Department of Education: Status of Efforts to Address Major Management Challenges

Published by the Government Accountability Office on 2003-06-10.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                          United States General Accounting Office

GAO                       Testimony
                          Before the Subcommittee on Government
                          Efficiency and Financial Management,
                          Committee on Government Reform,
                          House of Representatives
For Release on Delivery
Expected at 2 p.m., EST
Tuesday, June 10, 2003    DEPARTMENT OF
                          Status of Efforts to
                          Address Major
                          Management Challenges
                          Statement of Linda Calbom
                          Director, Financial Management and Assurance

                                                June 10, 2003

                                                DEPARTMENT OF EDUCATION

                                                Status of Efforts to Address Major
Highlights of GAO-03-872T, a testimony          Management Challenges
before the Subcommittee on Government
Efficiency and Financial Management,
Committee on Government Reform,
House of Representatives

In its 2003 performance and                     Education has taken steps to address its continuing challenges of reducing
accountability report on the                    vulnerabilities in its student aid programs and improving its financial
Department of Education, GAO                    management, such as establishing a senior management team to address
identified challenges in, among                 management problems, including financial management, throughout the
other areas, student financial aid              agency. And, while Education has made significant progress, weaknesses
programs and financial
management. The information
                                                remain that will require the continued commitment and vigilance of
GAO presents in this testimony is               Education’s management to resolve.
intended to assist Congress in
assessing Education’s progress in               •      Reduce vulnerability of student aid programs to fraud, waste,
addressing and overcoming these                        abuse, and mismanagement. Education has made considerable
challenges.                                            changes to address the ongoing challenges in administering its student
                                                       aid programs. However, Education needs to continue to address
                                                       systems integration issues, reduce fraud and error in student aid
                                                       application and disbursement processes, collect on student loan
GAO is not making new                                  defaults, and improve its human capital management.
recommendations in this
testimony, but past reports have
made specific recommendations                   •      Improve financial management. Education has implemented many
aimed at addressing some of these                      actions to address its financial management weaknesses. Significant
major management challenges.                           progress was made earlier this year when Education received an
                                                       unqualified—or “clean”—opinion on its financial statements for fiscal
                                                       year 2002. While this is an important milestone for the department,
                                                       internal control and systems weaknesses remain that impede
                                                       Education’s ability to produce timely, accurate, and useful financial
                                                       information for its managers and stakeholders.

                                                History of Financial Management Weaknesses

                                                    Fiscal                                Material internal control   Noncompliance with federal
                                                                                      a                                                    b
                                                    year          Audit opinion           weaknesses                  systems requirements
                                                    1995          Disclaimer              Yes                         N/A
                                                    1996          Disclaimer              Yes                         N/A
                                                    1997          Unqualified             Yes                         Yes
                                                    1998          Disclaimer              Yes                         Yes
                                                    1999          Qualified               Yes                         Yes
                                                    2000          Qualified               Yes                         Yes
                                                    2001          Qualified               Yes                         Yes
                                                    2002          Unqualified             Yes                         Yes
                                                Source: Auditors’ reports for fiscal years 1995-2002.
                                                Auditors issue unqualified opinions when the financial statements are presented fairly, in all
                                                material respects. Qualified opinions are issued when the financial statements are presented fairly,
                                                with exceptions that are specifically disclosed and described. Disclaimers of opinion are rendered
                                                when auditors cannot satisfy themselves as to whether the financial statements are presented fairly.
www.gao.gov/cgi-bin/getrpt?GAO-03-872T.         b
                                                These requirements became effective for fiscal year 1997.
To view the full testimony, click on the link
above. For more information, contact Linda
Calbom at (202) 512-9508 or
                       Mr. Chairman and Members of the Subcommittee:

                       I am pleased to be here today to discuss the major management challenges
                       faced by the Department of Education, its progress in addressing them,
                       and challenges that remain.

                       As you know, this January, we issued our Performance and Accountability
                       Series on management challenges and program risks at major agencies,
                       including the Department of Education.1 The report for Education focused
                       on a number of management challenges and continued the high risk
                       designation for student aid programs. You asked me to focus my testimony
                       on two areas in that report. These are Education’s efforts to (1) reduce
                       fraud, waste, abuse, and mismanagement in its student aid programs while
                       continuing to ensure access to postsecondary education and (2) improve
                       its financial management to help build a high-performing agency.
                       Education has taken steps to meet these challenges, such as establishing a
                       senior management team to address management problems, including
                       financial management, throughout the agency. And, while Education has
                       made significant progress, including receiving a clean opinion on its fiscal
                       year 2002 financial statements, weaknesses remain that will require the
                       continued commitment and vigilance of Education’s management to
                       resolve. I will discuss Education’s student aid programs and financial
                       management in turn.

