NASFAA Submits FSA Survey Results to Congress

On November 18, 2015, NASFAA President Justin Draeger provided testimony at a joint hearing of the House Committee on Education and the Workforce and House Committee on Oversight and Government Reform. Reported by NASFAA. The hearing explored the effectiveness of the Department of Education’s Federal Student Aid (FSA) operations as a performance-based organization (PBO). Following the hearing, the House in March 2016 asked NASFAA to provide additional information about institutions’ experiences with FSA. Based on information collected from a survey distributed to NASFAA’s membership, NASFAA staff submitted a report to the House on May 10 offering recommendations to help facilitate a strong, effective working relationship between schools and FSA.

The survey asked about waiting times for Department of Education (ED) approvals of various changes to institutional operations, or for final reports from a program review or federal audit, or for guidance. The survey also asked for areas in which ED provides a high level of accurate, timely service. Of the 2,718 institutional members sent the survey, 789 (29 percent) responded. When categorized by sector, responses reflected approximately the same distribution as seen in the NASFAA membership.

The report observes that in recent years, the relationship between schools and FSA has been strained with the increased growth in regulatory and operational burdens placed on schools and an increase in oversight activity by FSA, all of which leave schools feeling less like partners and more like adversaries.

NASFAA members report significant enough delays in FSA processing to raise concern that the partnership between the federal government and institutions is eroding. Comments gathered by the survey from NASFAA members indicate that schools feel silenced and even intimidated by these delays for fear of reprisal from FSA if they inquire or complain too often or too loudly. The report concludes that long processing timeframes represent a serious operational shortfall with FSA.

A significant number of institutions reported extended processing times for things as simple as program participation agreement (PPA) changes or, even more seriously, program review closeouts. For example, of 292 respondents that had a program review, 15 percent either received a final report within 3 months or just had the review completed within the past 3 months and are still waiting for the report. Ten percent of respondents have been waiting more than 18 months to receive their final report. The report points out that delays of such magnitude can exacerbate the penalties for disputed compliance interpretations and impact more students.

Approval of PPA renewals, processing of PPA changes that require ED notification only before disbursement, and receipt of policy or procedural guidance have the highest percentage of long-term processing times. Time needed for approval of new programs and for renewal of Program Participation Agreements were cited most often as having a negative impact on office operations (19 percent and 15 percent, respectively), and on serving students (23 percent and 13 percent).

The report notes that NASFAA has not found any public mention of processing targets of any kind for FSA operations. Lack of acknowledged targets raises serious concerns about a PBO’s ability to partner with institutions, and about oversight of its operations and service.

Despite these shortfalls, the survey revealed that many respondents feel FSA is excelling with their annual conference, electronic services for schools, electronic services for students, written policy guidance (although some respondents requested that the handbook be changed from PDF into a more web friendly format), and services from FSA regional trainers. Open-ended comments praised the amount of information offered through the sessions at the annual FSA conference, and commended regional trainers for their devotion to attending state and regional conferences and providing accurate and timely responses. In addition, many respondents spoke highly of the COD and CPS systems, expressing praise for them being well-maintained.

Both in response to the survey data and in the spirit of desiring to improve the partnership between FSA and schools, NASFAA offers the following five recommendations in the report:

Establish targets for processing PPA changes and academic program approvals, and for closing out program reviews.
Establish basic, measurable customer service goals.
Formally establish school operational feedback groups
Establish standard procedures for stakeholder consultation.
Congress should consider redefining the scope of FSA.
The report concludes with the hope that NASFAA and ED can work together to ensure the findings may help to facilitate a stronger partnership in the future.