Federal Student Aid’s Oversight of Schools Participating in the Title IV Programs

We found significant weaknesses in the processes for performing program reviews. We also found a weakness in selecting schools for program reviews. Program review specialists did not always conduct program reviews in accordance with FSA’s program review procedures. Specifically, required forms and documents were missing from the program review files, and staff did not always complete forms, adequately document fiscal testing for timely disbursement of funds and excess cash, determine whether schools had implemented Direct Loan quality assurance systems, and conduct distance education program reviews. We also found limited evidence of supervisory review of the program review files to ensure program review procedures are adequately completed. Further, the time allotted to perform program reviews may not have been adequate. Program Compliance division managers did not consider high annual dropout rates when prioritizing schools for program reviews as required by the HEA. As a result of the significant internal weaknesses we found, FSA has limited assurance that program reviews are appropriately identifying and reporting all instances of noncompliance.