The Department of Education (ED) has informed schools participating in the Quality Assurance (QA) Program that QA will be discontinued in its current form at the conclusion of the 2016-17 award year. QA allows schools to establish their own customized criteria for selecting Title IV applicants to verify and determining the documentation requirements, based on an ongoing analysis of elements most subject to error among the school’s applicant pool. QA selection and documentation criteria currently substitute for the federally-defined verification process in subpart E of the General Provisions regulations. QA schools will need to transition to those regulations when the program ends.
ED explains in a letter sent to QA schools that the QA program provided the basis for development of the current verification protocols that adopt a similar targeted approach. That, along with the implementation of verification tracking groups and the development of the IRS-FAFSA Data Retrieval Tool (DRT), led ED to conclude that the the QA program has met its original intent and purpose.
Although the letter does not mention it, there have been increasing calls for a move to prior-prior year income, with a good deal of attention on that issue by Congress. Such a move would increase the efficacy of the IRS-DRT and lessen the need for verification by all schools.
The letter from ED points out that the law authorizing the QA Program, section 487A(b) of the Higher Education Act, limits the program to verification. Further opportunities for innovation to areas other than verification under the QA section of law require statutory change, which ED is also considering recommending.
To allow participating schools sufficient time to transition to compliance with regular verification provisions, QA schools will not be required to complete the normal FSA assessments or use the ISIR Analysis Tool for the 2016-17 award year.
Many QA schools expressed dismay at the discontinuance of the program, especially given that ED has yet to fully implement the type of targeted verification that was ultimately promised during program integrity rule negotiations. ED will provide additional information and assistance to QA schools within the next few weeks.
Publication Date: 8/28/2015