Advisory Committee on Student Financial Assistance
November 30, 1999
The Honorable James M. Jeffords
Dear Senator Jeffords:
The Advisory Committee on Student Financial Assistance (the Committee) was established by Congress in the Higher Education Amendments of 1986 and serves as an independent source of advice and counsel on student aid policy to Congress and the Secretary of Education. Pursuant to its original legislative charge, the Committee has been monitoring the systems and contracts that comprise the Title IV student aid delivery system on an ongoing basis.
In the 1998 reauthorization of the Higher Education Act, the Committee was further charged in Public Law 105-244 with evaluating the implementation of a performance-based organization (PBO) and the modernization of the Department of Education?s (ED?s) systems and contracts and reporting recommendations annually. Pursuant to that charge, we have completed an assessment of the first year of the PBO?s operation, including a detailed review of all PBO plans and major technical documents. The purpose of this letter is to report on the results of that review and transmit our recommendations.
The Committee fully understands the challenge and complexity of implementing the federal government?s first PBO while simultaneously modernizing student aid delivery. We wish to commend Secretary Riley and the PBO?s Chief Operating Officer (COO), Greg Woods, for their commitment to the transformation of the organization and interest in improvements to the delivery of federal Title IV student aid funds. In particular, the Committee commends Mr. Woods for the enthusiasm and energy he has shown, the progress made to date, and his willingness to communicate with the higher education community. Under Mr. Woods? leadership, the PBO seems to be well on its way to assembling a core of talented, experienced managers capable of dramatically improving student aid delivery. Throughout higher education, expectations are very high for both the PBO and modernization process.
While a definitive evaluation of the PBO?s implementation and performance in modernization would be premature after only one year of monitoring, it is nevertheless possible to assess overall direction, priorities, and opportunities for improvement. To help us finalize our first-year evaluation and formulate recommendations, the Committee conducted a meeting in Washington, D.C. in early November to establish a community consensus on major issues.
During that meeting, we found significant good will toward and optimism about the PBO and modernization process. However, these generally positive feelings were tempered by fundamental concerns about structure and direction in certain areas of organization, modernization strategy and plans, and the centerpiece of the PBO?s original vision, Access America for Students (AAS). The community?s concerns were primarily in four areas:
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an emphasis on short-term systems solutions rather than systems and database integration;?
the inappropriateness of AAS as a vehicle for systems integration and modernization.Higher education representatives emphasized unanimously at our meeting that these concerns require resolution before proceeding with the expenditure of scarce resources for modernization. They stressed that a timely resolution of these concerns would greatly enhance the likelihood of a successful implementation of the PBO and completion of the modernization effort.
Based on these concerns, which are shared by our members, the Committee feels it would be prudent for ED to undertake a comprehensive reassessment in the four areas above. In conducting that reassessment, we suggest that ED give serious consideration to the following specific changes:
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reassign to the Office of Postsecondary Education (OPE) all policy functions, responsibilities--including accreditation and institutional oversight--and the appropriate staff;?
refocus the PBO's resources and activities on systems integration, with highest priority placed on creating an integrated Title IV database as soon as possible; and conduct a cost/benefit analysis before substituting short-term solutions?systems wrappers and middleware?for lasting systems and database integration;?
ensure that a System Architecture, Transition Plan, and Acquisition and Procurement Strategy meeting the requirements of the Department?s own lifecycle management policies are completed in a timely manner before proceeding with systems modifications;?
refocus Access America for Students (AAS) on integration of the origination and disbursement subsystem and eliminate entirely its dependence on creation of a new student account system.Given the complexity and importance of the task, the Committee recommends that the PBO conduct this reassessment and make appropriate modifications to its organization and system development strategy, plans and schedules in a timely manner.
As always the Advisory Committee stands ready to help in any way we can.
Sincerely,
/s/
Dr. Juliet V. Garcia
Chairperson
cc: The Honorable William F. Goodling (Identical original letter sent)
The Honorable Richard W. Riley (Identical original letter sent)
Advisory Committee members
Members of the Senate Health, Education, Labor and Pensions Committee
Members of the House Committee on Education and the Workforce
Members of the Subcommittee on Postsecondary Education, Training
and Life-Long Learning