                       Ensuring access to postsecondary education while reducing vulnerability
Student Aid Programs   of student financial aid programs to fraud, waste, abuse, and
                       mismanagement is one of the key management challenges Education
                       faces. Education helps millions of students enroll in higher education
                       programs by providing for more than $50 billion in grants and loans
                       annually. The department is responsible for ensuring that these programs
                       are efficiently managed, establishing procedures to ensure that loans are
                       repaid, and preventing fraud and abuse. Since 1990, we have identified
                       Education’s grant and loan programs as high risk for fraud, waste, abuse,
                       and mismanagement.

                       Both Education and Congress have made changes to address management
                       challenges in the student financial aid programs. Congress established

                       U.S. General Accounting Office, Major Management Challenges and Program Risks:
                       Department of Education, GAO-03-99 (Washington, D.C.: January 2003).

                       Page 1                                                                GAO-03-872T
Education’s Office of Federal Student Aid (FSA) as a performance-based
organization in 1998. Its purpose is to increase accountability of officials,
provide greater flexibility in management, integrate information systems,
reduce costs, and develop and maintain a system that contains complete,
accurate and timely data that can ensure program integrity. In 2001,
Education established a Management Improvement Team (MIT) of senior
managers to formulate strategies to address key management problems
throughout the department. According to Education, MIT has developed a
system to identify, track, and resolve audit and management issues both
agencywide and in the student financial aid programs.

Education has faced challenges in four areas related to its grant and loan
programs. These are (1) financial aid system integration issues, (2) fraud
and error in student aid application and disbursement processes,
(3) defaulted student loans, and (4) human capital management. I would
now like to briefly discuss each of these challenges.

Education has spent millions of dollars to integrate and modernize its
many financial aid systems in an effort to provide more information and
better service to students, parents, institutions, and lenders. Effectively
and efficiently investing in information technology requires, among other
things, an institutional blueprint that defines in both business and
technical terms the organization’s current and target operating
environments and provides a transition road map. Because Education did
not have this blueprint, commonly called an enterprise architecture, we
recommended in 1997 that the department develop an architecture and
establish standard reporting formats and data definitions.2 In September
2002, Education’s Office of the Inspector General (OIG) reported that the
department had made progress in taking specific actions to lay the
groundwork for an enterprise architecture. Still, critical elements need to
be completed, including integrating separate architectures into a
departmentwide architecture and fully implementing common identifiers
for students and institutions to use in departmentwide system
applications. As part of our review of the progress federal agencies have
made to effectively develop, implement, and maintain their enterprise
architectures, we are currently evaluating the management of Education’s
enterprise architecture efforts.

 U.S. General Accounting Office, Student Financial Aid Information: Systems
Architecture Needed to Improve Programs’ Efficiency, AIMD-97-122 (Washington, D.C.:
July 29, 1997).

Page 2                                                                  GAO-03-872T
With respect to modernization plans, we reported in November 2001 that
FSA selected a viable, industry-accepted means of integrating its existing
data on student loans and grants.3 FSA has made progress in implementing
this approach for its Common Origination and Disbursement process,
which includes the implementation of a common record that institutions
can use to submit student financial aid data for Pell Grant and Direct Loan
programs. The ultimate success of this process, however, hinges on
addressing serious postimplementation operational problems and helping
thousands of schools implement the common record. Further, as we
reported in December 2002,4 FSA has not completed a number of elements
that are important for managing any information technology investment.
These include determining whether expected benefits are being achieved
and tracking lessons learned related to schools’ implementation of the
common record. We have recommended that FSA develop metrics,
baseline data, and a tracking process for certain benefits expected from
the system, and that it develop and implement a process for capturing and
disseminating lessons learned to schools that have not yet implemented
the common record. FSA has begun acting on both of these issues.

Education has also faced challenges in ensuring that information reported
on student aid applications is correct and that adequate internal controls
are in place to prevent improper payments of grants and loans. The
department has taken steps, in two pilot programs with the Internal
Revenue Service (IRS), to match income reported on student aid
applications with federal tax returns.5 To continue this income match and
implement it on a broader scale, legislation to allow IRS to release the
information is necessary. Education has worked with the Department of
the Treasury and the Office of Management and Budget to ask that
Congress enact such legislation. The department also verifies income
information by asking 30 percent of applicants to provide copies of their
tax returns to their student financial aid offices. In addition to
strengthening its controls over student aid applications, we found that
Education also needed to address institutions that were disbursing grants

 U.S. General Accounting Office, Student Financial Aid: Use of Middleware for Systems
Integration Holds Promise, GAO-02-7 (Washington, D.C.: Nov. 30, 2001).
 U.S. General Accounting Office, Federal Student Aid: Progress in Integrating Pell Grant
and Direct Loan Systems and Processes, but Critical Work Remains, GAO-03-241
(Washington, D.C.: Dec. 31, 2002).
U.S. General Accounting Office, Major Management Challenges and Program Risks:
Department of Education, GAO-01-245 (Washington, D.C.: Jan. 2001).

