid administration funds are used to administer the Federal student financial
                assistance programs, authorized under Title IV of the Higher Education Act of 1965, as
                amended, which provide grants, loans, and Federal work study funds to help students
                and families pay for the cost of postsecondary education. The student aid
                administration account provides funding to administer the student aid lifecycle,
                including educating students and families about the process for obtaining Federal aid
                and repaying Federal student loans, processing student financial aid applications,




1
 On June 3, 2023, as a result of the enactment of the Fiscal Responsibility Act of 2023, unobligated
balances of ARP student aid administration funds were permanently rescinded.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                           1
                disbursing Direct Loan, Pell grant, and Federal work study funds, and managing the FSA
                loan portfolio.

                The Budget Group, located within the Finance Directorate of FSA and consisting of the
                Budget Formulation, Budget Execution, and Budget Operations Divisions, formulates
                and executes the FSA administrative budget, assists with the development of business
                unit budget initiatives, and supports business units in the management of FSA
                administrative funds for current year operations.

                According to FSA officials and staff, uses for the pandemic assistance student aid
                administration funds were identified based on the needs of FSA business units. Requests
                for funds were approved by the former chief operating officer, former deputy chief
                operating officer, and former chief financial officer prior to being allocated by the
                Budget Group for the CARES Act. 2 FSA updated how the funds would be used based on
                actual expenditures and when new announcements or extensions of the student loan
                repayment pauses were made by the Administration. For CRRSAA and ARP, the Business
                Operations Change Management Board, a group consisting of business unit
                representatives, identified FSA’s needs and developed requests to be sent to the FSA
                Finance Directorate. 3 The Finance Directorate then assessed the requests to determine
                whether the needs were pandemic-related and whether pandemic assistance student
                aid administration funds could be used to support those needs.


                What We Did
                The objective of our review was to determine FSA’s progress on spending student aid
                administration funds authorized by coronavirus response and relief laws, including how
                those funds have been used to date and FSA’s plans for using remaining funds.

                To accomplish our objective, we reviewed relevant laws, criteria, and guidance related
                to the use and tracking of pandemic assistance student aid administration funds. We
                held discussions with FSA staff to obtain an understanding of FSA’s budget process and
                oversight for pandemic assistance student aid administration funds. We also reviewed


2
  The FSA officials and staff we spoke with noted that they were not present when FSA identified what
areas to spend CARES Act student aid administration funds on, and that the individuals involved are no
longer with the Department. As a result, we were provided with their understanding of the process for
the CARES Act.
3
  The Finance Directorate supports FSA strategic objectives and ensures compliance with Federal
financial requirements. The Finance Directorate is comprised of the Financial Management Group,
Budget Group, and Financial Management Systems Group.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                         2
                  documents provided by FSA to determine how FSA has used or plans to use the
                  pandemic assistance student aid administration funds. In addition, we corresponded
                  with FSA staff from select business units that received pandemic assistance student aid
                  administration funding to obtain additional insight into the business units’ specific uses
                  of these funds.


                  What We Found
                  We found that as of November 30, 2022, FSA obligated 4 nearly 100 percent of the
                  $161.1 million in appropriations it received for pandemic assistance student aid
                  administration funds from the three major coronavirus response and relief laws. Nine
                  FSA business 5 units obligated approximately $157.8 million (98 percent) of the total
                  pandemic assistance student aid administration funds, with one business unit, the Next
                  Gen FSA Program Office, 6 accounting for 78 percent of the obligations.

                  The pandemic assistance student aid administration funds were used for personnel
                  compensation and benefits, information technology systems and services contracts, and
                  contractual services contracts. 7 As of November 30, 2022, FSA had approximately
                  $3.2 million remaining in unobligated ARP funds. As of April 4, 2023, specific plans for
                  how those funds will be used were still under development. 8




