Several NASFAA Recommendations Incorporated in FSA Long-Term Strategic Plan

By Owen Daugherty, NASFAA Staff Reporter

Federal Student Aid (FSA) last week published the final version of its long-term strategic plan and made several changes from its previous draft, including some revisions reflecting comments and suggestions NASFAA submitted.

The strategic plan charts the course for FSA through 2024 and beyond, outlining many changes and improvements to its existing offerings as well as several new targets, thresholds, and objectives.

Taking into account comments that NASFAA submitted during the 30-day public comment period, one noteworthy change from the draft to the final version is how FSA will look to increase engagement with and oversight of its partner institutions, which is one of the organization’s five strategic goals.  

NASFAA highlighted the importance of viewing that strategic goal as a two-way street when it comes to communication, affording institutions of higher education the ability to provide FSA feedback.

“If FSA seeks to adjust and rebalance its relationship with institutions, FSA must focus on creating additional formal and informal opportunities to learn and hear from schools,” NASFAA wrote in its submitted comments, which were reflected in changes FSA made to the final plan. 

The organization wrote that through existing tools and “programmatic processes, FSA will proactively assess program review and other oversight findings in the context of training and technical assistance provided to institutions to be sure that our training and technical assistance is effective.”

If the same findings appear in multiple institutions’ program reviews, FSA will work with the Department of Education (ED) to determine if changes or clarifications are necessary, and to revise training and technical assistance programs accordingly, the final plan says.

A large portion of the strategic plan focuses on how FSA’s role in the higher education and student loan landscape has changed dramatically over the years, to now essentially serving as one of the country’s largest banks, which FSA noted it was not designed to be.

As such, one of FSA’s outlined strategic goals is to enhance the management and transparency surrounding the massive student loan portfolio it is tasked with overseeing.

Following a suggestion from NASFAA, FSA added an objective, milestone, and, accomplishment marking its progress toward the strategic goal, noting that it implemented nearly 40 quarterly loan portfolio reports on the FSA data center, while establishing common definitions and governance for loan portfolio concepts and creating a foundation for data science, advanced analytics, and modeling work to better its portfolio management and transparency. 

NASFAA also recommended that FSA make a plan to streamline and consolidate all required reports on its website by storing strategic plans, performance plans, reports, and priority goals on the same FSA webpage to help it achieve the strategic goal.

And while that recommendation was incorporated, two other recommendations for that goal were left out: a summary posted on a single department webpage outlining FSA’s reporting requirements and their due dates, and an increased effort from FSA to publicize when these reports or plans are published.

Though FSA did not include anything related to the transparency in verification recommendations NASFAA made, ED did, during the FSA Conference, provide an update on the verification rate, which has decreased compared to previous years.

NASFAA also made several comments with regard to trends outlined by FSA in the report, many related to FSA’s management of the student loan portfolio. FSA also made several changes to performance metrics and targets, some presumably made due to the impact from the coronavirus. 


Publication Date: 1/19/2021

Joel T | 1/21/2021 10:4:04 AM

A round of applause for Peter G. :)

Peter G | 1/20/2021 7:31:32 PM

I think FSA needs to not just use Program Review data to assess their training and technical assistance, but also to assess the regulations, guidance, and tools that undergird the issue at hand, and at least in rare cases also advise Congress when statutory change may be advised. If you've built a system that people can't comply with, sure training may be the issue, but it may be the system itself.

It's easy to pick on R2T4, but enrollment reporting is another issue that shows up perpetually as a top finding, and sure, school error is a factor, but the reality is it's a digital reporting system that's basically just a 30 year old paper system jammed into a digital shell and for many schools I talk to it sucks up a lot of resources to even try to make it run as it currently exists. Schools that report directly to NSLDS seem to share a common set of issues, and schools that report via NSC have another common set of issues.

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