Page 3                                                                     GAO-03-872T
to ineligible students.6 The department has taken steps to analyze student
data to identify high concentrations of students over age 65 and eligible
noncitizens at individual institutions to determine whether problems exist
that warrant further review. These actions are encouraging, and if properly
implemented, should improve controls over these payments.

A continuing challenge for Education and FSA is preventing and collecting
defaulted student loans. While the national student loan default rate has
decreased from 11.6 percent in fiscal year 1993 to 5.9 percent in fiscal year
2000, the cumulative amount of defaulted student loans has increased by
almost $10 billion over the same period. Education and FSA have
implemented several default management strategies, such as establishing
electronic debiting as a repayment option, and working with some
guaranty agencies to set up alternatives to service and process claims for
defaulted loans. Our analysis of FSA’s internal documents indicated that
for fiscal years 2000 through 2002, FSA met or exceeded many of the goals
related to these strategies. However, neither Congress nor the public can
determine whether FSA’s default management goals have been met
because Education did not prepare performance reports that conform to
the requirements in the Higher Education Act.7 FSA’s report to Congress
on its performance in fiscal years 2000 and 2001 was not timely nor did it
indicate whether FSA met established performance goals. We have
recommended that Education and FSA prepare and issue reports to
Congress on FSA’s performance that are timely and clearly identify
whether performance goals were met.8

Like other federal agencies, Education must address serious human
capital issues, such as succession planning, because about one-third of
Education’s workforce is eligible to retire. In June 2001, we recommended
that the department develop human capital goals and measures for its

 U.S. General Accounting Office, Education Financial Management: Weak Internal
Controls Led to Instances of Fraud and Other Improper Payments, GAO-02-406
(Washington, D.C.: Mar. 28, 2002).
 The requirements are in the amendments to the Higher Education Act that established FSA
as a performance-based organization. Pub. L. No. 105-244, Title I, § 101(a), 112 Stat. 1581,
1604-1610 (1998).
U.S. General Accounting Office, Federal Student Aid: Timely Performance Plans and
Reports Would Help Guide and Assess Achievement of Default Management Goals,
GAO-03-348 (Washington, D.C.: Feb. 14, 2003).

Page 4                                                                       GAO-03-872T
             performance plans.9 In April 2002, we recommended that the department
             and FSA coordinate closely to develop and implement a comprehensive
             human capital strategy.10 Education added a specific objective to its
             strategic plan, and in 2002, issued a comprehensive 5-year human capital
             plan that incorporates FSA. This plan outlines steps and time frames for
             improving human capital management and specifies four critical areas
             where improvements should be made: (1) top leadership commitment,
             (2) performance management, (3) workforce skills enhancement, and
             (4) leadership and succession planning. It will be important that Education
             focus continually on implementation of the plan to achieve results.

             Now, Mr. Chairman, I would like to discuss Education’s financial
             management challenges and the progress Education has made in
             addressing them.

             Weaknesses in Education’s financial management and information
Financial    systems have limited its ability to achieve one of its key goals—improving
Management   financial management to help build a high-performing agency. Significant
             progress towards this goal was made earlier this year when Education
             received an unqualified—or “clean”—opinion on its financial statements.
             Prior to this, with the exception of 1997, Education had not received a
             clean opinion since its first agencywide audit in 1995. While this is an
             important milestone for the department, significant management
             weaknesses remain that must be addressed for Education to meet its goal
             in this area.

             Beginning with the department’s first agencywide audit in 1995,
             Education’s auditors have repeatedly identified significant financial
             management weaknesses. These weaknesses included Education’s
             inability to provide the auditors with sufficient evidence to satisfy
             themselves about the accuracy or completeness of certain amounts
             included in the financial statements, including billions of dollars of
             adjustments to amounts reported in previous years’ financial statements.

              U.S. General Accounting Office, Department of Education: Status of Achieving Key
             Outcomes and Addressing Major Management Challenges, GAO-01-827 (Washington, D.C.:
             June 29, 2001).
              U.S. General Accounting Office, Federal Student Aid: Additional Management
             Improvements Would Clarify Strategic Direction and Enhance Accountability,
             GAO-02-255 (Washington, D.C.: April 30, 2002).