4
 An obligation is a legally binding agreement that will result in outlays (e.g., to pay for goods, products,
services), immediately or in the future.
5
 Since the enactment of the CARES Act, two of the nine business units have become legacy business
units due to a reorganization.
6
  The Department approved the creation of the Next Gen FSA Program Office in January 2020, which
was expected to sunset on or about September 30, 2022. It is responsible for the management of all
aspects of the Next Gen FSA program and will transition Next Gen FSA elements to permanent
organizational units within FSA as they become operational. The goal of the Next Gen FSA program or
initiative is to modernize FSA’s technology, processes, and operations to improve student, parent, and
borrower experiences and outcomes, as well as those of student aid partners.
7
    Contractual services contracts exclude advisory and assistance contracts.
8
 According to the Department’s Office of Budget Service, FSA had $2,085 (less than 1 percent) of its ARP
student aid administration funds permanently rescinded as a result of the Fiscal Responsibility Act of
2023.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                               3
                Progress on Spending Pandemic Assistance Student Aid
                Administration Funds
                We found that FSA obligated nearly 100 percent of its pandemic assistance student aid
                administration funds. As of November 30, 2022, of the $161.1 million in total pandemic
                assistance student aid administration funds appropriated, FSA obligated approximately
                $157.8 million (98 percent), committed 9 $171,000 (less than 1 percent), and allowed
                approximately $58,000 10 (less than 1 percent) to lapse.

                FSA obligated approximately 99.9 percent of the $40 million in CARES Act student aid
                administration funds it was appropriated prior to the funds expiring on September 30,
                2021. FSA was able to obligate the entire $30 million in CRRSAA student aid
                administration funds it was appropriated prior to the funding expiring on September 30,
                2022. As of November 30, 2022, FSA obligated approximately $87.9 million (96 percent)
                of its ARP student aid administration funds and had approximately $3.2 million in
                unobligated ARP funds. See Table 1.

                Table 1. Status of Pandemic Assistance Student Aid Administration Funds
                                                                           Unobligated
                                        Obligated Funds as Percentage of                  Percentage of
              Fund      Appropriation                                      Funds as of
                                           of 11/30/22     Appropriation                  Appropriation
                                                                            11/30/22

            CARES Act    $40,000,000       $39,942,082         99.9%          $57,918          0.1%

             CRRSAA      $30,000,000       $30,000,000          100%            $0              0%

               ARP       $91,130,000       $87,901,867          96%         $3,228,133          4%

              TOTAL      $161,130,000      $157,843,950         98%         $3,286,051          2%




9
 Committed funds are amounts that have been earmarked in anticipation of a legal obligation and are
not considered part of a fund’s available balance.
10
   According to FSA Budget staff, the lapsed funds resulted from what was left in personnel funds after
all pay for fiscal year 2020 was applied and any pay accruals were reversed, and the deobligation of a
requisition in fiscal year 2022 that was for borrower outreach related to return to student loan
repayment.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                          4
              Uses of Pandemic Assistance Student Aid Administration Funds
              We found that out of the approximately $157.8 million obligated in student aid
              administration funds as of November 30, 2022, nine FSA business units obligated
              approximately $11.0 million (7 percent) for personnel uses and $146.8 million
              (93 percent) for non-personnel uses.

              Specifically, of the $157.8 million obligated as of November 30, 2022, $124.5 million
              (79 percent) was for contractual services excluding advisory and assistance contracts,
              $22.3 million (14 percent) was for information technology systems and services
              contracts, $8.3 million (5 percent) was for personnel compensation, and $2.7 million
              (2 percent) was for personnel benefits.

              Out of the nine business units, five (56 percent) reported obligating funds for personnel
              compensation and benefits, three (33 percent) reported obligating funds for
              information technology systems and services contracts, and seven (78 percent) reported
              obligating funds for contractual services excluding advisory and assistance contracts.
              Contractual services excluding advisory and assistance contracts made up the largest
              amount of student aid administration funds. See the figure below for a breakdown of
              the number of business units and percentage of obligations reported by spending
              category.

              Figure. Funds Obligated Reported by Spending Category and Business Unit
                8                                                                                   90%
                7                                                                                   80%
                6                                                                                   70%
                5                                                                                   60%
                                                                                                    50%
                4
                                                                                                    40%
                3                                                                                   30%
                2                                                                                   20%
                1                                                                                   10%
                0                                                                                   0%
                       Personnel     Personnel Benefits       Information   Contractual Services
                     Compensation                         Technology Systems (Non-advisory and
                                                             and Services    assistance services)
                                                               Contracts

                           Number of Business Units Reporting           Percentage of Obligations



              Actual Uses of Funds
              To obtain additional insight into specific uses of student aid administration funds, we
              corresponded with executive officers from the five business units that reported using
              funds for personnel compensation and benefits. The five business units are the Office of
              Partner Participation and Oversight; the Office of Student Experience and Aid Delivery;



U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                          5
                the Strategic Communications Directorate; the Office of Strategy, Innovation, and
                Transformation; and the Office of Strategic Measures and Outcomes.

