FSA’s Implementation of the FUTURE Act and FAFSA Simplification Act’s Federal Taxpayer Information Provisions through the Student Aid and Borrower Eligibility Reform Initiative

The objective of our audit was to determine whether FSA was effectively implementing the Fostering Undergraduate Talent by Unlocking Resources for Education (FUTURE) Act and the FAFSA Simplification Act provisions pertaining to Federal Tax Information (FTI) through the Student Aid and Borrower Eligibility Reform Initiative (SABER) initiative. Our audit covered December 19, 2019 (when the FUTURE Act was enacted) through May 31, 2023. We found that FSA did not effectively implement the FUTURE Act and the FAFSA Simplification Act provisions pertaining to FTI through the SABER initiative. Overall, FSA did not effectively perform implementation activities for the four FTI-related SABER systems that we reviewed in accordance with some of the processes for monitoring project costs and budgets, monitoring contracts, and managing risks that FSA established as part of an effective systems implementation framework because it did not always perform key steps or could not provide sufficient evidence to support completion of such key steps. Specifically, these key steps pertained to FSA’s establishing and monitoring of the systems’ costs and budgets, its performance oversight of the contractors responsible for implementing the systems, and its management of the risks, decisions, and issues pertaining to the systems’ implementation. For the Internal Revenue System (IRS) Publication 1075 “Tax Information Security Guidelines for Federal, State, and Local Agencies” security requirements that the IRS required FSA to implement prior to allowing the transfer of FTI to FSA systems, we found that FSA established and followed a plan to ensure that the security requirements were implemented. Additionally, we found that FSA adhered to its change management process for two FTI systems for which we tested a sample of one contract modification for each.