             Page 5                                                                 GAO-03-872T
    According to Education’s auditor, these adjustments were to correct
    “unnatural account balances” or otherwise adjust balances to the amount
    management’s analysis supported. The auditor reported that in many
    cases, the cause of the incorrect balances could not be definitively
    determined, and the adjusting entry prepared by management was a
    reasoned judgment of how to correct its accounts. Education’s auditors
    have also consistently reported major internal control weaknesses related
    to financial management systems and financial reporting. These
    weaknesses included (1) the absence of a fully integrated financial
    management system, (2) deficiencies in financial management practices
    that require extensive analysis of accounts to resolve errors through
    manual adjustments, (3) the lack of a rigorous review of interim financial
    data for timely identification and correction of errors, (4) the inability to
    accumulate, analyze, and present reliable financial information in the form
    of financial statements, (5) the dependence on a variety of stopgap
    measures to prepare financial statements, (6) the insufficiency of
    compensating controls, such as top-level reviews to address and try to
    compensate for systemic control weaknesses, and (7) the lack of a review
    to identify and quantify improper payments. Education’s auditors also
    reported that internal controls needed strengthening in numerous areas
    relating to Education’s investment of millions of dollars in property and

    Education has taken actions over the last several years to improve its
    financial management and to address the weaknesses identified. For
    example, during 2001, Education’s MIT developed specific actions to
    address issues raised in previous financial statement audits. According to
    a MIT report on its accomplishments, Education began performing certain
    critical reconciliations monthly and began preparing interim financial
    statements, which helped identify areas needing further study. Education
    also improved its internal controls over property and equipment, and its
    auditor did not report this area as a weakness in fiscal year 2002. In
    addition, according to Education’s auditor, during fiscal year 2002, the
    department implemented a new general ledger software package and FSA
    implemented a new financial management system to support management
    information reporting needs. The auditor also reported that the
    department implemented several processes during fiscal year 2002 to
    improve its financial management, including

•   convening the Accounting Integrity Board, the Audit Steering Committee,
    and the Accounting Assurance Group to plan, implement and manage
    quality accounting change control;

    Page 6                                                           GAO-03-872T
•   establishing the Financial Statement Committee and continuing the
    Financial Statement Preparation Team and other special task force teams
    all of which are designed to improve the financial statement processes;
•   developing and implementing reconciliation work plans, policies, and
    procedures; specialized teams; regular management reviews of the final
    work products; and management review for process improvement.

    While Education has made progress in addressing many of its weaknesses,
    in fiscal year 2002, the auditor again reported that significant financial
    management issues continued to impair the department’s ability to
    accumulate, analyze, and present reliable financial information. These
    problems, in part, resulted from inadequate internal controls over
    Education’s financial management systems and financial reporting
    process. The auditor also reported that weaknesses in the department’s
    ability to report accurate financial information on a timely basis were due
    to deficiencies in certain of the department’s financial management
    practices, including inadequate reconciliations and account analysis early
    in fiscal year 2002. The auditor added that issues associated with the
    transition to a new financial management system in fiscal year 2002 also
    contributed to the department’s difficulties in these areas. While the
    auditor reported that it noted improvements in the latter part of the fiscal
    year, it reported that it continues to believe that the department needs to
    focus more on reconciliation procedures, account analysis, and financial
    reporting. Until these issues are fully resolved, Education’s ability to
    produce timely, accurate, and useful financial information for its managers
    and stakeholders will be greatly impeded. In addition, beginning with
    fiscal year 2004, Education and other major government agencies will be
    required to produce audited financial statements within 45 days after the
    end of the fiscal year compared to 120 days for fiscal years 2002 and 2003.
    According to Education’s Fiscal Year 2004 Annual Plan, the department
    plans to implement this accelerated reporting date for its fiscal year 2003
    financial statements—a year earlier than required. This action will be a
    good “test” of Education’s new financial system and other financial
    management reforms.

    As we testified before the Subcommittee on Select Education in April
    2002, we identified other internal control weaknesses that make Education

    Page 7                                                          GAO-03-872T
vulnerable to improper payments and lost assets.11 In our testimony and
related report, 12 we stated that for May 1998 through September 2000,
weak internal controls over the (1) grants and loan disbursement process
failed to detect certain improper payments, (2) third party draft processes
increased Education’s vulnerability to improper payments, and
(3) government purchase cards resulted in some fraudulent, improper, and
questionable purchases. We also reported that Education lacked adequate
internal controls over computers acquired with purchase cards and third
party drafts. Among other things, we found that computer purchases
valued at almost $400,000 were not recorded in Education’s property
records, and $200,000 of that computer equipment could not be located.

