Gaps in Federal Student Aid Contract Oversight and System Testing Need Immediate Attention - GAO-25-107396

Oct 15, 2026

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This GAO report to congressional requesters examines how the Department of Education’s Office of Federal Student Aid oversees the FAFSA Processing System (FPS) contract and applies systems testing practices. Findings highlight gaps in deploying contractual requirements, tracking requirement status, validating contractor performance data, and ensuring contracting and project staff meet certification and specialized training needs. Testing shortcomings limit traceability to underlying requirements and weaken future user testing planning, increasing risk of significant deficiencies at deployment.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages62

Reading Time2 h 36 min

AccessFree to download

What GAO Found

Why GAO Did This Study

What GAO Recommends

Background

FSA Was Unable to Report the Current Status of FPS or Causes for Delays

FSA Established Two Contract Oversight Approaches but Did Not Fully Implement Them

FSA Could Not Always Demonstrate That Key Oversight Staff Had Necessary Qualifications

FSA Did Not Fully Apply Disciplined System Testing Practices for FPS

Conclusions

Recommendations for Executive Action

Agency Comments, Third-Party Views, and Our Evaluation

Appendix I Objectives, Scope, and Methodology

DEPARTMENT OF EDUCATION Gaps in Federal Student Aid Contract Oversight and System Testing Need Immediate Attention Report to Congressional Requesters September 2025 GAO-25-107396 United States Government Accountability Office Accessible Version GAO Highlights DEPARTMENT OF EDUCATION Gaps in Federal Student Aid Contract Oversight and System Testing Need Immediate Attention GAO-25-107396 September 2025 A report to congressional requesters. For more information, contact: Marisol Cruz Cain [at](at cruzcainm@gao.gov)[ cruzcainm@gao.gov](at cruzcainm@gao.gov). What GAO Found The Department of Education’s Office of Federal Student Aid (FSA) manages the Free Application for Federal Student Aid (FAFSA), which students and parents submit to determine a student’s eligibility for receiving financial aid. The FAFSA Processing System (FPS)—the system that underpins federal student aid—processes these applications (see figure) . Overview of the Free Application for Federal Student Aid (FAFSA) Process Accessible Data for Overview of the Free Application for Federal Student Aid (FAFSA) Process 1. Applicant completes the FAFSA form 2. Education processes aid forms via the FAFSA Processing System 3. Education sends reports to applicant, colleges, and state financial aid office 4. State financial aid office sends state aid eligibility report to colleges 5. Colleges prepare financial aid offers for students Sources: GAO analysis of Department of Education procedures and logo; [Golden Sikorka/stock.adobe.com](Golden Sikorka/stock.adobe.com) (icons) . | GAO-25-107396 In September 2024, GAO testified that nine of the 25 contractual requirements that defined FPS were not deployed. Examples of the nine requirements not yet deployed included allowing FSA to (1) make corrections to FAFSA applications and (2) modify eligibility rules and requirements. Education officials had stated that these remaining requirements would be deployed by 2026. However, as of May 2025, Education was unable to provide the status of the complete system. FSA officials said they could not readily provide the status because they were no longer tracking requirements. This raises questions about FSA ensuring required work under the contract is being performed. Further doubts about contract oversight surfaced when GAO determined that FSA was not validating contractor performance data. Although FSA had established processes for monitoring contractor performance, it did not fully implement them. In addition, FSA could not demonstrate that contracting officer’s representatives and project management staff had complied with certification requirements. The agency also did not ensure key acquisition staff had specialized training related to the systems development methodology used to develop FPS. Testing of IT systems is critically important. Although leading practices highlight the importance of thoroughly testing IT systems prior to deployment, FSA did not fully apply these practices. For example, test cases—used to determine whether an application, system, or system feature is working as intended—lacked information that would allow fortraceability to underlying requirements. Contributing to this lack of traceability was the absence of agency guidance on what information to include in a test case. In addition, FSA does not have a plan to guide future FPS user testing efforts. This increases the risk that testing will be incomplete and inconsistently executed. Overall, such testing shortfalls can lead to the discovery of significant system deficiencies when deployment occurs. Why GAO Did This Study In December 2023, FSA, the largest provider of student financial aid in the nation, deployed a new system with limited functionality to process student aid applications. However, the system—FPS—had availability issues, recurring errors, and long wait times that affected students’ability to receive aid. Since then, FSA has continued to wor

FAQs

What oversight gaps did GAO identify for the FPS contract?

GAO found contract oversight gaps including an inability to report complete system status, lack of tracking requirements, and incomplete implementation of monitoring processes. GAO also determined FSA was not validating contractor performance data.

How did GAO assess systems testing for FPS?

GAO evaluated whether FSA applied leading systems testing practices. The report notes that test cases lacked information to ensure traceability to underlying requirements and that agency guidance on what to include in test cases was absent.

What recommendations did GAO make to the Department of Education?

GAO made seven recommendations, including improving contract oversight, ensuring contracting staff receive proper certifications and training, and developing testing guidance and a plan for testing with system users linked to requirements.

Oct 15, 2026

Uploaded by Melati