                We also reviewed a nonstatistical, judgmental sample consisting of the two business
                units that obligated the most student aid administration funds for non-personnel uses
                to determine how the funds were used. The two business units, the Next Gen FSA
                Program Office and Business Operations, 11 accounted for 96 percent of the non-
                personnel funds obligated as of November 30, 2022. See Appendix A.

                Personnel Costs
                Approximately $3.6 million (9 percent) of the CARES Act student aid administration
                funds and $7.4 million (25 percent) of the CRRSAA student aid administration funds
                were used to support a total of 87.1 full-time equivalents (FTE). 12 No ARP funding was
                used for personnel costs. The FTEs consisted of both temporary employees that were
                specifically hired to assist with coronavirus activities as well as permanent employees
                that were completing work related to coronavirus activities that had a portion of their
                pay charged to CRRSAA funds.

                Five business units accounted for 100 percent of the approximately $11.0 million in
                personnel costs obligated:

                    •   Office of Student Experience and Aid Delivery, $4.6 million obligation,
                        43.3 FTEs. FTEs consisted of 26 temporary employees and 22 permanent
                        employees. Personnel processed and adjudicated background investigations to
                        onboard contractor personnel who directly supported CARES Act activities,
                        assisted with communications campaigns related to the pandemic, identified
                        and handled customer complaints stemming from pandemic-related policies
                        and CARES Act relief, provided data analysis on CARES Act related servicing data,
                        worked with servicers to rectify issues and ensure servicers were in compliance
                        with contractual standards and requirements, and developed necessary
                        reporting mechanisms that will be used to monitor loan portfolio health and the
                        status of borrowers when return to repayment occurs.

                    •   Office of Partner Participation and Oversight, $5.4 million obligation,
                        37.9 FTEs. FTEs consisted of 17 temporary employees and 40 permanent



11
  Business Operations is one of the two FSA business units that no longer exists due to a reorganization
referenced in footnote 5. The other legacy business unit is the Technology Office.

 Our review covered a time period of more than 1 year; as a result, a single employee can equate to
12

more than one FTE.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                          6
                      employees. Personnel worked on policy guidance, inquiries, and development of
                      various pandemic waivers and relief; reviewed a backlog of audited financial
                      statement reviews resulting from delayed submissions by institutions of higher
                      education due to coronavirus related school closings; trained and supervised the
                      individuals reviewing the backlog of audited financial statement reviews;
                      provided support to schools and systems related to the implementation of
                      pandemic-related policies; and provided oversight and monitoring over
                      activities related to the CARES Act and other pandemic-related policies such as
                      the pause on collections, refund of interest, refund of payments, and transfer of
                      defaulted loans to the Department.

                  •   Strategic Communications Directorate, $490,000 obligation, 3.8 FTEs. FTEs
                      consisted of two temporary employees that supported transitioning aspects of
                      FSA’s enterprise governance to a virtual or digital footprint due to the
                      coronavirus pandemic and FSA’s transition to a geographically dispersed
                      workforce. Activities included developing mechanisms to centrally gather and
                      standardize a compilation of preparation documents and materials for senior
                      leaders and stakeholders, developing a virtual mechanism for FSA's Chief
                      Operating Officer to formally document decisions, and establishing a strategic
                      framework with metrics to gauge team effectiveness as the enterprise
                      governance structure transitioned to a virtual environment.
                  •   Office of Strategy, Innovation, and Transformation, $322,000 obligation,
                      1.6 FTEs. FTEs consisted of one temporary employee that assisted with data
                      efforts regarding the pandemic and its effect on students, borrowers, and the
                      Federal student loan portfolio.
                  •   Office of Strategic Measures and Outcomes, $174,000 obligation, 0.5 FTEs.
                      FTEs consisted of four permanent employees that completed work related to
                      coronavirus activities and had a portion of their pay charged to CRRSAA funds.
                      These individuals worked on internal and external data requests pertaining to
                      the CARES Act, the development of return to repayment reports and related
                      contingency planning and assessments, and the development of other periodic
                      pandemic-related reports.
              Based on our review, the 87.1 FTEs under the 5 business units worked on coronavirus
              activities.