In response to our work, Education made several changes to its policies
and procedures to improve internal controls and program integrity. These
changes were a step in the right direction; but in many cases, our follow-
up work indicated that they had not been effectively implemented. In
March 2002, we reported that vulnerabilities remained in all areas we
reviewed, except for third party drafts, which were discontinued
altogether.13 For example, we reported that Education developed a new
approval process for its purchase card program; however, our testing of
3 months of purchase card statements under the new process found that
over 20 percent lacked proper support for the items purchased. In October
2002, Education told us that new policies and procedures were
implemented and aimed at reducing the department’s vulnerability to
future improper use of purchase cards. These new policies and procedures
relate to reviewing and approving purchase card transactions and
providing related training. Further, the department told us that misuse of
purchase and travel cards is now specifically included in the department’s
Table of Penalties with the desired effect of reducing misuse and abuse of
government issued credit cards. Education also told us that it recognizes
that reviewing and improving internal controls is an ongoing task and that
it intends to remain vigilant in this area. These are positive steps that
should help reduce the instances of improper purchases.

 U.S. General Accounting Office, Education Financial Management: Weak Internal
Controls Led to Instances of Fraud and Other Improper Payments, GAO-02-513T
(Washington, D.C.: Apr. 10, 2002).
 GAO-02-406, 30.

Page 8                                                                 GAO-03-872T
Finally, Education will need to continue its actions in addressing
weaknesses in its financial management information systems. The Federal
Financial Management Improvement Act (FFMIA) of 1996 requires
agencies to institute financial management systems that substantially
comply with federal financial management systems requirements,
applicable accounting standards, and the U.S. Government Standard
General Ledger. Every year since FFMIA was enacted, Education’s
auditors have reported that Education’s systems did not substantially
comply with the act’s requirements. In previous years, the auditors
reported that without a fully integrated financial management system,
deficiencies in the general ledger system, deficiencies in the manual
adjustment process, and the need to strengthen other financial
management controls such as reconciliation processes, collectively impair
Education’s ability to accumulate, analyze, and present reliable financial
information. In addition, according to Education’s auditor, although the
department implemented a new financial management system during fiscal
year 2002, issues associated with the transition to the new system
contributed to difficulties in providing reliable, timely information for
managing current operations and timely reporting of financial information
to central agencies; therefore, Education still did not substantially comply
with FFMIA’s requirements.

Education also needs to address identified computer security weaknesses
in its financial management and other information systems. In September
2001, we reported that Education had made progress in correcting certain
information system control weaknesses.14 At the same time, we identified
weaknesses in Education’s systems that place critical financial and
sensitive grant information at risk of unauthorized access and disclosure,
and key operations at risk of disruption. We recommended that Education
correct certain information system control weaknesses and fully
implement a comprehensive departmentwide computer security
management program. In response, Education stated that it had developed
a corrective action plan and is taking steps to further strengthen and
develop a more comprehensive information security program. In addition,
Education’s auditor reported that for fiscal year 2002, the department
made progress in strengthening controls over its information technology
processes but needs to continue efforts to develop, implement, and

 U.S. General Accounting Office, Education Information Security: Improvements Made,
but Control Weaknesses Remain, GAO-01-1067 (Washington, D.C.: Sept. 12, 2001).

Page 9                                                                 GAO-03-872T
                  maintain an agencywide risk-based information security plan, programs,
                  and practices to provide security throughout the life cycle of all systems.

                  In closing, Mr. Chairman, I want to reiterate that Education is taking
                  actions and making substantial progress in addressing major challenges
                  related to its student aid programs and financial management. At the same
                  time, some difficult issues remain that must be resolved before Education
                  is able to produce relevant, reliable, and timely information to efficiently
                  and effectively manage the department and provide full accountability to
                  its stakeholders.

                  Mr. Chairman, this concludes my statement. I would be happy to answer
                  any questions you or other members of the Subcommittee may have.

                  For information about this statement, please contact Linda Calbom,
Contact and       Director, Financial Management and Assurance, at (202) 512-9508, or
Acknowledgments   Robert Owens, Assistant Director, at (202) 512-8579. You may also reach
                  them by E-mail at calboml@gao.gov or owensr@gao.gov. Individuals who
                  made key contributions to this testimony include Lisa Crye and Diane
                  Morris. Numerous other individuals made contributions to the work
                  supporting this testimony.

                  Page 10                                                          GAO-03-872T
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