              Non-Personnel Costs
              As of November 30, 2022, approximately $146.8 million in non-personnel pandemic
              assistance student aid funds was obligated: $36.3 million (91 percent) of CARES Act
              funds, $22.6 million (75 percent) of the CRRSAA funds, and $87.9 million (96 percent) of



U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                       7
               ARP funds. The funds were obligated across 29 contracts to 21 vendors, 12 of which
               were FSA loan servicers. 13

               The two business units accounted for 83 percent and 13 percent, respectively, of the
               non-personnel funds obligated as of November 30, 2022:

                   •   Next Gen FSA Program Office, $122.3 million obligation. Funds were used for
                       activities related to administrative forbearance, 14 loan forgiveness and
                       discharge, return to repayment, servicing system modifications, data reporting
                       related to the return to repayment, borrowers’ reinstatement of auto-debit
                       payment, temporary changes to the Income-Driven Repayment application,
                       borrower outreach, and information technology services.

                       Servicers used funds for e-correspondence, mailings, mandatory
                       communications regarding the end of the administrative forbearance, engaging
                       with at-risk borrowers, and other customer service capabilities. In addition,
                       funds were used to expand hours of operation for service call centers and add
                       additional customer service representatives to address significant increases to
                       contact center volume.

                       For these additional customer service representatives to be able to support
                       customers, funds were used to purchase data storage and software licenses for
                       the customer relationship management tool used to interact with customers.
                       Additional information technology purchases included web capacity expansion,
                       web traffic management, and an increase in FSA’s system processing capacity to
                       meet increased customer interaction volume related to debt relief.

                   •   Business Operations, $18.4 million obligation. Funds were used for a variety of
                       activities that supported FSA’s pandemic relief actions such as the temporary
                       suspension of nearly all Federal student loan payments, collections, and accrual
                       of interest on most Federal student loans. Activities included providing outreach
                       and communications to student loan borrowers and employers through
                       mailings, conducting a multi-channel communications campaign informing and
                       engaging borrowers on what steps to take once administrative forbearance



 One of the loan servicers terminated its Federal student loan servicing contract with FSA around
13

October 22, 2020.
14
  As used in this report, administrative forbearance refers to the pause on loan payments and 0 percent
interest rate that FSA automatically applied to eligible student loans starting March 13, 2020, in
response to the coronavirus pandemic.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                        8
                        ends, and purchasing licenses for digital engagement tools to assist in engaging
                        with borrowers who are currently in administrative forbearance. In addition,
                        funds were used to incorporate pandemic-related system enhancements and
                        updates to the Common Origination and Disbursement system and Debt
                        Management and Collections System. 15
                Based on our review, we determined that the Next Gen FSA Program Office and
                Business Operations obligations were used for coronavirus activities. 16

                Planned Uses of Funds
                As of November 30, 2022, FSA had approximately $3.2 million in unobligated ARP funds;
                approximately $2.7 million (83 percent) of those funds had not yet been allotted 17 to
                FSA, while $171,000 (5 percent) has been committed for non-personnel uses, and
                $393,000 (12 percent) is part of the ARP student aid administration fund’s available
                balance. 18 According to the former deputy chief financial officer of the Finance
                Directorate and acting director of the FSA Budget Group (former deputy chief financial
                officer and acting director), 19 FSA plans to obligate the remaining ARP funds in fiscal
                year 2023. The former deputy chief financial officer and acting director stated that they
                anticipate the funds will be used for student loan servicer activities and outreach and
                communication with student loan borrowers in relation to the return to student loan



15
  The Common Origination and Disbursement system is designed to support origination, disbursement,
and reporting for Direct Loan, Pell Grant, and the Teacher Education Assistance for College and Higher
Education Grant programs. The Debt Management and Collections System houses all FSA held defaulted
debt. The system tracks all debts, interest accruals, and payments at the loan level; can associate all
loans to a specific borrower; and sends out bills and correspondence as needed.
16
  Based on the information we were provided by FSA, we were unable to determine whether five Next
Gen FSA Program Office requisition line items, accounting for approximately $186,700, were pandemic-
related. We considered this amount to be insignificant as it accounted for less than 1 percent of the
Next Gen FSA Program Office non-personnel obligations.
17
  An allotment is an authorization by either the agency head or another authorized employee to their
subordinates to incur obligations within a specified amount. The amount allotted by an agency cannot
exceed the amount apportioned by the Office of Management and Budget.
18
  An available balance is the total amount of allotted funding still available for spending minus
commitments and obligations.
19
  The former deputy chief financial officer of the Finance Directorate and acting director of the FSA
Budget Group left their position with FSA in May 2023, after the completion of our fieldwork.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                           9
                  repayment. The former deputy chief financial officer and acting director stated that the
                  chief operating officer and FSA finance director will have the final approval on all
                  spending decisions.

                  As of April 4, 2023, specific plans for how those funds will be used were still under
                  development. 20

                  FSA’s Oversight of Pandemic Assistance Student Aid
                  Administration Funds
                  According to FSA officials, the Budget Group routinely monitors the status of student aid
                  administration funds for the coronavirus response and relief laws. The former deputy
                  chief financial officer and acting director stated that as part of its oversight, the Budget
                  Group runs periodic reports to determine the available balance of the student aid
                  administration funds to be obligated for future contracts or services and to check
                  emerging requests for the funds. The director of the Budget Execution Division clarified
                  that the Education Central Automated Processing System (EDCAPS) status of funds
                  reports 21 are run several times a week and COGNOS reports 22 are run daily. The former
                  deputy chief financial officer and acting director commented that these reports help
                  determine the actual expenditures and the remaining student aid administration funds,
                  and that the data gathered from the reports is used to communicate with the business
                  units about how they plan to use remaining funds before they expire. As the funding
                  period approaches its expiration, the Budget Group looks at how the funds have been
                  spent and whether they can repurpose funds for other needs. The acting chief financial
                  officer of FSA also noted that the team meets with the chief operating officer weekly to
                  discuss the available fund balances, the expected uses of the funds, and the timeframes
                  for the uses of the available funds.




20
     See footnote 8.
21
   EDCAPS is the Department’s core financial system. EDCAPS status of funds reports provide a higher-
level view of the pandemic assistance student aid administration funds appropriated, including
allotments, calculated budget amounts, fund commitments, paid and unpaid obligations, and available
funds.
22
  The COGNOS application is the Department's reporting solution for financial systems that may be used
for reporting from the EDCAPS systems. COGNOS reports reflect the general ledger and list
commitments that have been obligated, paid and unpaid obligations, and the FSA business units that
obligated the funds.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                           10
              FSA Comments
              We provided a draft of this report to FSA for comment. FSA stated that prior to the
              enactment of the Fiscal Responsibility Act of 2023 it had plans in place to use the
              remaining ARP funds to support the end of the pandemic-related pause in repayments.
              The full text of FSA’s response is included at the end of the report.


              Scope and Methodology
              We reviewed the laws, criteria, and guidance related to the use and tracking of student
              aid administration funds, including Office of Management and Budget guidance on
              tracking and accounting for disaster and emergency funding and Department-provided
              guidance on its account classification structure. We held discussions with FSA staff to
              obtain an understanding of FSA’s budget process and oversight for pandemic assistance
              student aid administration funds. In addition, we reviewed reports provided by FSA
              detailing the status of the student aid administration funds and how the funds have
              been spent, as well as internal documents FSA used to track employees that were
              associated with coronavirus activities.

              To obtain additional insight into specific uses of student aid administration funds and
              whether the activities were related to the coronavirus pandemic, we corresponded with
              executive officers from the five FSA business units that reported using funds for
              personnel compensation and benefits. We also selected a nonstatistical, judgmental
              sample consisting of the two FSA business units that obligated the most pandemic
              assistance student aid administration funds for non-personnel uses to determine how
              the funds were used.

              We performed the work for this review from September 2022 through May 2023.

              Sampling Methodology
              We identified a population of business units that obligated pandemic assistance student
              aid administration funds for non-personnel uses from COGNOS reports provided by FSA.
              From this population, we selected a nonstatistical, judgmental sample consisting of the
              two business units that had the most obligations for non-personnel uses of the
              pandemic assistance student aid administration funding.

              Since we selected these business units judgmentally, results described in this report may
              not be representative of the population and should not be projected.

              Use of Computer-Processed Data
              Use of computer-processed data was limited to identifying the obligated and
              unobligated amounts of student aid administration funds under the CARES Act, CRRSAA,


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                    11
               and ARP, and how the funds were used. We obtained copies of financial budget
               execution documents from FSA including EDCAPS status of funds reports and COGNOS
               reports of commitments that have been obligated.

               To assess the reliability of the data, we compared the data to supporting documentation
               we received as part of our review. For the two business units that obligated the most
               student aid administration funds for non-personnel uses, we compared the descriptions
               and obligated amounts in the COGNOS reports to the requisition files. For the five
               business units that obligated funds for personnel compensation and benefits, we
               compared data to supporting documentation such as CARES Act and CRRSAA benefit
               trackers that we received from the FSA Budget Group and the business units. In
               addition, we concluded that the data contained in the EDCAPS reports was sufficiently
               reliable as EDCAPS is the Department’s core financial system and provides funds
               management functions including budget formulation, budget execution, and funds
               control.

               To verify the completeness of the data, we reconciled the amount of obligated and
               unobligated funds in the EDCAPS status of funds reports with Department of Treasury
               appropriation warrants for the CARES Act, CRRSAA, and ARP, and found that they
               accounted for the total amount of student aid administration funds FSA received under
               the coronavirus response and relief laws. 23 We also verified the completeness of the
               COGNOS reports by comparing the total obligations with the obligated amounts listed in
               the EDCAPS status of funds reports. While we identified some differences, we
               determined that they were immaterial and did not affect the overall findings of our
               review.

               As a result, we determined that the computer-processed data provided by FSA was
               reliable for the purposes of our review.

               Compliance with Standards
               We prepared this flash report in alignment with OIG’s quality control standards and the
               Council of Inspectors General for Integrity and Efficiency’s (CIGIE) “Quality Standards for
               Federal Offices of Inspector General,” which require that we conduct our work with
               integrity, objectivity, and independence. We believe that the information obtained
               provides a reasonable basis for the conclusions contained in this report.




23
  The EDCAPS status of funds reports reconciled to the Department of Treasury appropriation warrants
after accounting for the unallotted ARP funds that were not reflected on the EDCAPS report as of
November 30, 2022.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                       12
                   Appendix A. Pandemic Assistance Student Aid
                     Administration Obligations by Business Unit
                   Table 2. Distribution of Personnel and Non-personnel Obligations by FSA Business
                   Unit 24
                   (Dollar amounts are rounded to the nearest whole dollar and percentages are rounded to the nearest whole percentage.)

                                                     Percentage of                          Percentage of
                                    Personnel                           Non-personnel                                               Percentage of
           Business Unit                               Personnel                            Non-personnel      Total Obligations
                                    Obligations                          Obligations                                               Obligated Funds
                                                      Obligations                            Obligations


        Next Gen FSA Program
                                         $0                0%            $122,324,910             83%             $122,324,910             78%
               Office


         Business Operations             $0                0%             $18,437,956             13%              $18,437,956             12%

          Office of Student
         Experience and Aid          $4,633,685            42%            $1,883,797               1%              $6,517,482              4%
               Delivery

          Office of Partner
          Participation and          $5,379,880            49%             $619,301               <1%              $5,999,181              4%
              Oversight

        Enterprise Technology
                                         $0                0%             $3,375,871               2%              $3,375,871              2%
             Directorate


             Strategic
          Communications              $489,793             4%                  $0                  0%               $489,793               <1%
            Directorate


          Office of Strategy,
           Innovation, and            $322,200             3%               $45,282               <1%               $367,482               <1%
           Transformation



         Office of Strategic
                                      $174,187             2%                  $0                  0%               $174,187               <1%
       Measures and Outcomes


          Technology Office              $0                0%              $101,885               <1%               $101,885               <1%


                TOTAL                $10,999,746          100%           $146,789,002             100%            $157,788,748              -




24
  Information provided in Table 2 was compiled from COGNOS reports since business unit level
information is not available in EDCAPS status of funds reports. The total obligations calculated from the
COGNOS reports differed from the total obligations calculated from the EDCAPS reports as reflected in
Table 1. However, we determined that the differences were immaterial and that they did not affect the
overall findings of our review.


U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                                                                    13
              Appendix B. Acronyms and Abbreviations
               ARP             American Rescue Plan Act of 2021

               CARES Act       Coronavirus Aid, Relief, and Economic Security Act

               CRRSAA          Coronavirus Response and Relief Supplemental Appropriations
                               Act, 2021

               Department      U.S. Department of Education

               EDCAPS          Education Central Automated Processing System

               FSA             Federal Student Aid

               FTE             full-time equivalent




U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                                                                        14
              FSA Comments




                               (b) (6)




U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081                         15
U.S. Department of Education
Office of Inspector General
ED-OIG/F21DC0081               16


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